2025 Anti-Money Laundering Law Reform: Key Points for Real Estate Developers and Institutional Investors

In July 2025, the reform to the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI), commonly known as the Anti-Money Laundering Law, was published in Mexico’s Official Gazette. This update seeks to align Mexican regulations with international FATF standards and respond to emerging threats related to money laundering and terrorism financing.

Below is a summary of the main changes that impact participants in the real estate and financial sectors:

1. Lower Threshold for Identifying Beneficial Owners

One of the most significant changes is the reduction of the ownership threshold used to identify a beneficial owner: from 25% to 20%. This means more individuals must be identified and reported as beneficiaries, expanding the scope of corporate transparency.

2. New Thresholds for Vulnerable Activities

The reform adjusts the thresholds—measured in UMAs—for transactions considered vulnerable. For example, in real estate transactions, the new threshold for client identification has been revised, meaning developers and brokers must update their due diligence procedures.

3. Obligations for Virtual Asset Operations

Specific regulations have been introduced for those operating with cryptocurrencies or virtual assets. These include obligations to identify clients, report unusual transactions, and maintain records. Investment funds engaged in fintech or digital models must account for these requirements.

4. Increased Interagency Coordination

The reform strengthens information-sharing mechanisms between the Ministry of Finance (SHCP), the Financial Intelligence Unit (UIF), and tax authorities. This anticipates increased cross-checking between tax compliance and AML enforcement.

5. Higher Penalties and Broader Liabilities

Penalties for non-compliance have been toughened, including larger fines, business closures, and liabilities for legal representatives. Joint liability becomes increasingly important for complex corporate structures.

The 2025 AML Law reform is not just a regulatory update—it is an opportunity to reinforce internal compliance processes, corporate governance, and transparency. For developers, funds, and institutional vehicles, preparation means reviewing ownership structures, contracts, and due diligence protocols.