Amendment To The General Rules Of The Anti-Money Laundering Law

Dear Clients and Friends:

On August 7, 2026, an Agreement was published in the Federal Official Gazette (“DOF”) amending, adding, and repealing various provisions of the General Rules referred to in the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (“Anti-Money Laundering Law”), which includes several relevant matters that should be considered by those who carry out Vulnerable Activities (issuance and commercialization of cards, construction or real estate development, leasing of real property, commercialization of vehicles, receipt of donations, exchange of virtual assets, among others).

Among the main implications, the following stand out:

• The reduction of the threshold for the identification of the Controlling Beneficiary, based on voting rights, to more than 25% of the capital stock.
• The confirmation of the inclusion of trusts and any other legal vehicle as parties obligated to register with the Vulnerable Activities registry, using their own advanced electronic signature, and the establishment of the corresponding forms.
• The obligation to design and implement a risk assessment methodology and to classify each Client or User with whom such Vulnerable Activities are carried out, which must be included in the Internal Policies Manual or in another document specifically prepared for such purpose.
• The obligation to implement automated mechanisms for monitoring Clients’ or Users’ acts or transactions, records, accumulation of transactions, among others.
• The inclusion of a detailed regime regarding notices for virtual asset service providers, including threshold rules for their filing.
• The regulation of the 24-hour notices based on suspicion and on facts or indicia.
• New notices for attempted transactions or transactions that do not reach the applicable threshold.
• The inclusion of new provisions regarding notifications from the Financial Intelligence Unit (“UIF”) or the Tax Administration Service (“SAT”) to obligated parties, which will now be electronic and shall be deemed served on the fourth business day following their dispatch.
• The regulation of training and audit obligations applicable to those who carry out Vulnerable Activities.
• Obligations to consult records regarding Politically Exposed Persons.
• The Compliance Officer must be an individual; legal entities are excluded.

The Agreement generally enters into force on November 30, 2026; however, certain of these obligations will enter into force on a staggered basis through 2027.

In light of the foregoing, it will be necessary to review the operations of those participating in Vulnerable Activities in order to identify the applicable obligations and implement the necessary adjustments to their internal policies, client identification processes, and compliance mechanisms.

We remain at your disposal to assist you.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.