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Anti money laundering in Mexico for non financial businesses: vulnerable activities, client identification, monthly notices, cash bans and fines

Last verified: 2026-10-26 · Status: Changing

Mexico's anti money laundering law reaches beyond banks: businesses that habitually carry out one of sixteen vulnerable activities, such as non bank lending, real estate development, vehicle, jewelry or art sales, virtual asset exchange, leasing, armoring or corporate services, must register, know their clients and beneficial owners and file notices with the Ministry of Finance. Each activity has its own identification and notice thresholds in UMA; notices are due by the 17th of the following month, suspicious operations within 24 hours, and records must be kept for ten years. The same law bans cash payments for real estate from 8,025 UMA and for vehicles, jewelry, art and shares from 3,210 UMA, and omitted notices or prohibited cash payments are fined up to 65,000 UMA or 100 percent of the operation.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Peso amounts set in UMA use the 2026 daily UMA of MXN 117.31, in force since 1 February 2026 (INEGI publication in the DOF of 9 January 2026, as cited in IMSS Technical Council agreement ACDO.AS2.HCT.270126/9.P.DIR). Conversions are for orientation only.

Key facts

Deadline for a suspicious operation notice by vulnerable activity businesses	24 hoursLFPIORPI art. 18, section VI, as of 2026-10-26 · in force
Notice threshold, real estate development or brokerage	8025 UMALFPIORPI art. 17, section V, as of 2026-10-26 · in force
Notice threshold, vehicle sales	6420 UMALFPIORPI art. 17, section VIII, as of 2026-10-26 · in force
Notice threshold, non bank loans and guarantees	1605 UMALFPIORPI art. 17, section IV, as of 2026-10-26 · in force
Notice threshold per client operation, virtual asset exchange	210 UMALFPIORPI art. 17, section XVI, as of 2026-10-26 · in force
Voting rights above which a person is a beneficial owner by control	25 %LFPIORPI art. 3, section III, as of 2026-10-26 · in force
Maximum fine for omitted notices or prohibited cash operations (or 100 percent of the operation if greater)	65000 UMALFPIORPI art. 54, section III, as of 2026-10-26 · in force
Period over which operations with a client are accumulated for notice purposes	6 monthsReglamento LFPIORPI art. 7, as of 2026-10-26 · in force

The rule

1. Vulnerable activities. Article 17 lists the activities that trigger duties when carried out habitually or professionally, each with an identification threshold (from which client identification is required) and a notice threshold (from which a notice to the Ministry of Finance, SHCP, is required). They include gaming and raffles; non bank credit, service and prepaid cards and stored value instruments; traveler's checks; loans or guarantees by non financial lenders; construction, development or brokerage of real estate sales; receipt of funds for real estate developments for sale or rent; precious metals, stones, jewelry and watches; art; vehicles (air, sea and land); armoring; cash and valuables transport and custody; independent professional services when acting for a client in property deals, asset or account management, company formation or corporate operations; notaries and public brokers; non profit donations; customs agencies for listed goods; property leases; and virtual asset exchange platforms, including those serving Mexican citizens from abroad. Operations below the identification threshold carry no duty, but operations accumulated over six months above the notice threshold may be treated as subject to notice.
Cost to do it: Registration and notices are free; the cost is a compliance program (manual, training, monitoring, audit) proportional to risk.
Example: A non bank lender that grants a loan of MXN 250,000 must identify the borrower and file a notice, since the notice threshold for loans is 1,605 UMA (MXN 188,282.55) and loans have no lower identification threshold. / About USD 13,395 against a notice line of about USD 10,088.Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI), DOF 17 October 2012, art. 17 reformed by decree DOF 16 July 2025; Reglamento, art. 7 reformed DOF 27 March 2026, LFPIORPI art. 17, sections I to XVI and last paragraphs; Reglamento art. 7, 2025-07-16 official text · verified 2026-10-26 · changed: Decree DOF 16 July 2025 restated thresholds, added receipt of funds for real estate developments (section V Bis), notaries' formalizations, public and private facilitators under the mediation law, and operations through trusts; the regulation reform of DOF 27 March 2026 detailed how operations are accumulated per client and type of operation over up to six months.

