One year since the LFPIORPI reform: what changed for those who carry out vulnerable activities

On July 16, 2025, the Diario Oficial de la Federación published the decree that amends and adds various provisions to the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI), Mexico's anti-money-laundering law for non-financial businesses. One year on, we review the changes that weigh most on the operation of those who carry out vulnerable activities, based solely on the current text of the law.

This article is for information only and does not constitute legal advice. For specific decisions, consult the official text and your advisor on the matter.

New definitions that frame everything else

The reform expanded Article 3, which defines the law's concepts. Several of the additions have practical consequences:

• Client or User: any individual or legal entity, as well as trusts, entering into acts or transactions with someone who carries out a vulnerable activity.
• Real Estate Development: a project for the construction of real estate or the subdivision of lots intended for sale or rent.
• Politically Exposed Person: someone who holds or has held public office in Mexico or abroad, and the related persons the Ministry of Finance determines.
• Beneficial Owner: its definition was amended. Among the cases of effective control of a legal entity is holding voting rights over more than twenty-five percent of the share capital, and the law clarifies that the concept is equivalent to ultimate beneficiary and real owner.

The new obligations in Article 18

Article 18 lists what those who carry out vulnerable activities must do. The reform amended the existing sections and added others. Among the most relevant points of the current text:

1. Identifying the beneficial owner. If the client is a legal entity, trust or other legal arrangement, documents that identify its beneficial owner must be collected. If the client is an individual, their statement on whether they know of one must be collected.
2. Retention for at least ten years of supporting information and documentation, physically or electronically, counted from the date of the vulnerable activity.
3. Registration in the registry of persons who carry out vulnerable activities, through the portal the Ministry determines (section IV Bis).
4. A report within 24 hours when there is suspicion, or information based on facts or indications, that the funds may come from or be destined for operations with resources of illicit origin, even if the transaction did not take place.
5. Five added obligations (sections VII to XI): a risk-based assessment; an internal policy manual that includes monitoring of politically exposed persons; staff selection processes and annual training; automated mechanisms for permanent monitoring of transactions, with enhanced monitoring of high-risk or politically exposed clients; and an annual effectiveness review by internal audit or by an independent external auditor, depending on the risk level.

Article 20, also amended, requires legal entities to appoint a Compliance Officer before the Ministry, who must receive annual training.

Beneficial ownership: from a data point to an obligation of its own

Beyond Article 18, the reform added a Chapter IV Bis devoted to the beneficial owner. Commercial companies must respond to the authority's requests to determine it, keep the supporting information and register it in an electronic system operated by the Ministry of Economy, which they must also notify when transfers of shares or equity interests are recorded in their share registry.

Activities and thresholds that moved

Some concrete changes in Article 17:

• Real estate developments (section V Bis, added): receiving funds destined for a real estate development for sale or rent is a vulnerable activity, reportable from 8,025 UMA.
• Notaries, real estate (section XII, part A): the transfer or creation of real rights over real estate is reportable when the highest of the agreed price, the cadastral value, the market value or the secured principal reaches 8,000 UMA, a lower threshold than the one applied before the reform.
• Facilitators (part D, added): public and private facilitators under the General Law on Alternative Dispute Resolution Mechanisms become subject to the cases in part A.
• Cash (Article 32): the prohibition on cash payments was extended to payment consignments related to the listed transactions, and the Ministry was empowered to extend the prohibition to fungible goods through general rules.

Several figures still circulating in guides and presentations predate the reform. Before configuring a threshold, it is worth checking it against the current text.

What to review one year on

The decree took effect the day after its publication, with exceptions. Its transitory provisions gave the Ministry twelve months to amend the general rules, and state that the obligations in sections VII to XI of Article 18 take effect within the timeframes those rules set. For training and audit, the annual period is the calendar year, and the first one runs from January 1 to December 31, 2026. For that reason, the exact date on which each obligation becomes enforceable should be confirmed in the rules in force.

A reasonable review includes:

• confirming registration in the registry and the appointment of the compliance officer;
• checking that the identification file collects beneficial owner information as required by Article 18;
• updating identification and reporting thresholds for each activity in your systems;
• documenting the risk assessment and the internal policy manual, and planning training and the annual review.

At LoonByte we build tools for this work: LexBuild for AML compliance at real estate developers and construction firms, and AmigoApi to screen lists and compute UMA thresholds through an API.

Want to review how the reform affects your operation? Write to us.