Client Alert – Mexico Publishes Landmark Reform to Anti-Money Laundering Law: Major Compliance and Reporting Implications for Businesses

Overview

On July 17, 2025, Mexico published in its Official Gazette a comprehensive reform to the Federal Law for the Prevention and Identification of Transactions Involving Illicit Funds (“Anti-Money Laundering Law” or “AML Law”). This marks the most significant overhaul since its enactment in 2012. The reform broadens the scope of “vulnerable activities,” introduces new compliance obligations, tightens beneficial ownership requirements, and expands enforcement powers.

Key Takeaways

Trusts Now Fully Subject to AML Obligations
The reform confirms that trusts (fideicomisos) are fully subject to AML reporting when engaged in vulnerable activities. Trustees and fiduciaries must now implement due diligence, recordkeeping, and transaction monitoring policies.

New “Vulnerable Activity”: Real Estate Development
The receipt of funds for real estate developments intended for sale or lease is now expressly categorized as a vulnerable activity, regardless of the legal structure used. This directly impacts developers, agents, and intermediaries.

Expansion of Virtual Asset Rules
Entities other than licensed financial institutions that exchange or handle virtual assets are now under stricter AML scrutiny. The scope of obligations includes:
– Enhanced reporting of transactions.
– New recordkeeping and audit mandates.
– Implementation of automated monitoring systems.

Enhanced Obligations for All Covered Entities
Entities performing vulnerable activities must now:
– Obtain direct knowledge of their clients and users.
– Retain supporting documentation, emails, and images for at least 10 years.
– Undergo annual audits (internal or external).
– Establish automated compliance mechanisms.
– Conduct enhanced due diligence for Politically Exposed Persons (PEPs).

Revised Beneficial Ownership Rules
– Only natural persons may now qualify as beneficial owners.
– The ownership threshold is reduced from 50% to 25% of voting shares.
– All commercial entities must identify and report their beneficial owners via the government’s Mercantile Companies Portal (PSM).

Tax Authority Empowerment
The Ministry of Finance (SHCP) is now explicitly recognized as a victim under criminal proceedings for money laundering (Article 400 Bis of the Federal Criminal Code). It may file criminal complaints directly with prosecutors.

Effective Date and Transition
The reform takes effect immediately upon publication (July 17, 2025), with a 12-month window for regulatory agencies to issue implementing rules. However, companies should begin updating their compliance frameworks now.

What Companies Should Do Now

– Evaluate whether their operations fall under the expanded list of vulnerable activities.
– Review and update AML policies and data retention systems.
– Reassess client onboarding and KYC procedures, especially for high-risk individuals.
– Verify beneficial ownership structures and prepare to report accordingly.
– Anticipate audit requirements and establish automated monitoring tools where applicable.

These changes will significantly affect financial services providers, real estate developers, tech startups, cryptocurrency platforms, and other actors in the digital economy.

FisherBroyles Can Help

Our Mexico-focused regulatory and compliance team is available to assess your company’s exposure and support implementation. Please contact:

For additional information, please contact   

Sergio Legorreta at [email protected] or Jair Bravo, Partner, [email protected] with any questions or more specific situations.

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