Amendment to the Regulations of the Anti-Money Laundering Law (LFPIORPI)

The amendment to the LFPIORPI in force since July 17, 2025 introduced substantial changes: new vulnerable activities, strengthened obligations, updated thresholds, and the incorporation of concepts such as Politically Exposed Persons (PEPs) and Controlling Beneficiary, with the threshold reduced to 25%. The implementing decree develops these concepts and powers. Although the Regulations implement several of the changes introduced by the LFPIORPI, the amendment to the general rules is still pending (with a deadline of July 17, 2026). Obligations such as official forms, PEP consultation, and audit requirements will be subject to those rules. In the meantime, they will be complied with in accordance with the rules in force as of July 17, 2025. Below, we present the most relevant changes introduced by the decree, grouped by subject matter. Main changes introduced by the Amendment to the Regulations The amended Regulations incorporate clarifications regarding definitions, institutional powers, obligations of obligated parties, and sanctioning procedures: I. Definitions and Terminology (Article 2) Three definitions are added: (i) Reports, those submitted in accordance with the general rules; (ii) List of PEPs, prepared on the basis of the list of public positions applicable to Financial Entities and the information referred to in Article 51 Ter of the LFPIORPI; and (iii) Persons Vested with Public Faith, which includes notaries, public brokers, public servants empowered to attest to public faith, and facilitators under the General Law on Alternative Dispute Resolution Mechanisms. II. Powers of the FIU and the SAT (Articles 3 and 4) Powers are added to the FIU: to issue the form for authorities to provide information for the List of PEPs; to establish exceptions by means of agreements published in the DOF; to promote specialized units in the federal entities for the receipt and analysis of asset-related information; and to safeguard the Notices and Reports of Vulnerable Activities. The powers of the SAT are expanded: the obligation to receive Notices and Reports (previously only Notices), verification visits at the RFC domicile when the party subject to the visit cannot be located, and expanded oversight including Reports, audit opinions, and the remediation of observations. Powers are added to request the assistance of law enforcement, to serve electronic notifications, and to require audit opinions and supporting documentation. III. Rules on Aggregation of Transactions and the 24-Hour Notice (Articles 7 and 7 Bis) a. The aggregation of transactions considers a period of up to six months, with the aggregation Notice being submitted upon carrying out the last transaction that reaches or exceeds the threshold, even where the period has not been exhausted. Where no identification amounts are established, all transactions will be Vulnerable Activities subject to aggregation. b. The obligation to submit the 24-hour Notice is reinforced, even where the act has not been consummated and only the data of the person who attempted to carry it out is available. This obligation will be subject to the updating of the official forms. IV. Deadlines and Sanctioning Procedures (Articles 8, 9, and 10 Bis) a. Specific deadlines are incorporated for the verification and sanctioning procedures. The SAT must impose sanctions within a maximum of 10 business days when a requirement is not met, without exhausting the sanctioning procedure of the Federal Law on Administrative Procedure. It must issue the notice of observations within a maximum of 10 business days and the final resolution within a maximum of 20 business days. b. The new Article 10 Bis allows the SAT to base its resolutions on facts contained in its files, databases, or provided by other authorities. Certified digital copies will have the same evidentiary value as originals, and the information contained in CFDIs will be presumed to be true. V. Registration, Enrollment, and Audit Obligations (Articles 12, 12 Bis, and 14) Registration and enrollment expressly include trusts and other legal arrangements. The new Article 12 Bis requires obtaining and retaining the internal or external audit opinion and the documentation regarding the remediation of observations. Article 14 refers to the identification of the Controlling Beneficiary directly, eliminating the term “beneficial owner.” VI. Retention of Documentation (Article 20) The retention period for Notices and Reports was adjusted from five to ten years from the submission and issuance of the electronic acknowledgments, counted as of July 17, 2025. VII. New PEP Regime (Chapter Six Bis) a. A new chapter is created (Articles 45 Bis to 45 Quinquies) governing the compilation and classification of the List of PEPs by the FIU, subject to transparency and national security rules. b. The list may be shared with decentralized bodies of the SHCP for supervisory purposes, subject to a prior agreement. c. Financial Entities and those engaging in Vulnerable Activities may electronically consult with the FIU whether a Client or User is a PEP, when they are unable to determine this during their identification. d. The obligated authorities must update the information within 5 business days following any change. VIII. Other Relevant Changes a. Date of the act or transaction (Article 5): The date is no longer defined as that of execution, but rather as the date established in the general rules for each Vulnerable Activity. For activities under Section XII of Article 17, it includes the date of formalization before a notary. b. Linked transactions in games and betting (Article 21 Bis): The circumstances under which a series of linked transactions exists in games involving betting, contests, or drawings are defined, including digital platforms. Threshold: 325 times the daily value of the UMA within 24 hours. c. Loans, advances, and credits (Article 24): The moment at which the act is deemed to have been carried out is modified: previously it was upon the execution of the contract; now it is when the funds derived from the loan, advance, or credit are made available to the Client or User. d. Agreements with Collegiate Entities (Article 33 Bis): A maximum term of 10 years, with the possibility of renewal for an equal or lesser term, subject to verification by the SAT and to the quality of the Notices as assessed by the FIU. e. Express acknowledgment of violations (Article 55 Bis): A procedure is added that includes a free-form written submission before the SAT detailing the infractions, a statement under penalty of perjury that the violations have been corrected, and supporting documentation. Deadlines: (i) 5 days following the verification record (first infraction), or (ii) 15 days following notification of the commencement of the sanctioning procedure (recidivism). f. Training (Article 52): The catalog of entities that issue training certificates is expanded to include the Ministry of Security and Citizen Protection and the National Guard. IX. Transitional Provisions The decree establishes a detailed transitional regime that includes, among other relevant aspects, the repeal of all administrative provisions that conflict with the decree. What comes next? With these Regulations, a fundamental step has been taken in the implementation of the new AML/CFT framework. However, the key piece is the general rules that the SHCP must issue before July 2026, defining: official forms, PEP consultation procedures, simplified identification measures, audit requirements, and transaction monitoring mechanisms. To download the DOF decree, click on the following link: https://www.dof.gob.mx/nota_detalle.php?codigo=5783547&fecha=27/03/2026#gsc.tab=0 Our team remains at your disposal to help you implement this new regulatory framework. If your company engages in vulnerable activities, contact us for a diagnostic session. For additional information, contact: Luis Burgueño, Partner:+52 (55) 5258 1003 | lburgueno@vwys.com.mx Alberto Córdoba, Partner:+52 (55) 5258 1016 | acordoba@vwys.com.mx Diego Sierra, Partner:+52 (55) 5258 1039 | dsierra@vwys.com.mx Raymundo Soberanis, Partner:+52 (55) 5258 1059 | rsoberanis@vwys.com.mx Ricardo Cacho, Partner:+52 (55) 5258 1000 | rcacho@vwys.com.mx Max Morales, Associate:+52 (55) 5258 1014 | mmorales@vwys.com.mx Joel Domínguez, Associate:+52 (55) 5258 1027 | jdominguez@vwys.com.mx

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