Anti-money Laundering Rules 2026: What Every Real Estate Developer Must Solve Before it's Too Late
- Newlex
- 18 hours ago
- 6 min read
The new General Rules (RCG) of the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) are now official. Agreement 115/2026 of the Ministry of Finance and Public Credit (SHCP), published on August 7, 2026, in the Official Gazette of the Federation, closes a cycle of reforms that began in July 2025 and that fundamentally changed the rules of the game for those who develop real estate projects in Mexico. If your business raises resources to build, divide, or market a development, this is no longer an exclusive issue in the legal area: it is an operational risk that can stop a sale, financing, or an investment round if it is not resolved.
What exactly changed on August 7, 2026?
Agreement 115/2026 modifies the General Rules in force since 2013 (reformed in 2014 and 2020) to align them with the reform to the LFPIORPI of July 2025 and with the Regulation reformed in March 2026. In practical terms, this is what the SHCP finished defining:
An order of priority to identify the controlling beneficiary in complex structures (trusts, companies, investment vehicles).
A formal Risk-Based Approach (RBA), with clients classified as low, medium, and high risk.
Updated rules to identify Politically Exposed Persons (PEP).
The specific requirements for the internal policy manual, annual training, annual audit, and, most needed, automated continuous operations monitoring mechanisms.
Three dates that you should already have marked
The new anti-money laundering regime did not come suddenly: it was built in three stages, and all three are already in force.
July 16, 2025 — Reform to the LFPIORPI, in force from the next day. Here section V Bis of article 17 was born, which directly affects real estate development.
August 7, 2026 — SHCP Agreement 115/2026, which modifies the General Rules: the piece that translates all of the above into operating procedures.
November 30, 2026 — SHCP Agreement 115/2026 comes into force along with all its provisions towards obligated subjects.
The faction that changed the game: V Bis of article 17
Before July 2025, the anti-money laundering radar in real estate focused on the purchase and sale of real estate (section V of article 17): notaries, brokers, and those who brokered an already closed transaction. The reform added a new section, the V Bis, which qualifies as Vulnerable Activity "the receipt of resources that are allocated to carry out a Real Estate Development whose purpose is its sale or rental," and defines "Real Estate Development" (article 3, section IV Bis) as "the project for the construction of properties or division of lots intended for sale or rental."
The difference with fraction V is not cosmetic:
In other words, if your structure receives money from investors or buyers to build a development—even if you subcontract the construction and even if you are not the one who signs the final deed—you are already an obligated subject under the LFPIORPI.
The obligations you already have, even if you have not put them into action
With the three pieces of the framework already in force, this is what applies today to whoever carries out the Vulnerable Real Estate Development Activity:
Identification of the client and the person providing the resources, regardless of the amount. The obligation to identify applies from the first weight; there is no minimum floor.
Notice to the SHCP when the operation (or the sum of related operations) reaches 8,025 UMA (of the order of $900,000–$940,000 pesos, according to the daily value of the UMA in force in 2026).
Identification of the controlling beneficiary, with the new order of priority established by Agreement 115/2026—critical when the development is structured through a trust or a company with several levels of shareholders.
Registration in the registry of Vulnerable Activities before the SAT.
Complete identification file kept for 10 years (no loose emails or WhatsApp: an orderly file, available for audit).
Internal policy manual, annual staff training, and annual compliance audit.
Automated mechanisms for continuous monitoring of operations—the obligation that, until Agreement 115/2026, did not have a clear procedure on how to comply.
Controlling beneficiaries in real estate trusts and SPVs: the most common blind spot
Most medium- and large-scale developments in Mexico are structured with a trust or a specific-purpose company that raises capital from several investors. That is exactly the scenario that the reformed LFPIORPI—and now Agreement 115/2026—puts under the magnifying glass: it is no longer enough to identify "who signs"; it is necessary to document who really controls the structure, with what percentage and under what order of priority. For a developer, this usually means redoing or completing the project vehicle's stock chart, not just filling out a form.
Automated monitoring: the obligation that is no longer resolved with an Excel sheet
This is probably the change with the most operational friction. The regulation reformed in March 2026 already anticipated that obligated subjects must have automated mechanisms to monitor the transactional profile of their clients; Agreement 115/2026 finished defining what is expected from this monitoring: continuous monitoring of operations, alerts against atypical behavior (fractional payments, contributors other than the buyer, and unexplained financing), and evidence that this monitoring really occurs, not only that there is a manual that describes it.
For a developer, this is not just a legal problem: it is also an infrastructure problem. And that is exactly where a compliance platform like Regcheq changes the panorama because it solves, in a friendly and quick way, what previously meant building a system from scratch:
In other words, the part of the reform that keeps developers up at night the most—having real automated monitoring with up-to-date watch lists and being ready for an audit—is, today, the easiest to solve if you rely on the right tool instead of trying to build it internally.
What happens if it is not fulfilled?
The LFPIORPI sanctions are not symbolic: they range from 200 to 65,000 UMA for administrative offenses, and in the most serious cases—omitting notices or altering files—they can reach between 10% and 100% of the value of the operation involved. Beyond the fine, the real risk for a developer is reputational and transactional: an institutional investor or a bank financing the project will demand evidence of compliance before disbursing, and not having it ready can stop the closure.
What to do in the coming weeks
Confirm if your structure falls into fraction V Bis, even if you are not the one who builds or sells directly.
Reviews the share and control organization chart of the trust or SPV of the project and documents the controlling beneficiary according to the new order of priority.
Register (or update your registration) in the SAT Register of Vulnerable Activities.
Update your internal policy manual and your risk matrix with the criteria of Agreement 115/2026.
Solve automated monitoring, watchlists, and audit support with a platform like Regcheq before an institutional client or bank asks you to do so as a closing condition.
Frequently asked questions
Since when should I comply if I already have a development underway? Since July 17, 2025, the date on which the reform that created section V Bis came into force. It is not an obligation that begins with Agreement 115/2026; the latter only finishes defining the operating procedures.
Does Section V Bis apply to me if I do not build or sell directly? Do I only manage the project resources? Yes. Section V Bis qualifies the receipt of resources destined for development, not the construction or sale itself. Management trusts and vehicles that raise capital from investors are included.
What exactly is the "automated monitoring" required by the new rule? A mechanism that provides continuous monitoring—not only at the time of initial identification—of the client's operations, capable of generating alerts against atypical behavior, crossing updated watch lists, and leaving evidence of that surveillance for an eventual audit. Platforms like Regcheq offer it already integrated, without the developer having to build it from scratch.
Where can I consult the official text? In the Official Gazette of the Federation (dof.gob.mx, afternoon edition of August 7, 2026) and on the SAT Money Laundering Prevention Portal (sppld.sat.gob.mx).
Conclusion
Real estate development is no longer a spectator in the Mexican anti-money laundering framework: with section V Bis, the Regulation of March 2026 and now agreement 115/2026, it is one of the sectors with the most new obligations and the most operational ambiguity to be resolved. Newlex's recommendation for developers and investors is the same one we have found with each piece of this reform: do not wait for a bank or investor to demand it as a closing condition. Structuring the controlling beneficiary of your investment vehicle well is a legal job; solving automated monitoring, watchlists, and audit preparation with a tool like Regcheq is instead the quickest part of this entire package to solve.
