ReformAML
AML: what changes under Resolution 115/2026 and the compliance timeline
The amendment to the General Rules (Reglas de Carácter General) takes effect on November 30, 2026; its transitional articles and two UIF resolutions phase in the rest between February 2027 and 2028. What changes, who is affected, and what to have ready on each date.
- Published
- October 14, 2026
- Reading time
- 6 minutes
- Law discussed
- Resolution 115/2026 (DOF, August 7, 2026)
- Entry into force
- November 30, 2026
In this article
In this article
6 min · 7 sections
If your company builds, develops, or brokers real estate, leases property, sells vehicles or jewelry, receives donations, or provides professional services on behalf of clients, it probably carries out a vulnerable activity (one of the activities subject to Mexico's anti-money-laundering law). The AML regime was reformed in stages: the Law in July 2025, its Regulations in March 2026, and the General Rules (Reglas de Carácter General) through Resolution 115/2026 (Acuerdo 115/2026), followed in September by two resolutions of the UIF (Financial Intelligence Unit) on forms.
The essentials, in thirty seconds
- Resolution 115/2026 (Acuerdo 115/2026), published in the Official Gazette of the Federation (DOF) on August 7, 2026, amends the 2013 General Rules; it does not issue new rules. It takes effect on November 30, 2026.
- Then, in stages: risk assessment, Manual, customer classification, and beneficial owner from March 1, 2027; automated systems no later than June 1, 2027; first audited period, 2028.
- Beneficial owner: the Law deems a legal entity to be controlled by whoever can exercise the vote of more than 25% of the capital, among other cases; the Rules look first for whoever holds 25% or more and require it to be documented.
- Two UIF resolutions (DOF, September 24, 2026) set a new enrollment and registration form from February 1, 2027, and new forms for all reports, including the 24-hour suspicious-transaction report, from June 1, 2027.
- Documentation of each transaction is kept for at least ten years; penalties are challenged through an appeal for review (recurso de revisión) or before the Federal Court of Administrative Justice (Article 61 of the LFPIORPI).
What was amended
The July 16, 2025 amendment to the Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds, LFPIORPI) added to Article 18, among others, Sections VII to XI: risk assessment, Internal Policies Manual, personnel selection and training, automated monitoring, and annual audit, and left it to the Rules to set when they become enforceable (Third Transitional Article of the decree). Resolution 115/2026, published on August 7, 2026, does not issue new rules: it amends the 2013 Rules to develop those obligations and the identification of the beneficial owner (beneficiario controlador).
NoteAcronyms
LFPIORPI: Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Mexico's AML law). UIF: Unidad de Inteligencia Financiera (Financial Intelligence Unit). SAT: Servicio de Administración Tributaria (Mexico's federal tax authority). UMA: Unidad de Medida y Actualización (index used to set fines and thresholds).
Who it applies to
The Rules are addressed to those who carry out the vulnerable activities listed in Article 17 of the LFPIORPI, including through fideicomisos (Mexican trusts) or other legal structures. For several activities, the Law sets one amount for identifying the customer and another, higher one for filing a report; for others, such as real estate construction or brokerage, the customer is identified in every transaction and only the report depends on the amount.
Among the activities in Article 17
- Habitual or professional real estate construction, development, or brokerage, and funds for developments (Sections V and V Bis).
- Real estate leasing (XV); sale of vehicles (VIII) and of jewelry, watches, precious metals, or precious stones (VI).
- Notarial attestation (fe pública) by civil-law notaries, corredores públicos (public commercial brokers), and facilitators of alternative dispute resolution (XII).
- Professional services that handle the client's funds or assets, or manage companies or trusts on the client's behalf (XI).
- Donations to nonprofit associations (XIII) and virtual asset platforms (XVI).
- Does not apply: Amounts below those set in the relevant section, unless transactions aggregated over six months exceed the reporting threshold (penultimate paragraph).
| Activity | Section | Identification threshold | Reporting threshold |
|---|---|---|---|
| Habitual or professional real estate construction, development, or brokerage; funds for developments | V and V Bis | Every transaction | 8,025 UMA |
| Real estate leasing (monthly value) | XV | More than 1,605 UMA | 3,210 UMA |
| Transfer of real estate or in rem rights before a notary | XII, A, a) | Every transaction | 8,000 UMA |
2026–2028 timeline
The transitional articles of Resolution 115/2026 phase in the new obligations, and the two UIF resolutions of September 24, 2026, set when the enrollment and reporting forms change. These are the dates published in the Diario Oficial de la Federación (DOF).
