In brief
On 27 March 2026, the Federal Executive Branch published the amendment to the Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicitly Sourced Funds (“Regulations”) ( “Amendment”). This Amendment is related to the amendments made to the Federal Law for the Prevention and Identification of Transactions with Illicitly Sourced Funds (“Anti-Money Laundering Law”) in July 2025. The changes in both rules affect the compliance models of those who carry out Vulnerable Activities, increasing operational controls with a risk-based approach.
Among other things, the Amendment develops and strengthens various obligations for individuals and entities that carry out Vulnerable Activities, strengthens the supervisory powers of the authorities (including powers related with the internal and external audits), regulates the use of electronic means, regulates politically exposed persons (PEPs), and establishes alternative compliance mechanisms.
Vulnerable Activities are certain non‑financial business activities and professions expressly identified in the Anti–Money Laundering Law as higher risk and subject to specific compliance obligations.
In more detail
Among other relevant aspects, the Amendment:
- Extends the retention period of information related to notices filed by those that carry out Vulnerable Activities from five to 10 years.
- Updates and expands the operational framework applicable to Vulnerable Activities, providing greater detail on their identification, the filing of notices, and the retention of information.
- Requires conducting and retaining internal or external audits related to anti money laundering prevention.
- Strengthens the authorities’ powers to request information, carry out compliance verifications, and conduct sanctioning proceedings, including powers to review compliance with the internal or external audits obligations.
- Incorporates specific provisions for identifying PEPs, including the use of lists administered by the Financial Intelligence Unit.
- Clarifies when notices must be submitted for the performance of Vulnerable Activities involving aggregated amounts that exceed the thresholds established in the Anti–Money Laundering Law.
- Allows compliance with the Regulations through simplified measures when the persons carrying out the activities are considered low risk.
- Updates key operational concepts and definitions, including those related to advanced electronic signatures, reports, and general administrative rules.
Pending General Administrative Rules (Reglas de Carácter General)
The Amendment provides that several obligations and compliance modalities will be subject to the General Administrative Rules to be issued by the Secretary of the Treasury. These rules have not yet been published. It should be noted that various obligations that were introduced to the Anti-Money Laundering Law in July 2025 will also be regulated in the General Administrative Rules, so it is essential to be attentive to their publication, because their content will be decisive for the practical implementation of the new regulatory framework.
Conclusion
Given these new provisions, we recommend revising and adjusting your internal controls and procedures to ensure timely and full compliance with the Anti–Money Laundering Law and its Regulations. If you would like to assess the impact of these changes, please contact the Baker McKenzie team, who will be pleased to support you with that analysis.