Mexico’s 2025 Anti-Money Laundering Reforms: A Game-Changer for Every Corporation Operating or Doing Business in Mexico

Executive Brief

On July 16, 2025, the Mexican government enacted the most significant reform in over a decade to the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (LFPORI). This is not a minor update—it represents a structural shift in the corporate and compliance landscape.

The amendments dramatically expand the scope of regulated entities, impose new and stricter obligations, and, most critically, establish personal liability for directors and officers. Every corporation with operations or business in Mexico must prepare for this new regulatory framework.

Key Aspects of the Reform

1. The End of Exemptions: Virtually All Companies Are Now Covered

The most impactful change is the expansion of what constitutes a “Vulnerable Activity.” Previous income thresholds that excluded many companies have been eliminated, pulling a vast number of previously exempt entities into the scope.

• Sale of goods: any entity habitually selling tangible products is now regulated, far beyond real estate, vehicles, or jewelry.

• Newly added activities:

  a) Corporate governance: board meetings, maintaining corporate books, and administrative functions. b) Professional services: legal, accounting, financial, and corporate consulting services when managing assets or facilitating transactions.

  c) International trade: all import and export operations, regardless of value or volume.

👉 In short: if you operate a legal entity in Mexico, you are most likely now subject to LFPORI obligations.

2. Compliance Programs: From Checkbox to Core Business Function

A generic compliance manual is no longer sufficient. The law requires a formal, dynamic, and risk-based Compliance Program.

• Mandatory implementation for every regulated entity.

• Tailored approach based on industry, client base, geography, and transaction risks.

• Enhanced minimum requirements now include:

  • Documented risk assessments.

  • Screening against sanctions lists and PEP identification.

  • Escalation, rejection, and reporting protocols for unusual transactions.

3. Director & Officer Liability: Now Personal and Real

The reform introduces a formal Duty of Oversight for directors and senior officers.

• Executives and board members can be held personally and jointly liable for fines if compliance programs are ineffective. Ignorance is not a defense.

• The Board or Audit Committee must review and formally approve the Compliance Program annually, with minutes reflecting oversight.

4. Strengthened Reporting & UIF Powers

• Complex structures: companies must report to the Financial Intelligence Unit (UIF) any trusts or arrangements obscuring beneficial ownership.

• Freezing orders: UIF may now directly order companies to freeze assets or suspend client transactions without a court order.

5. Severe Penalties

The cost of non-compliance has increased dramatically:

• Fines up to 10% of annual gross income.

• Suspension of operations from 90 days to 5 years.

• Ineligibility of sanctioned individuals to act as legal representatives.

• Increased risk of asset forfeiture under Mexico’s forfeiture laws.

Conclusion

The 2025 LFPORI reforms usher in a new era of corporate accountability in Mexico. Compliance can no longer be treated as a secondary task—it is a strategic business priority and a core responsibility of corporate leadership.

At Ojeda y Caro Abogados, we can assist in developing an immediate action plan to determine whether your operations fall under the expanded definition of Vulnerable Activities and help you implement a robust compliance program.

📩 Contact us at contacto@ojedaycaro.com for further information.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The application of the law depends on the specific facts of each case. We strongly recommend engaging qualified Mexican corporate counsel to assess your company’s obligations under these reforms.