2. Core duties. Anyone carrying out a vulnerable activity must (I) identify and know clients directly and verify identity with officially recognized documents, keeping copies; (II) in business relationships, obtain information on the client's activity or occupation, based among others on its tax registry filings; (III) for companies, trusts and other legal arrangements, obtain documents identifying the beneficial owner, and for individuals, a statement on whether a beneficial owner exists; (IV) keep supporting information and records for at least ten years at the address registered with the SHCP; (IV Bis) register, update or deregister in the vulnerable activities registry through the SAT portal, which requires an active tax registration and advanced electronic signature (e.firma); (V) allow verification visits; and (VI) file notices and reports. A notice is also due within 24 hours of a suspicion or of information that funds may be linked to money laundering, even if the operation did not take place. The 2025 reform added a risk based assessment, an internal policies manual covering politically exposed persons (applied across majority owned branches and affiliates, including foreign ones), annual training, automated transaction monitoring, and an annual internal or independent external audit; these last duties apply on the dates set by the general rules.
Cost to do it: Typical costs: KYC tools and screening lists, a monitoring system, staff training and, depending on risk, an independent external auditor each calendar year.
Example: A car dealer selling a vehicle to a company must obtain and copy the representative's ID, the company's documents and those identifying its beneficial owner, and keep them for ten years. / For a US buyer company, the dealer must identify the individuals who ultimately control it, for example those holding more than 25 percent of the votes.LFPIORPI art. 18 reformed and sections IV Bis and VII to XI added by decree DOF 16 July 2025, transitory articles Second and Third; Reglamento arts. 7 Bis and 12 reformed DOF 27 March 2026, LFPIORPI art. 18; Reglamento arts. 7 Bis and 12, 2025-07-16 official text · verified 2026-10-26 · changed: Decree DOF 16 July 2025 extended record keeping to ten years, added the 24 hour suspicion notice, the registry duty and the new program duties (sections VII to XI), whose start dates depend on the general rules (transitory Third).

3. Beneficial owner and compliance officer. The beneficial owner is the individual or group who ultimately benefits from an operation or exercises effective control of a legal entity client, meaning the ability to impose decisions at shareholders' meetings or appoint or remove most directors, to hold rights to vote more than 25 percent of the capital, or to direct management, strategy or main policies; the concept equals final beneficiary and real owner. Legal entities and those acting through trusts must appoint and keep a compliance officer before the SHCP, who must be trained every year; until one is appointed and accepted, the board or sole administrator is responsible. Separately, all commercial companies must answer authority requests to identify their beneficial owners, report share transfers recorded in their share registry, and register beneficial owner information in an electronic system operated by the Ministry of Economy.
Cost to do it: Failing the beneficial owner duties of arts. 33 Bis and 33 Ter is fined MXN 234,620 to MXN 1,173,100 (2,000 to 10,000 UMA; USD 12,571 to USD 62,854).
Example: A Mexican S.A. de C.V. owned 60 percent by a US LLC must trace the LLC to the individuals who control it and register them in the Ministry of Economy system. / The 25 percent voting line matches many foreign registers, but Mexico also counts control through contracts or management influence.LFPIORPI arts. 3, section III, 20, 33 Bis and 33 Ter (reformed and added by decree DOF 16 July 2025), Arts. 3, section III, 20, 33 Bis and 33 Ter, 2025-07-16 official text · verified 2026-10-26 · changed: Decree DOF 16 July 2025 set the voting test at more than 25 percent and added arts. 33 Bis to 33 Quáter on beneficial owner registration for all commercial companies.

4. Notice deadlines. Notices are filed electronically, in the official formats published in the DOF, no later than the 17th of the month following the operation. Each notice contains data on the reporting party, the client and its beneficial owner and occupation, and a description of the operation. Filing up to 30 days late is fined as a late notice; filing more than 30 days late is treated as an omitted notice. Those who stop carrying out vulnerable activities must deregister, or they must keep filing.
Cost to do it: Late notice (up to 30 days): MXN 23,462 to MXN 234,620 (200 to 2,000 UMA). Over 30 days late: treated as omitted, MXN 1,173,100 to MXN 7,625,150 or 10 to 100 percent of the operation.
Example: An art dealer that sold a painting for 5,000 UMA on 12 May must file the notice by 17 June. / The notice line for art is 4,815 UMA, about USD 30,264.LFPIORPI arts. 23, 24 and 53, section III, reformed by decree DOF 16 July 2025; Reglamento art. 12, LFPIORPI arts. 23, 24 and 53; Reglamento art. 12, 2025-07-16 official text · verified 2026-10-26

