Mexico’s Anti-Money Laundering Law Reform 2025

On July 16, 2025, the reform to the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI), better known as the Anti-Money Laundering Law, was published in the Official Gazette of the Federation (DOF). This reform is important because it establishes new rules to prevent money laundering in Mexico and directly affects real estate agencies, developers, notaries, investors, and buyers. At Plalla Real Estate, our goal is to help you understand, in simple terms, what this reform means and how it impacts the property buying process.

 

 

WHAT IS THE ANTI-MONEY LAUNDERING LAW (LFPIORPI)?

 

The Anti-Money Laundering Law, officially called LFPIORPI (Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds), is a Mexican regulation designed to prevent illicit money from being used in formal economic activities. Its main purpose is to protect the financial system and strategic sectors such as real estate, notarial services, and virtual assets.

 

The law lists several vulnerable activities, meaning operations that, due to their nature, could be used for money laundering. These include the purchase and sale of real estate, the creation of trusts, handling large amounts of cash, cryptocurrency transactions, and the work of notaries and public brokers.

 

In the real estate sector, this law is especially relevant because buying or selling properties is one of the most common ways to move large amounts of money. For this reason, real estate agencies, developers, buyers, and investors must follow identification, reporting, and documentation rules to ensure safe and compliant transactions.

 

MAIN CHANGES IN THE 2025 REFORM

 

The new reform to the Anti-Money Laundering Law introduces changes that aim to clarify who participates in each transaction and how money flows must be monitored. These are the key concepts that now form part of the law and directly impact the real estate sector:

 

Introduction of new concepts

 

• Beneficial Owner: it is now mandatory to identify the individual who truly controls the transaction, even if they are not directly listed in the contracts. This provides greater certainty for buyers and investors.
• Politically Exposed Persons (PEPs): public officials or former officials, as well as their relatives. Their transactions must be reviewed more carefully to reduce risks.
• Compliance Officer: every company or development must have a designated person responsible for ensuring compliance with the law and receiving ongoing training.
• Risk: introduces the obligation to measure and assess the risk of each client or transaction, with stricter controls applied in higher-risk cases.
• Real estate development: for the first time, construction projects and lot sales are formally classified as “vulnerable activities,” which implies greater obligations of identification and reporting.

 

Adjustment of reporting thresholds

 

The reform also modifies the amounts from which certain transactions must be reported to the authorities. This means that activities that previously did not require reporting must now be reported if they exceed the new limits:

 

• Prepaid cards and value instruments: lower thresholds now apply for identifying and reporting transactions, including reloads or deposits.
• Notaries and public brokers: they must now report transactions at lower thresholds related to property transfers or trusts.
• Virtual assets (including operations from abroad): cryptocurrency transactions carried out by Mexican citizens outside the country must also be reported if they exceed the set limits.
• Trusts: thresholds have been adjusted for the constitution or modification of ownership or guarantee trusts.
• Games, raffles, and contests: the scope of activities that require reporting has been expanded, now including those carried out under new authorizations.

 

Expansion of Vulnerable Activities

 

One of the most relevant changes is that more economic activities are now considered vulnerable to money laundering. In the real estate and financial sectors, this means greater responsibility when handling transactions:

 

• Real estate developments: receiving funds for construction projects or land lots intended for sale or rent is now classified as a vulnerable activity.
• Virtual assets (crypto): cryptocurrency transactions are now formally regulated under the law, requiring additional identification and reporting controls.
• Notaries and brokers: while they were already regulated, the reform expands the scenarios in which they must report operations, especially property transfers and trust agreements.

 

Identification and Recordkeeping

 

The reform strengthens the obligation to thoroughly know those involved in transactions. This is meant to provide greater transparency and security in the market:

 

• Beneficial Owner: the individual who ultimately controls or benefits from the transaction must be identified and registered, even if they are not directly listed in the contracts.
• Recordkeeping: all related documentation must now be kept for 10 years, doubling the previous requirement of 5 years.

 

Automated Systems and Monitoring

 

Businesses engaged in vulnerable activities must modernize their internal processes to detect suspicious transactions:

 

• Internal controls: implementing tools to monitor transactions in real time.
• Risk profiles: creating transactional profiles of clients and applying enhanced monitoring for those considered high risk.

 

Risk-Based Approach (RBA)

 

A more flexible yet stricter compliance model is introduced: each business must assess the risks of its transactions and clients to apply proportional measures.

 

• Risk assessment: analyzing each transaction and client to determine the level of exposure.
• Internal policies: companies must have clear manuals and procedures to guide the detection and reporting of unusual transactions.

 

Internal and External Audits

 

The reform also requires periodic reviews to ensure businesses comply with the Anti-Money Laundering Law:

 

• Annual review: every business carrying out vulnerable activities must undergo an internal audit once a year.
• External audits: in high-risk cases, reviews must be conducted by an independent external auditor to guarantee impartiality and trust.

 

Mandatory Training

 

The reform requires companies to strengthen the knowledge of those responsible for compliance with the law:

 

• Compliance Officer: the designated person in charge must receive specialized training to ensure proper compliance with AML obligations.
• Annual training programs: all staff involved in vulnerable activities must receive yearly training on money laundering prevention and risk management.

 

Registration of Beneficial Owners

 

Controls are reinforced to identify who truly controls a company or corporation:

 

• Corporations: must register the full information of their Beneficial Owner with the Ministry of Economy.
• New Articles 33 Bis, Ter, and Quáter: establish the obligation to keep these records updated and respond to any requests from the authorities.

