New Registration, Filing, Notice and Report Forms for Anti-Money Laundering Compliance

On September 24, 2026, two Resolutions were published in Mexico’s Federal Official Gazette (Diario Oficial de la Federación, “DOF”). The first updates the official registration form for persons and entities carrying out Vulnerable Activities, while the second updates the official forms for filing Notices and Reports.

These changes are part of the implementation of the recent amendments to the Federal Law for the Prevention and Identification of Transactions involving Resources of Illicit Origin (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, “LFPIORPI”), its Regulations and the General Rules, and require persons and entities carrying out Vulnerable Activities to review both their current registration information and their procedures for preparing and filing Notices and Reports.

1. Update to the Registration Form

The first Resolution updates the registration form to expressly identify, among others, persons and entities carrying out Vulnerable Activities through trusts or other legal arrangements, public or private facilitators of alternative dispute resolution mechanisms, customs agencies, and individuals or legal entities that promote the customs clearance of goods without the involvement of a customs broker or customs agency.

The new Annex “A” expands the information required for registration. In the case of trusts, for example, information must be provided regarding the trust itself, the trustee, the trust officer, settlors and beneficiaries. For other legal arrangements, information must be provided regarding their participants or members and the capacity in which they participate.

Additionally, when a Vulnerable Activity is carried out through a trust or other legal arrangement, information regarding its participants or members must be submitted using the Excel template available through the Portal, which will generate the corresponding XML file. If any information concerning a participant or member needs to be amended or corrected, such participant or member must first be deregistered, after which the corrected or updated information must be resubmitted.

Annex “B” is also updated with respect to the designated Compliance Representative, who must complete the designation process through the Portal, including the acceptance or rejection of the appointment, as well as providing contact information and address details.

A particularly relevant aspect is the transitional regime applicable to persons and entities that are already registered. Customs agencies, persons directly promoting the customs clearance of goods, and persons carrying out Vulnerable Activities through a trust or other legal arrangement that registered before February 1, 2027, must deregister and immediately complete a new registration clearly identifying the capacity in which they carry out their acts or transactions.

2. New Notice and Report Forms

The second Resolution updates the official forms used to file Notices and Reports and adapts them to the new obligations established under the LFPIORPI, its Regulations and the General Rules.

Among the main changes is the addition and updating of fields related to the identification of the Beneficial Owner, as well as modifications to the forms to identify Notices concerning transactions for which there are suspicions, facts or indications of a potential connection with transactions involving resources of illicit origin or other related offenses.

The new forms also allow for the filing of the Notices provided for under Articles 26 Bis, 26 Bis 1, 26 Bis 2 and 27 of the Rules, including those that must be submitted within 24 hours after the relevant circumstances arise. These Notices may be required even when the act or transaction does not meet the ordinary reporting threshold and even when the transaction is not ultimately completed, provided that sufficient information is available to identify the Client or User, or the person who attempted to carry out the transaction.

Additionally, Form 12-C is introduced for certain transactions carried out by public or private facilitators of alternative dispute resolution mechanisms, as well as Form 14-A for certain foreign trade-related Notices. Annex “A,” concerning the tariff classifications of goods whose customs clearance constitutes a Vulnerable Activity, is also updated.

Notices and Reports will continue to be filed electronically through XML files via the Anti-Money Laundering Portal. It is important to note that an acknowledgment marked as “rejected” does not constitute evidence of compliance with the filing obligation. Any errors must therefore be corrected and the information resubmitted within the applicable deadline.

3. Relevant Dates

The amendments will enter into force gradually:

• December 1, 2026: The Resolution concerning Notices and Reports will take effect exclusively for purposes of the Fifth Transitional Provision of the Rules, in order to begin calculating the applicable period for the new Notices under Articles 26 Bis, 26 Bis 1, 26 Bis 2 and 27. This does not mean that the new forms must generally be used as of this date.
• February 1, 2027: As a general rule, the new registration form will enter into force. As of this date, customs agencies, persons directly promoting the customs clearance of goods, and persons carrying out Vulnerable Activities through trusts or other legal arrangements that registered before February 1, 2027, must deregister and immediately complete a new registration.
• June 1, 2027: The registration form for public and private facilitators of alternative dispute resolution mechanisms will enter into force. On the same date, general use of the new Notice and Report forms will begin, even when they relate to transactions carried out or reporting periods prior to that date. Notices under Articles 26 Bis, 26 Bis 1, 26 Bis 2 and 27 of the Rules may also be filed as of this date.
• June 30, 2027: This will be the final date on which the previous forms will remain available for amending previously filed Notices. Such amendments may only be made in accordance with the terms and within the 30-calendar-day period established in the Resolution. As of July 1, 2027, the previous forms will no longer be available.

4. Recommended Actions

Considering the implementation period established under the Resolutions, we recommend that persons and entities carrying out Vulnerable Activities:

• review their current registration to determine whether it accurately reflects the manner and capacity in which they carry out the relevant Vulnerable Activity and, in particular, whether deregistration and a new registration will be required;
• identify and complete the information required regarding trusts, other legal arrangements and their participants, as well as the designated Compliance Representative;
• review the information and documentation currently collected from Clients or Users and Beneficial Owners in order to identify potential gaps in relation to the new mandatory fields;
• adapt their systems and procedures for generating, validating and submitting XML files, including procedures to promptly identify and address rejected Notices and the new Notices that must be filed within 24 hours; and
• update their internal manuals, policies and procedures, and train the personnel responsible for identifying, documenting and reporting the relevant transactions.

The published amendments are not merely a change to the filing forms. They require a broader review of the information currently available, the manner in which persons and entities carrying out Vulnerable Activities are registered, and the internal processes used to identify and report transactions subject to the LFPIORPI.

Cannizzo is available to assist clients in reviewing their current registration, implementing the new forms, and updating their anti-money laundering compliance policies, procedures and systems.

Yours sincerely,

Cannizzo