5. Cash ban. Paying or accepting payment in coins and bills, in pesos or foreign currency, or in precious metals is prohibited, even if the cash passes through a financial institution, for (I) creating or transferring real rights over real estate from 8,025 UMA; (II) transfers of vehicles (air, sea or land) from 3,210 UMA; (III) watches, jewelry, precious metals and stones, per piece or lot, and art from 3,210 UMA; (IV) gaming tickets and prizes from 3,210 UMA; (V) armoring services from 3,210 UMA; (VI) transfers of shares or partnership interests from 3,210 UMA; (VII) use or enjoyment rights over property, vehicles or armoring from 3,210 UMA a month; and (VIII) consignment of payment for any of those operations, at the UMA value on the day of payment.
Cost to do it: Breach: MXN 1,173,100 to MXN 7,625,150 (10,000 to 65,000 UMA; USD 62,854 to USD 408,553) or 10 to 100 percent of the operation's value, whichever is greater, for anyone who takes part in a prohibited operation (art. 53, section VII).
Example: A buyer cannot pay any part of the price of a MXN 1,500,000 pickup truck in cash, because the vehicle exceeds 3,210 UMA (MXN 376,565.10). / The lines are about USD 50,441 for real estate and about USD 20,176 for vehicles, jewelry, art and shares.LFPIORPI art. 32 reformed by decree DOF 16 July 2025, Art. 32, sections I to VIII, 2025-07-16 official text · verified 2026-10-26 · changed: Decree DOF 16 July 2025 reworded art. 32, added section VIII on consignments and allowed general rules to extend the ban to fungible goods.

6. Sanctions and crimes. The SHCP fines (I) failures to answer requests, breaches of art. 18 duties, late notices and defective notices with 200 to 2,000 UMA; (II) breaches of the beneficial owner duties with 2,000 to 10,000 UMA; and (III) omitted notices and prohibited cash operations with 10,000 to 65,000 UMA or 10 to 100 percent of the value of the operation, whichever is greater. Fines are tax credits collected by the tax authority. The SHCP does not fine, once, a party that spontaneously complies before any verification and acknowledges the breach; later spontaneous corrections get up to 50 percent off. Giving false information for notices, altering it or filing illegible data is punished with two to eight years in prison, including negligent cases unless corrected spontaneously. Money laundering itself is punished with five to fifteen years in prison and 1,000 to 5,000 days fine, and companies can face criminal consequences such as suspension and closure.
Cost to do it: Fine bands in 2026: MXN 23,462 to MXN 234,620; MXN 234,620 to MXN 1,173,100; MXN 1,173,100 to MXN 7,625,150 or up to 100 percent of the operation.
Example: A broker that never filed the notice for a MXN 12,000,000 house sale faces the greater of MXN 1,173,100 to MXN 7,625,150 or MXN 1,200,000 to MXN 12,000,000 (10 to 100 percent). / About USD 642,956 sale; exposure up to about USD 642,956.LFPIORPI arts. 52 to 55 and 62 reformed by decree DOF 16 July 2025; Código Penal Federal arts. 11 Bis and 400 Bis, LFPIORPI arts. 52, 53, 54, 55 and 62; CPF arts. 11 Bis and 400 Bis, 2025-07-16 official text · verified 2026-10-26 · changed: Decree DOF 16 July 2025 reformed arts. 53 to 55 and 62 (new 2,000 to 10,000 UMA band, the once only waiver and 50 percent reduction, and negligent false information offences).

