Chihuahua, Chih., July 25, 2025

Dear Clients and Friends,

On July 16, 2025, the decree amending various provisions of the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (Anti-Money Laundering Law) and the Federal Criminal Code was published in the Official Gazette of the Federation (DOF). This reform represents a profound transformation of Mexico’s anti-money laundering legal framework, aligning with international FATF standards and tightening obligations for companies engaged in Vulnerable Activities.

• Key Changes in the Reform
  • Redefinition and New Concepts
    • Beneficial Owner: The threshold is reduced from 50% to 25%. Entities must identify and retain related information.
    • Transfers of Shares or Equity Interests: Mandatory notice before the Ministry of Economy.
    • Politically Exposed Person (PEP): Formal monitoring must be incorporated into internal policies.
    • Compliance Officer: Must be clearly identified, properly trained, and act under direct legal responsibility.
    • Risk and Risk-Based Approach (RBA): Entities must establish a clear, documented, and functional methodology.
  • Operational Obligations
    • Automated Systems: All entities carrying out vulnerable activities must implement technology for monitoring, identifying, and alerting unusual operations.
    • Annual Internal or External Audit: Based on the entity’s risk level, following rules to be issued by the Ministry of Finance (SHCP).
    • Mandatory Annual Training: For all personnel involved in compliance duties.
    • 24-Hour Notice: To the SHCP upon detecting suspicious transactions, even if not completed.
    • Documentation and Retention: Mandatory safeguarding of information for 10 years.
    • Compliance Manual: Immediate update and implementation of internal policies aligned with the new framework.
  • Expanded Scope of Vulnerable Activities
    • Explicit inclusion of:
      • Real estate developments.
      • Operations with virtual assets, even those carried out abroad by Mexican citizens.
    • Changes to threshold amounts:
      • Now defined in Units of Measurement and Update (UMA) instead of minimum wages.
• Strengthening of the Criminal Regime
  • Article 400 Bis of the Federal Criminal Code: Allows the Public Prosecutor to investigate operations without a prior complaint, although formalization by the SHCP is still required for criminal prosecution.
• Transitory Provisions and Effective Date
  • The decree becomes effective on July 17, 2025.
  • The Ministry of Finance and the Tax Administration Service have 12 months to issue secondary rules enabling practical enforcement of the amended provisions (especially sections VII to XI of Article 18 – risks, training, manual, systems, and audits).
  • Mechanisms for voluntary compliance are provided, allowing offenders to correct irregularities before being detected, thereby avoiding or reducing sanctions.

Implications for Your Organization
This reform is not merely formal. It entails:

• Operational reengineering.
• Technological implementation.

Investment in compliance, automation, and training is no longer optional—it is now a legal and immediate obligation.

Therefore, our law firm is prepared to provide the necessary support to companies that require advice on this issue.

You can contact either, Rolando Castellanos-Macal at rcastellanos@iclmx.com; and Jorge Almanza-Ríos at jalmanza@iclmx.com; for any further information that you might require.