Amendments to the Regulations of the Federal Law for the Prevention and Identification of Operations with Illicit Resources

On March 27, 2026, the decree amending, supplementing and repealing various provisions of the Regulations of the Federal Law for the Prevention and Identification of Operations with Illicit Resources (the “Regulations”) was published in the Official Gazette of the Federation (Diario Oficial de la Federación). The decree entered into force the day following its publication (March 28, 2026).

The reform must be analyzed in light of the amendments to the Federal Law for the Prevention and Identification of Operations with Illicit Resources (“LFPIORPI”) published in July of last year, which introduced a structural change to the regime applicable to Vulnerable Activities, incorporating a risk-based approach, new compliance obligations and figures such as the Beneficial Owner, Politically Exposed Persons and enhanced supervisory schemes.

In this context, the amendments to the Regulations are primarily aimed at developing and aligning the provisions with the current Law and strengthening their practical application. The main changes are summarized below:

1. Powers of the authorities

The powers of the Ministry of Finance and Public Credit (“SHCP”), the Financial Intelligence Unit (“UIF”) and the Tax Administration Service (“SAT”) are clarified and, in certain cases, expanded. In particular, the strengthening of the SAT’s powers stands out, including its authority to conduct verification visits, require information and documentation, monitor compliance with obligations, impose sanctions, carry out electronic notifications and request audit reports together with evidence of remediation. Additionally, the possibility of requesting the assistance of public force is foreseen.

1. Notices and aggregation of transactions

More precise rules are established for the determination and filing of notices (Avisos). In particular, the aggregation of transactions must consider a period of up to 6 (six) months, and the notice must be filed at the moment the applicable threshold is reached or exceeded, without the need to exhaust such period.

Additionally, the obligation to file notices within 24 (twenty-four) hours is introduced with respect to transactions that were not completed, provided that information is available regarding the individual who attempted to carry them out.

III. Information requests and procedure

The UIF and the SAT may directly require information, documentation, data and images from obligated parties, Collective Entities and centralizing bodies. As a general rule, such information must be provided within 10 (ten) business days, which may be extended for an additional 5 (five) business days.

In the event of non-compliance, the SAT may impose sanctions within shorter timeframes and without being subject to the sanctioning procedure set forth in the Federal Administrative Procedure Law, thereby strengthening the authority’s enforcement capacity.

1. Audit, registration and compliance

Compliance obligations are reinforced, including the requirement to be registered with the Federal Taxpayers Registry (RFC) and to use an advanced electronic signature for registration as an obligated party.

Additionally, the obligation to obtain, retain and provide to the SAT the audit report derived from internal or external audits, as well as to evidence the remediation of identified findings, is expressly incorporated.

The possibility of applying simplified identification measures in low-risk scenarios, subject to general rules, is maintained.

1. Recordkeeping

The extension of the information retention period to a minimum of 10 (ten) years is reflected, in accordance with the provisions of the LFPIORPI, including notices, reports, supporting documentation and electronic acknowledgments. This obligation also applies to Collective Entities with respect to information from their members.

1. Politically Exposed Persons (PEPs)

A new chapter has been introduced regulating the List of Politically Exposed Persons, which is under the responsibility of the UIF. The Regulations provide for its integration, updating and consultation mechanisms by obligated parties.

Additionally, obligations are established for various authorities to provide and keep the relevant information updated.

VII. Remediation and express acknowledgment of non-compliance

A mechanism for the express acknowledgment of non-compliance is introduced, whereby obligated parties may inform the SAT of the breaches incurred, evidence their correction and submit the corresponding supporting documentation. The Regulations detail the requirements to access this mechanism and its interaction with verification and sanctioning procedures.

While both the 2025 amendments to the LFPIORPI and these amendments to the Regulations establish a new regulatory framework in matters of anti-money laundering compliance, their full implementation is still under development, as various provisions of both the LFPIORPI and the Regulations refer to General Rules to be issued by the SHCP, which remain pending issuance.

In this context, the Regulations reinforce and make operational the structural changes introduced by the LFPIORPI reform, making it necessary to review and, where appropriate, strengthen existing compliance systems.

We recommend conducting a preliminary assessment of internal processes and controls, as well as closely monitoring the issuance of the General Rules, to timely adjust compliance frameworks as the regulatory regime is further developed.

We remain at your disposal to analyze the specific impact on your operations and to assist in the implementation of the necessary measures.

Yours sincerely,

Cannizzo