 

Strengthening of Sanctions

 

The Anti-Money Laundering Law now includes stricter penalties for those who fail to comply with their obligations:

 

• Revocation of permits: authorities may cancel licenses or authorizations for repeated violations.
• Participation of the UIF: the Financial Intelligence Unit will play a more active role in investigations and may act as a victim or complainant in legal proceedings.
• Voluntary correction: in the case of a first violation, if the company corrects the issue voluntarily, the penalty may not be applied or could be reduced by up to 50%.

 

Prohibition of Cash Payments

 

The reform clarifies and strengthens the prohibition on carrying out certain transactions with cash:

 

• Scope of the prohibition: it is forbidden to settle obligations with cash (pesos, foreign currency, or precious metals), even if the payment is made through a financial institution.
• New rules based on UMA: maximum permitted amounts are now calculated using the Unit of Measure and Update (UMA), which gives greater precision when applying limits.

 

 

IMPACT OF THE REFORM ON THE REAL ESTATE SECTOR

 

The 2025 Anti-Money Laundering Law reform has a direct effect on the real estate sector, as property transactions and developments are now considered closely monitored activities. This means that developers, notaries, buyers, and investors must comply with new transparency rules.

 

Real estate developers

 

Construction projects and land subdivision intended for sale or rent are now classified as vulnerable activities. Developers are required to identify each client, record transactions, and implement internal controls to report to the authorities when amounts exceed the established thresholds.

 

Notaries and public brokers

 

Notaries and brokers now face lower reporting thresholds for transactions such as property transfers and trust agreements. This means more transactions must be formally reported, strengthening traceability and reducing the risk of irregular operations.

 

Foreign buyers and investors (trusts)

 

Foreign investors purchasing property in the so-called restricted zone (near coasts or borders) must continue to do so through a fideicomiso (bank trust). With the reform, the requirements for identifying and registering the Beneficial Owner are stricter, providing greater legal certainty but also requiring more documentation and compliance from the buyer.

 

 

PRACTICAL STEPS TO COMPLY WITH THE LAW

 

For developers, real estate agencies, notaries, and investors to comply with the 2025 Anti-Money Laundering Law, it is essential to apply simple but effective measures. Here are the key steps:

 

Client and beneficial owner identification

 

It is mandatory to directly identify each client and register the Beneficial Owner of the transaction. This includes collecting official documentation and keeping it up to date.

 

Implementation of internal controls

 

Companies must establish clear processes to review transactions and detect unusual activity. This helps prevent risks and avoids penalties.

 

Use of automated systems

 

Digital systems make it easier to monitor transactions, analyze risk profiles, and submit reports to the authorities. They also provide greater transparency in every operation.

 

Training and internal policies

 

Sales, legal, and administrative teams must receive annual training on money laundering prevention. Companies are also required to have internal manuals that guide staff on how to act in each scenario.

 

Periodic audits

 

Internal and external audits are essential to verify compliance. In higher-risk cases, reviews must be conducted by independent auditors to provide greater certainty.

 

 

FREQUENTLY ASKED QUESTIONS ABOUT THE 2025 ANTI-MONEY LAUNDERING LAW

 

When does the reform take effect?

 

The reform was published on July 16, 2025 in the Official Gazette of the Federation and came into force the following day. However, some specific deadlines will be defined by the Ministry of Finance (SHCP) and the Tax Administration Service (SAT) through general rules.

 

What sanctions apply to real estate companies?

 

Sanctions can range from financial penalties and revocation of permits to suspension of activities in serious cases. The reform also allows for voluntary correction benefits, meaning penalties can be avoided if the issue is resolved immediately.

 

What happens if I don’t register the Beneficial Owner?

 

Failure to register or update the Beneficial Owner may result in heavy fines and the inability to complete legal or financial procedures. Corporations are also required to provide this information through the Ministry of Economy’s system.

 

Do homebuyers also have to comply?

 

In most cases, buyers comply indirectly since the real estate agency, developer, or notary requests the information and files the report. However, it is important to be prepared with official identification, proof of funds, and documentation on the origin of the resources.

 

What are the implications for cryptocurrencies and virtual assets?

 

Transactions with virtual assets are now regulated, even if carried out abroad by Mexican citizens. This means the parties involved must be identified, and any transactions exceeding the legal thresholds must be reported.

 

What obligations do notaries and public brokers have?

 

Notaries and brokers must now report transactions at lower thresholds, especially for property transfers and trust agreements. This strengthens traceability in real estate operations.

 

Is paying for a property in cash prohibited?

 

Yes. The law prohibits settling certain transactions with cash, even if done through financial institutions. The maximum amounts are now calculated using the UMA, and exceeding them can result in severe penalties.

 

How does this affect foreign investors?

 

Foreign investors must continue to use a fideicomiso (bank trust) to purchase properties in the restricted zone (coastal or border areas). With the reform, identification requirements are stricter, ensuring greater legal certainty but also requiring more documentation.

 

 

CONCLUSION AND SPECIALIZED ADVICE

 

The 2025 Anti-Money Laundering Reform marks a turning point in how real estate transactions are conducted in Mexico. While it may seem complex, it actually represents an opportunity: transactions are now safer, more transparent, and provide greater legal certainty for developers, buyers, and investors alike.

 

At Plalla Real Estate, we understand that buying a property is one of the most important decisions in life. That’s why our team of advisors accompanies you every step of the way, ensuring that your investment is made in full compliance with the law, without risks, and with complete confidence.

 

Are you ready to invest in Mexico with security and professional support? Contact us and discover how we can help you find the ideal property with the peace of mind of being protected under the new regulations.

 

What do you think of the information?

 

We would love to hear your thoughts. If you have any comments, questions, or concerns, feel free to leave them in the comments section below. We’re here to help and guide you.

 

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