New Anti-Money Laundering Law: Higher Fines for Businesses

QUINTANA ROO, Mexico — A recent reform to the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (Lfpiorpi), published in the Official Journal of the Federation (DOF) on July 16, 2025, and in force since the following day, entails significant adjustments for companies engaged in activities considered vulnerable.

Fausto Darío Bañuelos Sánchez, a specialist in Real Estate Law and Anti-Money Laundering Compliance, warned that business owners will have to modify their compliance structures and adapt to the new provisions. "It is a regulatory body that must be complied with and it will generate costs. It has difficulties, but there is no option: the business owner must take the step, as verification visits by tax authorities have been increasing," he stated.

One of the main fears for business owners is the fines. The generic minimum penalty is 22,000 pesos, but monthly omissions of required notices can accumulate million-peso amounts. Each obligated entity must submit notices no later than the 17th of each month, even if it has had no operations. Failure to do so within the following 30 days is considered an omission, and the fine can reach 1.1 million pesos per month.

In a scenario of total non-compliance, a company could receive an initial fine of 13.2 million pesos for one year of omitted notices, in addition to further penalties for lacking manuals, forms, or personnel to comply with the norm.

The expert emphasized that the first step is to identify if a company performs a vulnerable activity. The law does not require hiring an external advisor, but he recommended doing so to structure an adequate compliance program. However, he warned that in Quintana Roo there are still not enough specialized firms on the subject.

A novel aspect is the inclusion of the restricted zone trust, used by foreigners to purchase properties on the coast or in border regions, as a vulnerable activity. "It is still not clear who will be responsible for fulfilling the obligations in these cases: the trust banks or the foreign beneficiaries themselves, such as retirees who bought beach houses," he explained. The definition of general rules could take up to 12 months.

The notarial sector had its threshold lowered for the sale of goods and real estate; previously they reported from 16,000 UMAs (Unit of Measure and Update), and now it is from 8,000, which is equivalent to 947,000 pesos. In the case of the automated system, it is not yet known what specific characteristics it must have.

There are restrictions on cash payments above certain amounts for specific activities. For the sale of real estate, the limit is 8,025 UMAs, which is 900,000 pesos, meaning the client is prohibited from paying or settling that amount or more in cash, and the seller is prohibited from receiving it. For other activities, such as the sale of vehicles, jewelry, precious metals, works of art, tickets and prizes from games or draws, shares, and leases, the limit is 3,210 UMAs, which is 363,000 pesos per operation.

Some obligations came into force immediately, while anti-money laundering audits will be applied starting with the 2026 fiscal year.

"Beyond the economic cost, the problem is cultural; many business owners do not comply adequately with the norm. However, the objective of the reform is to strengthen the financial system and shield it from illicit operations that affect both the economy and the administration of justice," he concluded.