Scope of Application
The General Agreement eliminates certain duplicative requirements, consolidates certain procedures, and simplifies various administrative processes applicable to a wide range of regulated entities. The General Agreement takes effect on the day following its publication and applies prospectively; applications already filed will be processed in accordance with the regulations in effect at the time of submission.
Key Changes for the General Agreement
The General Agreement introduces the following key changes:
a) Unification of SITI AML/CFT account registration (CNBV-2026-001). Three SITI AML/CFT account registration procedures: i) CNBV-28-024-A; ii) CNBV-30-004; and iii) CNBV-2025-016-004-A, are consolidated into a single unified filing, significantly reducing documentary and administrative burdens for non-regulated SOFOMs, currency exchange houses, money transmitters and investment advisors.
b) Merger of share transfer reporting procedures (CNBV-2026-002). The two procedures for reporting share transfers exceeding 2% (two percent) of paid-in capital: i) CNBV-28-015; and ii) CNBV-19-039-A, are merged into one, requiring solely the submission of an electronic form.
c) Elimination of homoclaves from the Single Registry. Eighteen homoclaves (official regulatory filing codes) are eliminated from the Federal Government’s Single Public Registry of Procedures and Services (Portal Ciudadano Único de Trámites y Servicios), including several applicable to fintech institutions (ITFs), banking institutions and popular financial entities, to avoid duplicated filings.
d) Elimination of virtual asset reporting obligations. The transaction reporting codes for virtual asset transactions have been eliminated for credit institutions and ITFs. This elimination is due to the fact that, pursuant to Provision Three of Circular 4/2019, such institutions are not authorized to enter into or offer to the public transactions involving virtual assets (they may only enter into internal transactions previously authorized by the Bank of Mexico), and therefore the reporting obligations served no practical purpose. The General Agreement also expressly states that the CNBV may not require documentation beyond that provided for in the General Agreement itself, including documents already on file.
Considerations
Entities subject to CNBV oversight should consider the following:
1.- SITI PLD/FT account holders. Entities maintaining SITI PLD/FT accounts under the previous homoclaves i) CNBV-28-024-A; ii) CNBV-30-004; and iii) CNBV-2025-016-004-A, should confirm that their registration and compliance status is properly reflected under the new unified CNBV-2026-001 filing.
2.- Transitional period. The CNBV has up to one year from the General Agreement’s entry into force to harmonize its internal regulations and guidelines (including AML/CFT general provisions and the SITI/PLD account manual) with these changes. During such period, the General Agreement prevails over any inconsistent prior provisions or administrative criteria.
3.- Compliance programs. Companies with compliance programs referencing eliminated or merged homoclaves should promptly update their compliance manuals, internal procedures and regulatory references accordingly.
Our Banking and Finance practice team is available to assess the General Agreement’s impact on your entity’s compliance programs, review pending CNBV filings, and support any adjustments required. Please do not hesitate to reach out.
