🇲🇽 Mexico: new rules strengthen the risk-based approach to combating money laundering
🇲🇽 Mexico: new rules strengthen the risk-based approach to combating money laundering
New provisions have been issued to clarify and further develop the obligations established under the Federal Law for the Prevention and Identification of Transactions with Resources of Illicit Origin (LFPIORPI), following the recent reform of Mexico’s anti-money laundering framework.
The new approach seeks to move beyond purely bureaucratic controls and place greater emphasis on effective risk management. Agreement 115/2026 was published on August 7 in the Official Gazette of the Federation (DOF), with the aim of establishing uniform criteria for the application of the regulations across the country.
What is it about❓
📌 The central principle is the adoption of a Risk-Based Approach (RBA).
Operators engaged in “vulnerable activities”, a term used under Mexican law, will be required to develop their own risk matrix and establish internal controls based on the risks identified.
Key measures include:
🔹 Enhanced KYC and customer due diligence procedures.
🔹 Individual assessment of each customer’s risk level, taking into account, among other factors, their relationships with gambling platforms.
🔹 Identification of the beneficial owner.
🔹 Reporting of suspicious transactions within 24 hours, where the criteria established by the regulations are met.
📌 What other obligations will operators have to meet❓
The new provisions also strengthen internal prevention and control mechanisms:
🔹 Development of training programs for compliance personnel.
🔹 Conducting annual audits to assess the effectiveness of AML systems. The first results are expected to be submitted in 2028.
📌 Greater transaction monitoring and oversight
The regulations also introduce a more systematic approach to transaction monitoring.
🔹 Based on each customer’s transaction profile, operators will be required to identify potential deviations from their usual behavior and detect potentially unusual patterns.
🔹 Transaction-related records and data must be retained for 10 years, in accordance with the new requirements.
🔹 Supervisory measures must be applied according to the risk level associated with each activity. In practice, this means that sectors considered higher risk, such as gambling, will be subject to stricter controls than activities with lower exposure.
📌 Context: Mexico’s anti-money laundering legislation was enacted in 2013. In 2025, the framework underwent a reform that introduced 5 new obligations, including, among the most significant, the implementation of the RBA. All of this is taking place against a backdrop of continuing deterioration in relations with the United States 🇺🇸 and an increasingly restrictive stance by Mexican authorities toward gambling: in July, 10 online casinos were blocked over alleged links to terrorist financing.
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