{"id":4059,"date":"2026-04-23T12:09:27","date_gmt":"2026-04-23T12:09:27","guid":{"rendered":"https:\/\/www.ibarrapg.com\/?p=4059"},"modified":"2026-04-23T18:33:22","modified_gmt":"2026-04-23T18:33:22","slug":"amendments-to-the-aml-regulations-operational-implementation-of-the-new-compliance-framework-and-strengthened-supervisory-and-enforcement-powers","status":"publish","type":"post","link":"https:\/\/www.ibarrapg.com\/en\/amendments-to-the-aml-regulations-operational-implementation-of-the-new-compliance-framework-and-strengthened-supervisory-and-enforcement-powers\/","title":{"rendered":"Amendments to the AML Regulations: Operational Implementation of the New Compliance Framework and Strengthened Supervisory and Enforcement Powers"},"content":{"rendered":"

The purpose of this note is to inform you that, further to our client alert dated July 16<\/span>th<\/sup>, 2025 regarding the amendment to the Federal Law for the Prevention and Identification of Transactions with Resources of Illicit Origin (the \u201c<\/span>AML Law<\/span><\/span>\u201d) and Article 400 Bis of the Federal Criminal Code, on March 27th<\/sup>, 2026 the Official Gazette of the Federation published the decree amending, supplementing, and repealing various provisions of the Regulations to the AML Law (the \u201c<\/span>Decree<\/span><\/span>\u201d). This regulatory amendment operationalizes the new legal framework, strengthens the powers of the Tax Administration Service (<\/span>Servicio de Administraci\u00f3n Tributaria<\/span><\/em>, the \u201c<\/span>SAT<\/span><\/span>\u201d) and the Financial Intelligence Unit (<\/span>Unidad de Inteligencia Financiera<\/span><\/em>, the \u201c<\/span>UIF<\/span><\/span>\u201d), and introduces relevant adjustments regarding reports, audits, politically exposed persons, and record retention.<\/span><\/p>\n

Key Amendments<\/span><\/h4>\n

1.- Politically Exposed Persons.<\/strong> <\/span>A dedicated chapter on Politically Exposed Persons (\u201c<\/span>PEPs<\/span><\/span>\u201d) is introduced, a UIF-managed list is contemplated, and financial entities and obligated parties are allowed to consult it, subject to the applicable general rules.<\/span><\/p>\n

2.- Broader powers for the SAT and the UIF.<\/span><\/strong> Both authorities may directly request information, documentation, data, and images; the Decree also contemplates electronic notifications, verification visits, and short response periods, with only limited extensions.<\/span><\/p>\n

3.- New rules on reports and transaction aggregation.<\/span><\/strong> Transactions carried out with the same client or user must be aggregated by type of transaction for up to six months, and the relevant report must be filed once the applicable threshold is met. In addition, a 24-hour report is regulated even when the transaction is not ultimately completed.<\/span><\/p>\n

4.- Registration and deregistration of obligated parties.<\/span><\/strong> The obligation to register before the SAT is strengthened for legal entities, trusts, and other legal arrangements, requiring a valid tax registration and advanced electronic signature, as well as a formal deregistration when the vulnerable activity ceases.<\/span><\/p>\n

5.- Audits and remediation of findings. <\/span><\/strong>Obligated parties must obtain, retain, and, where applicable, provide the SAT with the internal or external audit opinion and support documentation evidencing the remediation of observations.<\/span><\/p>\n

6.- Record retention and heightened enforcement. <\/span><\/strong>The obligation to retain reports, acknowledgements, and support documentation for at least ten years is reaffirmed, and review and sanction procedures for non-compliance are strengthened.<\/span><\/p>\n

Impact of the Amendment<\/span><\/h4>\n

This amendment confirms that Mexico\u2019s anti-money laundering regime has entered a phase of greater operational sophistication and heightened enforcement. For notaries, commercial notaries, trusts, collective entities, and other obligated parties, having policies on paper will no longer be sufficient; implemented controls, complete files, responsiveness to information requests, and effective follow-up on audits will be required.<\/span><\/p>\n

Although the Decree entered into force on the day following its publication, several operational aspects still depend on the update of official forms, annexes, electronic means, and general rules. We recommend an immediate review of risk matrices, identification procedures, aggregation and reporting mechanisms, record-retention policies, and readiness for internal or external audits.<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

The purpose of this note is to inform you that, further to our client alert dated July 16th, 2025 regarding the amendment to the Federal Law for the Prevention and Identification of Transactions with Resources of Illicit Origin (the \u201cAML Law\u201d) and Article 400 Bis of the Federal Criminal Code, on March 27th, 2026 the […]<\/p>\n","protected":false},"author":3,"featured_media":4060,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-4059","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-otros"],"acf":[],"_links":{"self":[{"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/posts\/4059","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/comments?post=4059"}],"version-history":[{"count":3,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/posts\/4059\/revisions"}],"predecessor-version":[{"id":4063,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/posts\/4059\/revisions\/4063"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/media\/4060"}],"wp:attachment":[{"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/media?parent=4059"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/categories?post=4059"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.ibarrapg.com\/en\/wp-json\/wp\/v2\/tags?post=4059"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}