Activity	Identification from	Notice from
Gaming, raffles and prizes	325 UMA (MXN 38,125.75; USD 2,043)	645 UMA (MXN 75,664.95; USD 4,054)
Non bank loans and guarantees	All operations	1,605 UMA (MXN 188,282.55; USD 10,088)
Real estate development, construction or brokerage of sales	All operations	8,025 UMA (MXN 941,412.75; USD 50,441)
Receipt of funds for real estate developments for sale or rent	All operations	8,025 UMA (MXN 941,412.75; USD 50,441)
Precious metals, stones, jewelry and watches	805 UMA (MXN 94,434.55; USD 5,060)	1,605 UMA (MXN 188,282.55; USD 10,088)
Art sales or auctions	2,410 UMA (MXN 282,717.10; USD 15,148)	4,815 UMA (MXN 564,847.65; USD 30,264)
Vehicles, new or used (air, sea, land)	3,210 UMA (MXN 376,565.10; USD 20,176)	6,420 UMA (MXN 753,130.20; USD 40,352)
Armoring of vehicles or real estate	2,410 UMA (MXN 282,717.10; USD 15,148)	4,815 UMA (MXN 564,847.65; USD 30,264)
Cash and valuables transport or custody	All operations	3,210 UMA, or always if the amount is unknown
Donations received by non profits	1,605 UMA (MXN 188,282.55; USD 10,088)	3,210 UMA (MXN 376,565.10; USD 20,176)
Property leases (monthly value)	Above 1,605 UMA a month	3,210 UMA a month
Virtual asset exchange platforms	All operations	210 UMA per client operation, or a fee of 4 UMA
Notaries: transfers of real estate rights	All operations	8,000 UMA (highest of price, cadastral or market value)
Notaries: company formation, capital changes, share sales	All operations	Always

Selected vulnerable activities and thresholds in 2026 (LFPIORPI art. 17; UMA MXN 117.31; USD at MXN 18.6638)

Operation	Cash banned from	MXN 2026	About USD
Real estate rights	8,025 UMA	MXN 941,412.75	USD 50,441
Vehicles, jewelry, watches, precious metals and stones, art, gaming tickets and prizes, armoring, shares and partnership interests	3,210 UMA	MXN 376,565.10	USD 20,176
Use or enjoyment rights over property, vehicles or armoring	3,210 UMA a month	MXN 376,565.10	USD 20,176

Cash payment bans (LFPIORPI art. 32)

Worked example

A Mexican subsidiary of a foreign group starts leasing commercial space it owns. Monthly rent of MXN 450,000 exceeds 3,210 UMA (MXN 376,565.10), so each month it must identify the tenant and its beneficial owner and file a notice by the 17th of the next month (LFPIORPI arts. 17, section XV, and 23). The rent cannot be paid in cash (art. 32, section VII). As a legal entity it must appoint a compliance officer before the SHCP (art. 20) and register in the vulnerable activities registry with its e.firma (Reglamento art. 12).
If it forgets the notices for a year, each omitted notice risks the greater of MXN 1,173,100 to MXN 7,625,150 or 10 to 100 percent of the operation; coming forward spontaneously before any verification, for the first time, avoids the fines (art. 55).

Step by step

1. Screen every revenue line against the sixteen activities of LFPIORPI art. 17 and their thresholds, including side businesses such as leases or intra group lending.
2. Register in the vulnerable activities registry through the SAT portal with the company e.firma before the first operation, and appoint a compliance officer (Reglamento art. 12; LFPIORPI art. 20).
3. Build KYC files: ID copies, occupation or activity, and beneficial owner documents for legal entity clients (LFPIORPI art. 18, sections I to III).
4. Calendar the 17th of each month for notices and keep a 24 hour route for suspicious operations (arts. 18, section VI, and 23).
5. Block cash above the art. 32 lines in contracts, invoicing and point of sale systems.
6. Prepare the risk assessment, manual, training, monitoring and annual audit required by the 2025 reform as the general rules phase them in, and keep all records ten years.

Common traps

Thinking AML is only for banks: listed activities apply to any business that carries them out habitually or professionally, including foreign owned companies (LFPIORPI art. 17).
Splitting operations: operations with the same client are accumulated over six months for notice purposes (art. 17 and Reglamento art. 7).
Accepting cash through a bank deposit: the ban applies even when cash is paid through a financial institution (art. 32).
Missing the 30 day line: a notice filed more than 30 days late is fined as omitted, at 10,000 to 65,000 UMA or up to 100 percent of the operation (arts. 53 and 54).
Forgetting to deregister: a registered business that stops the activity must deregister or keep filing (Reglamento art. 12).
Overlooking group policies: the 2025 reform requires the internal policies manual to apply to majority owned branches and affiliates, including foreign ones (art. 18, section VIII).

Sources

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