On July 16, 2025, a decree was published in the Federal Official Gazette (“DOF”) amending the Federal Law on the Prevention and Identification of Operations Using Illicit Resources (“LFPIORPI”), also known as the Anti-Money Laundering Law, as well as Article 400 Bis of the Federal Criminal Code (“CPF”), which typifies the crime of operations with illicit resources. This amendment includes several changes that result in new duties for individuals.

The following is a summary of the most important aspects:

A. Extension of the concepts “Controlling Beneficiary” and “Politically Exposed Person”. 

• The concept of “Controlling Beneficiary” is now aligned with the terms “ultimate beneficial owner” and “actual owner”, expanding the assumptions in which information must be collected to identify it.
• The percentage of shareholding to be considered control over a legal entity is reduced from 50% to 25%.

In addition, a chapter is added that provides obligations for commercial corporations:

• To comply with the requirements of the authorities to identify the Controlling Beneficiary and keep the supporting documentation.
• To file notices in the electronic system of the Ministry of Economy corresponding to the transfer or constitution of rights of any nature over shares or equity interests, including the information that identifies the Controlling Beneficiaries.

The definition of Politically Exposed Person is added, and the obligation to identify them and monitor their operations through internal policy manuals and automated mechanisms is imposed.

B. New regime of obligations for those who carry out Vulnerable Activities.

Among the main changes, the following stand out:

• In addition to identifying customers, it is now required to know them directly, verifying their identity by means of identification documents and keeping copies of these; in the case of legal entities, their Controlling Beneficiary must also be identified.
• To obtain a statement from the individual client on the existence of a Controlling Beneficiary and, if applicable, the corresponding documentation.
• Keep for 10 years (previously it was for 5 years) the supporting documentation of the Vulnerable Activities, including commercial correspondence and customer identification information.
• Enroll in the Register of persons performing Vulnerable Activities.
• Submit, in addition to the regular notices, a new notice when there is a suspicion or evidence that the resources could come from or be destined to the commission of the crime provided in Article 400 Bis of the CPF. This notice must be submitted within 24 hours after the suspicion arises, even if the operation is not carried out.
• Prepare of a manual of internal policies, monitoring operations with Politically Exposed Persons, adopting annual training programs and having automated systems for monitoring operations with clients.

Corporate groups shall implement internal policies applicable to all branches and subsidiaries, including foreign entities, to prevent operations with resources of illicit origin.

C. Sanctions, collaboration between authorities and final considerations.

• Collaboration between the Ministry of Finance and Public Credit (“SHCP”), the Ministry of Security and Citizen Protection (“SSPC”) and the National Guard is strengthened.
• The supervisory powers of the Financial Intelligence Unit (“UIF”) and other authorities are expanded, such as those of the Public Prosecutor’s Office, which will now be able to investigate, at any time, conduct involving the use of services provided by the financial system.

The amendment became effective the day after its publication in the DOF; however, the SHCP and the Tax Administration Service (“SAT”) must issue general rules in the next 12 months to develop and specify various obligations, as well as to define their deadlines. Therefore, the application of the reform will be progressive as the secondary legislation is published.

Any questions or doubts regarding this bulletin should be directed to:

Maximiliano Sánchez
msc@cmgdlaw.com