Amendment to the General Rules of the Anti-Money Launde

The new Rules further develop and define the way new obligations incorporated into the LFPIORPI must be complied, establishing new criteria, procedures, and compliance mechanisms.

This implementation will occur in phases; therefore, it is important to identify the regulatory obligations and corresponding actions that must be adopted over next months.

A. First Sections of Amendments: In force on November 30, 2026

  I. Key Amendments related to Vulnerable Activities

• Donations: The Rules clarify the obligated entities under this Vulnerable Activity.
• Non-Profit Organizations: A specific regulatory regime is established for specific associations and entities.
• Time of occurrence: Criteria are established to determine when a Vulnerable Activity is deemed to have occurred.
• Penalty for Non-Compliance: Not applicable.

  II. Key Amendments to the AML Portal:

• Registration and Enrollment: New procedures are introduced for trusts, other legal vehicles, and Virtual Asset Service Providers (VASPs).
• Late Registration: It will produce legal effects as of the date identified in the corresponding filing.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  III. Key Amendments Regarding Politically Exposed Persons (PEPs)

• PEP Identification: The Rules establish the criteria for identifying Politically Exposed Persons, including certain family members and associated people.
• PEP Search: The Rules enable the Financial Intelligence Unit app “PEP Search 2.0” to verify Mexican Politically Exposed Persons.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  IV. Key Amendments to the Internal Policies Manual

• Minimum Requirements: The Rules establish the mandatory minimum content for the Internal Policies Manual, which must include the policies, criteria, and necessary procedures to comply with AML obligations and Risk management.

• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

B. New Compliance Framework Implementation: Throughout 2027

  V. Main Implications of the Training and Personnel Screening Requirements

• Initial Training Period: The Rules establish the first training from January 1, 2027, through December 31, 2027.

• Training Requirement: Personnel involved in AML activities must receive annual training.
• Personnel Screening: Procedures must be established to verify the technical qualifications, experience, and integrity of personnel involved in AML activities.

Effective date March 1, 2027

• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  VI. Key Implications of the Risk-Based Approach - Effective March 1, 2027

Individuals, entities and vehicles carrying out Vulnerable Activities must comply with the following:

• Risk-Based Approach: Implement a methodology to identify, assess, and mitigate Risks associated with Vulnerable Activities.
• Risk Classification: Classify Clients or Users as Low, Medium, or High Risk, and such classification must be reviewed periodically.
• Know Your Customer/User Requirements: Establish a Transactional Profile and monitor it through an alert system and apply enhanced measures where appropriate.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  VII.  Key Implications Regarding Ultimate Beneficial Owners - Effective March 1, 2027

• Identification Procedure: The Rules establish criteria and an order of priority for identifying the Ultimate Beneficial Owner, and the identification process must be documented.
• Identification Requirements: The data and documentation required to be collected are clarified and reduced.
• Exceptions: Certain circumstances are incorporated under which collecting specific Ultimate Beneficial Owner information will not be mandatory.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

VIII. Key Implications of Electronic Notifications - No later than April 2027

• The Portal is designated as the official channel for notifications, and it must be consulted on every business day. Notification messages must be opened within three business days; otherwise, they will be deemed served on the fourth business day.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  IX.  Key Implications of Automated Compliance Mechanisms - Effective June 1, 2027

• Automated mechanisms must be implemented to manage Client or User files, monitor and aggregate transactions, assess Risk Levels and Transactional Profiles, and generate the corresponding alerts.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

  X. Key Implications of Suspicious Activity Reports

• Effective Date: Six months after the entry into force of the Resolution amending the official Notice and Report forms.
• The Rules establish new reporting obligations requiring the submission of reports within 24 hours when conduct, facts, or indicators suggesting possible money laundering activities are detected, as well as in certain situations involving individuals or entities included in the lists contemplated by the Rules.
• Such reports may be filed even if the transaction does not reach the reporting threshold or is not actually carried out.
• Penalty for Non-Compliance: MXN $23,462 to MXN $7,625,150, (around USD $1,375 to USD $446,960).

C. Commencement of Audits: The first audit review period will cover January 1, 2028, through December 31, 2028.

• Compliance Audits: An annual audit must be conducted to assess compliance with AML obligations.
• Financial Intelligence Unit-Certified Auditor: Entities classified as High Risk must engage an independent external auditor holding a valid AML certification issued by the Financial Intelligence Unit.
• Penalty for Non-Compliance: MXN $23,462 to MXN $234,620, (around USD $1,375 to USD $13,753).

Need expert advice? Speak with our UIF-certified consultants. → [Schedule a meeting]

What Does This Mean for Organizations?

The new Rules represent a significant shift in the compliance framework applicable to entities and individuals carrying out Vulnerable Activities by introducing obligations that require new methodologies, procedures, controls, and monitoring tools.

Given their phased implementation, organizations should assess their current compliance framework to identify existing gaps and establish an implementation plan that enables timely compliance with the new obligations.

Implementation Priorities

1. Identify applicable obligations and assess the current compliance framework.
2. Design, develop, or update methodologies, policies, procedures, controls, and automated mechanisms.
3. Implement and update records, systems, internal processes, training programs, and monitoring mechanisms.
4. Periodically assess and verify the effectiveness of the compliance framework and satisfy audit requirements.

How Can We Help?

At Kreston BSG, we have specialists and Financial Intelligence Unit-Certified Professionals with extensive experience in the design, implementation, and assessment of AML compliance frameworks applicable to Vulnerable Activities.

Our team can assist with:

• Assessment and evaluation of existing compliance programs.
• Implementation of Risk-Based Approach.
• Risk classification and KYC process.
• Updating Internal Policies Manuals.
• Design and implementation of compliance controls and mechanisms.
• Specialized AML training.
• Compliance audits and assessments.

Is your organization ready to comply with the new AML requirements? → [Speak with a specialist]

Kind regards,

Kreston BSG México

Authors: Luis A. Avila Bravo, Legal & Tax Partner, and Francisco J. Téllez, certified by the Financial Intelligence Unit (UIF) in Legal & AML | Project Manager.

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