- 2026The UIF publishes the resolutions amending the enrollment and registration form and the forms for reports and statements.
- 2026Entry into forceResolution 115/2026 takes effect (First Transitional Article).
- 2027New enrollment and registration form; those already registered who act through a fideicomiso or other legal structure, or who clear goods through customs, must deregister and re-enroll (Third Transitional Article of the UIF registration-form resolution).
- 2027Risk assessment and Manual available to the authority; customer classification, beneficial owner, and selection of new personnel apply (Second to Fourth and Sixth Transitional Articles).
- 2027Deadline for automated systems (Ninth Transitional Article). Reports and statements, including 24-hour reports, on the new forms; the old ones cease to be available on July 1 (UIF report-forms resolution, Second, Fourth, and Fifth Transitional Articles).
- First annual training period, January to December (Seventh Transitional Article).
- First audit period, January to December (Eighth Transitional Article).
What to prepare, and in what order
- Confirm your activity and your registration
Check whether you fall under Article 17 and whether your enrollment in the SAT registry is current (Article 18, Section IV Bis, of the Law). If you operate through a fideicomiso or other legal structure, plan for deregistration and re-enrollment using the form that applies from February 1, 2027.
Deadline: Before Nov 30, 2026
- Assess your risks and update the Manual
A methodology with indicators by transaction, customer, geographic area, and channel (Articles 10 Septies and 10 Septies 1 of the Rules), included in the Manual together with the customer risk classification (Articles 23 Bis, 23 Ter, and 37).
Deadline: Available to the authority · Mar 1, 2027
- Document the beneficial owner
Order set by Article 23 Quinquies: 25% or more of the capital, control by other means and, lastly, senior management; for fideicomisos, Article 23 Quinquies 1. Document the procedure.
Deadline: Transactions from Mar 1, 2027
- Select and train your personnel
Selection with a signed statement for new hires (Article 39 Bis 2) and an annual training program (Article 39 Bis), with evidence kept for ten years.
Deadline: Training · year 2027
- Implement automated systems
A single file per customer, aggregation of transactions over six months, and alerts for transactions outside the customer's profile and for high-risk or politically exposed customers (Article 41).
Deadline: Deadline · Jun 1, 2027
- Plan for the audit and urgent reports
With low or medium risk, the internal audit may issue the audit report; with high risk, an external auditor must do so (Articles 42 to 45). Decide who files the 24-hour suspicious-transaction report (Articles 26 Bis and 26 Bis 1).
Deadline: Audited period · 2028
NoteBeneficial owner (beneficiario controlador)
The individual or group of individuals who ultimately obtain the benefit of the transaction or control the client legal entity. The Law deems control to exist when a person can exercise the vote of more than 25% of the capital, impose decisions or appoint the majority of the directors, or direct the company (Article 3, Section III).
Where to comply and how to challenge penalties
| Authority | Role |
|---|---|
| Financial Intelligence Unit (UIF) | Interprets the Law, the Regulations, and the Rules for administrative purposes; issues the forms and requests information (Article 3 of the Regulations). |
| Tax Administration Service (SAT) | Keeps the registry, receives reports, verifies compliance, and imposes penalties (Article 4 of the Regulations). |
Enrollment and reports are filed through the SAT's Sistema del Portal en Internet (SAT Anti-Money Laundering Portal, SPPLD). Penalties are challenged through an appeal for review before the Ministry of Finance (Secretaría de Hacienda y Crédito Público) or before the Federal Court of Administrative Justice (Article 61 of the LFPIORPI).
Frequently asked questions
Does a new law take effect on November 30, 2026?
No. On that date, the amendment to the General Rules (Resolution 115/2026) begins to apply. The amendment to the Law was published on July 16, 2025, and the amendments to its Regulations on March 27, 2026; both are already in force. What changes in November is the operational detail of how they are complied with.
How do I know whether my activity is a vulnerable activity?
