Mexico: New Reforms Strengthen Anti-Money Laundering Controls in the Real Estate Sector

On July 16, 2025, the President of the United Mexican States, Claudia Sheinbaum, published the Decree amending and supplementing various provisions of the Federal Law for the Prevention and Identification of Transactions with Illegally-Sourced Funds (LFPIORPI) and the Federal Criminal Code. These changes introduce new obligations for participants in the real estate sector, especially developers, brokers, and notaries public.

Key reforms include:

• New Identification and Control Obligations
  • The definition of “controlling beneficiary” is broadened and detailed, equating it to “ultimate beneficiary” or “actual owner,” and now includes individuals or legal entities who:
    • Obtain the benefit of enjoyment, use, exploitation, or disposal of a good or service through a client or user; or
    • Exercise effective control over a legal entity that, as a client or user, carries out acts or transactions with a party engaging in a vulnerable activity (as defined by the LFPIORPI), as well as those on whose behalf such acts or transactions are carried out.
  • The definition of “client or user” now includes any individual, legal entity, or trust that carries out acts or transactions with those engaging in vulnerable activities.
  • The definition of “real estate development” is included as the project for the construction of real property or subdivision of lots intended for sale or lease.
  • Legal entities must retain documentary evidence to identify and register them in the Ministry of Finance and Public Credit’s electronic system.
  • The identification obligation applies even if the legal entity is not a direct client but participates in a transaction.

• Identification of New Vulnerable Activities and Adjustment of Thresholds Triggering Reporting Obligations. As part of the reforms, new vulnerable activities have been incorporated and transaction amounts triggering the obligation to file a report with the Ministry have been modified. These activities include:

  • The construction or development of real estate, as well as brokerage in the transfer of ownership or creation of rights over such property (brokers), in transactions involving the purchase or sale of the property when the value of the act or transaction equals or exceeds 8,025 times the daily value of the Unidad de Medida y Actualización (UMA).
  • The receipt of funds destined for a real estate development intended for sale or lease when the value of the act or transaction equals or exceeds 8,025 times the daily UMA value.
  • The provision of notarial services where the transfer or creation of real rights over real estate is recorded, when the agreed price, cadastral value, commercial value, or the principal guaranteed amount—whichever is highest—equals or exceeds 8,000 times the daily UMA value. This also includes the creation or modification of trust agreements transferring ownership or serving as collateral when the amount equals or exceeds 4,000 times the daily UMA value.
  • The creation of personal rights of use or enjoyment of real estate with a monthly value exceeding 1,605 times the daily UMA value, where the monthly amount of the act or transaction equals or exceeds 3,210 times the daily UMA value.

• Prohibition of Cash Payments

  • The payment in cash or precious metals is prohibited, even if a financial entity is involved, in acts that involve:
    • The creation or transfer of real rights over real estate valued at an amount equal to or greater than 8,025 times the daily UMA value; or
    • Monthly rents valued at an amount equal to or greater than 3,210 times the daily UMA value.
• New Administrative Obligations. Essentially, the obligated parties under Article 18 of the LFPIORPI must:
  • Safeguard and protect information related to the provision of vulnerable activities.
  • Register or update their registration in the Vulnerable Activities Registry.
  • Designate a compliance officer before the Ministry.
  • Prepare an internal policies manual.
  • Conduct annual training for compliance officers, executives, and employees involved in vulnerable activities.
  • Implement automated mechanisms for permanent monitoring of transactions with clients or users.
  • Carry out internal or external audits depending on the level of risk.
• Imposition of Penalties
  • Penalties for failing to file reports required by the LFPIORPI, or for doing so incorrectly, can reach: (i) 65,000 times the daily UMA value, or (ii) 100% of the value of the transaction in question, whichever is greater.
  • A benefit of waiver or reduction of penalties is incorporated for voluntary regularization prior to any official verification by the Ministry.

These reforms represent a significant change in the regulatory framework applicable to real estate activities in Mexico, strengthening oversight of transactions susceptible to money laundering and establishing new obligations for various actors in the sector. It is essential for developers, brokers, and notaries public to stay informed and update their internal processes to comply with the new legal requirements and avoid the penalties established by law.