In July 2025, Mexico enacted substantial reforms to the Federal Law for the Prevention and Identification of Operations with Resources from Illicit Sources (LFPIORPI)—AML Law, radically transforming the compliance landscape for businesses conducting vulnerable activities. These reforms expanded existing obligations for all regulated sectors and introduced high-impact specific changes in the jewelry and real estate industries that have generated unprecedented operational challenges.
Key Changes Introduced by the Reform
The most significant modifications that those handling vulnerable activities must implement include:
Corporate Identification and Transparency:
- Beneficiary owner: Obligation to identify the real persons behind complex corporate structures, going beyond superficial information about legal representatives
- Trusts under the scope: For the first time, trusts must comply with specific transparency requirements, revealing settlors, trustees, and beneficiaries
Risk-Based Management:
- AML/CFT self-assessment: Companies must evaluate their own level of exposure to money laundering and terrorist financing risks
- Annual independent audit: Obligation to contract external audits specialized in AML/CFT, representing a significant recurring operational cost
Human Resources and Training:
- Hiring profiles: Implementation of integrity assessments and background checks for key personnel
- Annual training programs: Continuous and mandatory AML/CFT training for all relevant personnel
Technology and Record Retention:
- Automated monitoring systems: Obligation to implement technology capable of identifying and monitoring customer transactional profiles, detecting unusual operations
- Doubling of retention period: Documents must be retained for 10 years instead of the previous 5 years, doubling storage and document management obligations
The obligation to have automated systems represents a paradigmatic shift. It is no longer sufficient to maintain passive records; companies must implement technology capable of detecting anomalous patterns and unusual operations. For many small and medium enterprises, this represents substantial technological investments and the need to hire specialized personnel.
Critical Impact on the Jewelry Sector: The End of the Cash Exception
The jewelry sector has historically been recognized as a high-risk vulnerable activity due to characteristics that make it exceptionally attractive for money laundering operations: high value concentration, extreme portability, subjective valuation, opaque market, global acceptance, cash preference, absence of centralized registry, and verification difficulty. These characteristics converge to create a scenario where a single transaction can launder millions of pesos with relative ease.
The Fundamental Regulatory Change
Section VI of Article 17 of the LFPIORPI establishes as a vulnerable activity the commercialization or intermediation, habitual or professional, of precious metals, jewelry, and high-end watches.
Before the reform: The law required reporting to the Financial Intelligence Unit (UIF) only those operations paid in cash that exceeded established thresholds. This limitation created a significant gap, as high-value operations paid through transfers, checks, or cards remained outside the reporting scope.
After the reform: The cash payment limitation was eliminated. The reform took effect the day after its publication, leaving many merchants without time to adapt their systems.
New Applicable Thresholds:
- $91,077.70 MXN ($4,918.51 USD): All operations exceeding this amount, regardless of payment method, must comply with complete AML/CFT obligations
- $181,589.70 MXN ($9,806.48 USD): Operations exceeding this threshold must be mandatorily reported to the UIF, regardless of payment method
Immediate Consequences
The immediate enforcement has generated critical challenges:
Report volume: Jewelry stores that previously reported dozens of operations annually must now report hundreds or thousands, especially those commercializing high-end pieces.
Urgent technological investment: Many jewelry stores operated with basic point-of-sale systems. Implementing automated systems with compliance functionalities represents significant investments that must be made immediately.
Personnel training: Sales staff must identify when a transaction approaches thresholds and activate identification and documentation protocols, requiring exhaustive training in practical scenarios.
Impact on customer experience: New documentary requirements may affect the shopping experience, particularly for high-value customers accustomed to discrete and expedited transactions.
Unfair competition risk: Informal merchants who don’t comply gain competitive advantage, while formal merchants face higher operational costs.
Impact on Real Estate Development: The Elimination of Administrative Benefits
Real estate development faces particular challenges for anti-money laundering compliance: projects involve dozens or hundreds of simultaneous operations, pre-sales occur years before final deed execution, payments are fractioned over months or years, and multiple parties participate (developer, marketer, financial institution, trust).