Article 17 of the LFPIORPI lists the vulnerable activities and sets, depending on the activity, the amounts (in multiples of the daily UMA value) from which the customer must be identified or a report filed; for some, such as real estate construction or brokerage, the customer is identified in every transaction. Determining whether a specific transaction falls within scope requires reviewing the activity, how habitually it is carried out, and its amounts, including the aggregation of transactions by the same person over six months. Anyone acting through a fideicomiso or other legal structure also carries out the activity.
What if none of my client's shareholders reaches 25% of the capital?
The Rules set an order of priority (Article 23 Quinquies). If no one holds 25% or more, the person who controls the company by other means, such as strategy or decision-making, is identified; failing that, the person in senior management or the highest administrative position. In a fideicomiso, it is the individual who exercises effective control, who may be the trustee, a settlor, a beneficiary, a protector, or a member of the technical committee; if any of them is a legal entity, the chain is followed up to the individual (Article 23 Quinquies 1). Identification takes place before the transaction or, at the latest, when the business relationship begins, and is documented.
Must I have everything ready by November 30, 2026?
Not everything. Resolution 115/2026 takes effect on that date, but its transitional articles, to which the legal reform deferred these dates, phase in the new obligations: risk assessment, the Manual, customer classification, and beneficial ownership apply from March 1, 2027; automated systems and reports on the new forms, from June 1, 2027; the first training period is 2027 and the first audited period, 2028. If you act through a fideicomiso, the new enrollment form applies from February 1, 2027.
Can I challenge a SAT fine in this area?
Yes. Article 61 of the LFPIORPI allows administrative penalties to be challenged through the appeal for review (recurso de revisión) under the Ley Federal de Procedimiento Administrativo (Federal Administrative Procedure Law), before the Ministry of Finance itself, or directly before the Federal Court of Administrative Justice through administrative litigation. The appropriate route and the deadlines depend on the ruling served.
Official sources
This article was prepared from the texts published by the authorities. We recommend consulting them directly.
- DOFAcuerdo 115/2026 por el que se modifican las Reglas de Carácter General de la LFPIORPI (Resolution 115/2026 amending the General Rules under the LFPIORPI) (opens the source's website). Ministry of Finance and Public Credit, evening edition. First to Twelfth Transitional Articles.
- SATAcuerdo 115/2026 (PDF íntegro en la Normateca de Actividades Vulnerables) (full PDF in the SAT's regulatory library on vulnerable activities) (opens the source's website)Articles 10 Septies, 23 Bis to 23 Quinquies 1, 26 Bis, 37, 39 Bis, 41 to 45, and transitional articles.
- DOFResolución que modifica la diversa por la que se expide el formato oficial para el alta y registro de quienes realicen actividades vulnerables (UIF resolution amending the enrollment and registration form) (opens the source's website). UIF. In force February 1, 2027; trusts and other structures deregister and re-enroll (Third Transitional Article).
- DOFResolución que modifica la diversa por la que se expiden los formatos oficiales de los avisos e informes que deben presentar quienes realicen actividades vulnerables (UIF resolution amending the report forms) (opens the source's website). UIF. New forms from June 1, 2027; the old ones cease to be available on July 1, 2027.
- DOFDecreto que reforma y adiciona la LFPIORPI y reforma el artículo 400 Bis del Código Penal Federal (decree amending the LFPIORPI and Article 400 Bis of the Federal Criminal Code) (opens the source's website). Articles 3, 17, 18, and 61 amended; First to Third Transitional Articles.
- DOFDecreto que reforma, adiciona y deroga disposiciones del Reglamento de la LFPIORPI (decree amending the LFPIORPI Regulations) (opens the source's website). In force the day after its publication (First Transitional Article).
- DiputadosLey Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds) (opens the source's website)Current text, last amended DOF, July 16, 2025. Articles 3, 17, 18, and 61.
- DiputadosReglamento de la Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI Regulations) (opens the source's website)Current text, last amended DOF, March 27, 2026. Articles 3, 4, and 12.
- SATActividades Vulnerables: Normateca (Ley, Reglamento, Reglas de Carácter General y acuerdo de modificación) (vulnerable activities: regulatory library with the Law, Regulations, General Rules, and amending resolution) (opens the source's website)
- SATSistema del Portal en Internet (SPPLD) para el alta, los avisos y los informes de actividades vulnerables (online portal for enrollment, reports, and statements on vulnerable activities) (opens the source's website)
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TopicsLFPIORPI · Vulnerable activities · General Rules · Beneficial owner · Risk assessment · SAT
