Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (LFPIORPI) Reform: Key Compliance Implications

On July 16, 2025, a substantial reform to the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (LFPIORPI or the Law) was published in the Federal Official Gazette (DOF). This reform aims to strengthen Mexico’s regulatory framework for anti-money laundering (AML) and counter-terrorism financing (CTF), involving new authorities such as the Ministry of Security and Citizen Protection and the National Guard in the fight against these crimes.

Non-compliance with these provisions may result in administrative and criminal sanctions, as well as reputational damage. In this context, companies are advised to:

• Assess whether they engage in Vulnerable Activities,
• Update their internal compliance policies and procedures,
• Verify the traceability of their corporate structures and the proper identification of the Beneficial Owner,
• Train key personnel in accordance with the new legal requirements,
• Conduct internal audits to assess specific risks and the level of regulatory compliance.

Among the most significant changes are:

• The redefinition of the concept of Beneficial Owner, expanding its scope and establishing mandatory registration in the electronic system of the Ministry of Economy.
• The concept of Politically Exposed Persons (PEPs) is introduced, along with specific identification and monitoring measures.

Regarding Vulnerable Activities, the reform expressly includes a definition of real estate developments, establishing that the financing of real estate developments is cataloged as Vulnerable Activity, and introduces new thresholds applicable to certain activities already covered by the law.

Some of the modifications regarding the obligations of those engaged in Vulnerable Activities include:

• Extension of the information retention period from 5 to 10 years;
• Additional obligations concerning the identification of the Beneficial Owner;
• Additional obligations regarding the safeguarding of transaction records;
• Mandatory registration in the Registry of persons engaged in Vulnerable Activities;
• Use of official formats, some of which were recently published in the DOF (June 9, 2025);
• New types of reports to be submitted;
• Implementation of a Risk-Based Approach (RBA) assessment;
• Maintenance of a Manual of Internal Policies;
• Mandatory annual training;
• Implementation of automated monitoring systems;
• Conducting audits to assess the effectiveness of compliance with applicable obligations.

Many of these new obligations will be subject to the terms established in the General Rules to be issued by the Ministry of Finance and Public Credit (SHCP) within a period not exceeding twelve (12) months. An increase in audits and information requests by the Financial Intelligence Unit (UIF) and the Tax Administration Service (SAT) is anticipated.

At Cannizzo, Ortiz y Asociados, S.C., we can advise you on the implementation of the changes provided in the new LFPIORPI to remain in compliance and avoid possible sanctions. Our team of experts is available to provide personalized advice and support in the adoption of this new regulation.

For more information, please contact Karen Ortega at [email protected].

Yours sincerely,

Cannizzo