Mexico’s Real Estate Sector Prepares for New Anti-Money Laundering Rules

Mexico City — Mexico’s real estate industry must overhaul its anti-money laundering procedures before new regulations take effect on Nov. 30, expanding the requirements for anyone involved in property transactions.

The new General Rules of the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds — known as the Anti-Money Laundering Law — broaden the obligations for individuals and companies that carry out “vulnerable activities” related to real estate.

David Merino Téllez, compliance officer at AMPI Nacional, the country’s main real estate industry association, said on the program “Tiburones Inmobiliarios” that the rules go far beyond identifying clients and filing notices. They now require risk assessments, internal manuals, staff training and additional controls.

“The model changed from just sending notices to a compliance system,” Merino said, adding that the regulations also establish a new supervision scheme.

Noncompliance carries significant financial consequences. Merino said failing to file certain notices can trigger fines of more than 1 million pesos, while the steepest penalties can exceed 7.5 million pesos depending on the violation.

Who Must Comply

The rules apply to individuals and legal entities that carry out the vulnerable activities listed in Article 17 of the law, including certain real estate development and brokerage operations and the use or enjoyment of properties when the established conditions and thresholds are met.

The obligations do not stop at companies. Independent advisors working on commission or under professional services contracts may also be responsible. Merino said liability depends on the contracting arrangement and how the transaction is carried out.

“A real estate advisor is normally not a member of the agency; they are a commission agent or an independent service provider,” he said, explaining why advisors should not assume that their firm’s compliance automatically covers their own obligations.

Files, Manuals and Biometric CURP

Those carrying out vulnerable activities must review their registration, update client files and have procedures in place to understand each client’s economic activity and the source of the funds used in every transaction. They must also apply controls to identify controlling beneficiaries and politically exposed persons.

Merino stressed that keeping a copy of an ID is not enough. Firms must verify that the document belongs to the person taking part in the transaction and document that check. “The ID in hand and confirming that the person sitting in front of you matches the ID,” he said. The file, he added, must record who performed the verification and the date and time.

The specialist also urged firms to review their compliance manuals in light of changes involving the biometric CURP, Mexico’s unique population registry code. “Most of the manuals I have seen do not contemplate it,” he said.

A Staggered Timetable

The agreement published in the Official Gazette sets Nov. 30, 2026, as the general start date, though some obligations carry their own deadlines.

An internal policies manual must be drawn up within 90 calendar days of registration. Under a transitional provision, starting March 1, 2027, those already registered whose 90-day window has closed must have a manual that includes a risk assessment methodology and make it available to authorities on request.

The risk-based evaluation must also be available to authorities on request from March 1, 2027. Automated mechanisms must be in place by June 1, 2027, and the first annual audit review period will run from Jan. 1 to Dec. 31, 2028.

Merino told real estate professionals to prepare without panicking and to use the time available. “There is still time between now and Nov. 30; a lot can be done to get off to a good start,” he said, recommending training and specialist advice where needed.