Short answer
If your company carries out a vulnerable activity under Mexico's anti-money laundering law (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, LFPIORPI, art. 17), such as the sale of real estate, vehicles or jewellery or certain services, it must identify its clients, keep records and file notices with the SAT (art. 18). SNZ Legal Group helps companies comply from Guadalajara, with a manual, processes and training.
Core obligations
- Register on the SAT anti-money laundering portal.
- Identify clients and verify their identity with official documents (LFPIORPI art. 18).
- Identify the beneficial owner (beneficiario controlador).
- File notices when transactions exceed the legal thresholds, which are expressed in UMA and vary by activity.
- Keep the information for the legal period.
- Appoint a compliance officer, adopt a policy manual and train staff.
Building a compliance programme
A practical programme includes a diagnosis of the business and its transactions, a policy manual, client identification forms, staff training, a notice calendar and periodic review, at least once a year and whenever the law, thresholds or business change. It also helps with banks and commercial partners, which increasingly request AML information.
| Common vulnerable activity | Example |
|---|---|
| Real estate | Sale or brokerage of homes and land |
| Vehicles | Sale of new or used cars |
| Jewellery and metals | Jewellery stores |
| Loans | Non-bank loans or credit |
| Real estate leasing | Leases above a certain value |
Thresholds and scope must be checked for each activity against article 17.
Verification visits and sanctions
The SAT can verify registration, client files, notices and the manual. The law provides fines for failing to file notices, filing late or failing to identify clients, and some conduct may be a crime. A company that is prepared shows its manual, organised files and notice receipts.
Common mistakes
- Thinking AML rules apply only to banks.
- Not identifying the beneficial owner.
- Accepting cash above the legal limit.
- Not keeping client files.
Frequently asked questions
How do we know if our activity is vulnerable?
Article 17 of the LFPIORPI lists vulnerable activities. We review your line of business and tell you whether it applies.
Do you run internal compliance audits?
Yes. We review client files and processes and deliver a report with corrective actions.
What is a notice (aviso)?
A report to the SAT of transactions that exceed the thresholds set by law.
Who is the beneficial owner?
The individual who ultimately benefits from or controls a transaction or a company.
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