The Historical Administrative Benefits
Recognizing these challenges, the Ministry of Finance and Public Credit (SHCP) had granted the sector an administrative benefit through General Rules that allowed:
- Initial project registration with the authority with complete information
- Obtaining a unique development identification code
- Continuous information collection during the construction and commercialization period
- Single consolidated report upon project conclusion, containing all information on operations, customers, amounts, and documentation
This benefit implicated a 98% reduction in the number of individual notices, maintaining equally complete and useful information for the authority, with greater operational efficiency for developers and error reduction.
The Benefit Elimination (September 2025)
In September 2025, the SHCP issued a General Rule specifying that, as a consequence of the July reforms, the administrative facility was without effect as of October 2025.
New regime: All real estate developments must present individual notices for each operation exceeding 8,025 UMAs, equivalent to $907,948 MXN ($48,996.86 USD).
The Impact
Exponential multiplication of reports: A development of 200 units that previously generated 1 consolidated report must now generate up to 200 individual reports, assuming all units exceed the threshold (likely in middle and upper-class urban developments).
Timing complexity: The obligation arises at different moments depending on transaction structure (cash payment, fractioned payments, down payments), generating uncertainty and risk of involuntary non-compliance.
Massive administrative resources: Developers require automated systems to track thresholds per unit, dedicated personnel for notice presentation, post-report update processes, and coordination with notaries and marketers.
Dramatic cost increase: Specialized software, specialized personnel (compliance officers, analysts), consultant fees for annual audits, and sales personnel time dedicated to compliance procedures.
Marketing impact: Longer transaction closing times, potential loss of buyers who perceive requirements as invasive, and need to educate buyers on legal foundations.
Essential Strategic Recommendations
For the Jewelry Sector:
Immediate technological implementation: Invest in point-of-sale systems integrated with anti-money laundering functionalities that automatically identify thresholds and activate protocols.
Exhaustive practical training: All personnel must understand thresholds, identification obligations, and file integration processes through practical scenarios and role-playing.
Frictionless process: Develop procedures that comply with legal requirements while minimizing impact on customer experience. Proactively communicate to high-value customers about regulatory requirements.
For the Real Estate Sector:
Comprehensive process redesign: Integrate identification and documentation requirements from first contact with buyers, not as last-minute requirements.
Specialized platforms: Implement specific technology for compliance management in real estate developments that handles fractioned payments, multiple buyers, and updates.
Institutional collaboration: Establish efficient channels with banks and financial institutions to coordinate compliance and avoid duplications.
Cross-cutting Recommendations:
Proactive audits: Conduct quarterly compliance assessments to identify and correct deficiencies before they generate liabilities.
Specialized advisory: Have specialized AML/CFT legal advisory that correctly interprets obligations and designs robust compliance programs.
Compliance culture: Cultivate an organizational culture that values compliance from senior management to operational personnel.
Consequences of Non-Compliance
Non-compliance generates not only administrative consequences but criminal liabilities:
Administrative sanctions: Fines of tens of millions of pesos, temporary or permanent closure, and disqualification from conducting vulnerable activities.
Criminal consequences: Article 400 Bis of the Federal Criminal Code typifies the crime of money laundering with sanctions of 5 to 15 years in prison. Systematic non-compliance can be interpreted as facilitation of laundering.
Reputational damage: Public designation generates irreparable damage, customer loss, and difficulties accessing financial services.
Conclusion
The 2025 reforms to the AML Law represent a fundamental change in anti-money laundering compliance in Mexico, particularly for the jewelry and real estate sectors. The elimination of historical exceptions and the imposition of more rigorous obligations reflect both the evolution of international standards and the increasing sophistication of money laundering schemes.
For companies conducting vulnerable activities, the question is no longer whether they should invest in robust compliance, but how much and how quickly they can implement the necessary systems, processes, and culture. Companies that act proactively will not only avoid severe consequences of non-compliance but will build competitive advantages based on integrity, reputation and operational efficiency.
The time to act is now. The cost of preparation is invariably less than the cost of remediation or sanctions.
This article is provided for informational purposes only and does not constitute legal advice. Companies facing compliance challenges related to the LFPIORPI should consult with specialized legal counsel to evaluate their specific situation and develop appropriate compliance strategies.
