Reforms to the Anti-Money Laundering Law and the Federal Criminal Code
New Implications and Obligations Regarding Money Laundering and Terrorist Financing Prevention (ML/TF)

On April 16, 2025, the Decree amending and adding various provisions to the following laws was published in the Diario Oficial de la Federación:

• The Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds (Anti-Money Laundering Law), and
• Article 400 Bis of the Federal Criminal Code.
  

These reforms respond to recommendations from the Financial Action Task Force (FATF/GAFI), in a context of increasing international scrutiny of Mexico’s financial operations.

Key Changes Introduced by the Reform

1. New or Revised Definitions

• Definitions have been clarified for “Politically Exposed Person (PEP),” “User,” “Risk,” and “Financial Entity.”
  
• The threshold for identifying a Controlling Beneficiary has been reduced from more than 50% ownership to more than 25%.
  
  
  
• The concept of “Real Estate Development” has been introduced, including both construction and subdivision for sale or lease. This activity is now considered vulnerable and subject to reporting.
  

2. New Obligations for Regulated Entities

• The catalog of vulnerable activities has been expanded to include real estate developers.
  
• Transactions involving Mexican citizens from abroad using virtual assets (cryptocurrencies) are now considered vulnerable.
  
• Compliance Officers must now receive annual training in accordance with rules to be issued by the Ministry of Finance (SHCP).
  
• All commercial companies must:
  
  • Report the identity of the Controlling Beneficiary to the SHCP.
    
  • Notify every transfer of shares or equity interests, regardless of the type of transaction.
    
• Annual external audits are now mandatory to evaluate compliance, according to specific rules.
  
• Regulated entities must identify and register Politically Exposed Persons, and maintain direct knowledge of clients and users.
  
• Supporting documentation must be retained for 10 years (previously 5).
  
• Notaries, public brokers, and other legal professionals now have standardized reporting obligations.
  
• Entities are required to implement a risk-based approach, which will require updating internal manuals and procedures.
  

These provisions will come into effect on July 17, 2025, and for specific cases, on the dates established in the corresponding regulatory provisions.

At Vega, Guerrero & Asociados, we can advise you on how these new regulations may affect your company’s commercial and financial operations, and assist you in complying with the various obligations introduced under this new legal framework.