INFORMATIVE NOTE

Date of Publication in the Official Gazette of the Federation: March 27th, 2025 (afternoon edition).

Date of entry into force: March 28, 2026, subject to the exceptions set forth in Transitory Articles: Third (registration and enrollment obligations for parties engaged in certain vulnerable activities until the relevant form is published), Fifth and Sixth (reporting operability contingent upon the updating of forms the infrastructure updates of the Financial Intelligence Unit or UIF and the Tax Administration Service or SAT), and Seventh (the obligation to retain documentation for the period specified in Article 20).

– Who is affected by the Amendment?

Entities and individuals engaged in Vulnerable Activities (including trusts, Politically Exposed Persons (PEPs), Notaries, Commercial Notaries, and facilitators of alternative dispute mechanisms or ADRs).

– Important aspects of the Amendment to be considered:

The Amendment harmonizes the regulatory framework with the 2025 Law amendments, strengthening oversight and tightening the compliance regime. Within the regulatory changes, it is worth mentioning the following:

• The definitions of ‘Reports’, ‘Politically Exposed Persons List’, and ‘Advanced Electronic Signature’ are introduced, among others; furthermore, the concept of ‘Public Officers with Attesting Authority’ is expanded to include public servants vested with attesting authority and facilitators regulated under the General Law on Alternative Dispute Resolution Mechanisms.

• A new 6 (six) month aggregation regime is established to determine if the threshold is reached for the obligated party to file the notice at the time of the operation that exceeds such amount.

• The obligation to file a 24-hour Notice for non-consummated operations is created, mandating the reporting of attempts to perform acts or operations when data identifying the client or user who has performed such attempt is available.

• The 10 (ten) business-day period to respond to or address information requests is maintained, with the possibility of requesting an additional extension of up to 5 (five) business days. However, the application of the procedure provided for in the Federal Administrative Procedure Law is eliminated; therefore, the SAT will impose the penalty directly within a period not exceeding 10 (ten) business days in the event of non-compliance or partial response.

Only 5 (five) business days are granted to rebut observations. Otherwise, the facts will be deemed admitted.

• The SAT may motivate its resolutions using its own databases and those of other authorities, which are presumed true, which shall be presumed as certain, without being obligated to disclose which databases it consulted in the case of information generated by the subject itself.

• The obligation to retain information is extended from 5 (five) to 10 (ten) years, applicable to all acts or operations constituting vulnerable activities in terms of article 17 of the Law, performed as of July 17, 2025.

• The obligation to have an annual internal or external audit report and to evidence before the SAT the remediation of any inconsistency identified in such report is added.

• It is specified that the obligation to file notices and reports persists until the deregistration request is formalized before the SAT, which shall take effect as of its filing date.

• The SAT is empowered to perform verification visits at the tax domicile if the subject is not located at the registration address, in addition to authorizing the use of public force and expedited electronic notifications.

• Chapter Six Bis is implemented, which regulates the electronic inquiry before the UIF to verify whether a client is included in the centralized Politically Exposed Persons (PEP) List.

• A formal self-correction procedure is established through a simple written brief to obtain fine reductions, provided it is carried out prior to the commencement of the authority’s verification faculties and the applicable requirements are met.

• Regarding gambling games and raffles, the linkage of transactions within a 24- hour period is defined for physical or digital operations that total 325 times the UMA; that is approximately $38,125.75 M.N. (Thirty-eight thousand one hundred twenty-five pesos 75/100 Mexican Currency) in 2026.

• Enrollment and Registration for subjects who started activities as of July 17, 2025, must be carried out using the 2013 format, EXCEPT for: (i) facilitators of ADRs, (ii) those acting through trusts or legal arrangements, (iii) customs agencies, and (iv) foreign trade entities, who must wait until the new forms expressly identify them.

• Public Notaries and Commercial Notaries must consider the new thresholds and reporting scenarios established in the Law for all acts performed as of July 17, 2025.

• The operability of the 24-hour Notice and of the notices for the transfer of valuables where no intrinsic value is determined is contingent upon the technical update of the official formats by the UIF.

– Some specific suggestions as a result of the Amendment are:

• Update internal handbooks, policies, and processes, including those related to the new obligations and addressing requests for information, ensuring compliance.
• Organize immediate training on the new obligations and changes in the operability of reports to avoid non-compliance and the risk of fines.
• Obtain and safeguard evidence of the remediation of any audit findings prior to a request, ensuring the materiality of the correction
• Obtain the audit report to comply with the new documentary remediation standard.
• Adjust automated monitoring mechanisms to detect accumulations over 6-month periods and 24-hour alerts for attempted transactions.
• Validate that the activity address matches the tax domicile registered in the RFC to avoid presumptions of non-location and sanctions.
• Review the enrollment status, historical compliance and, if applicable, deregistration in Merger and Acquisition processes to evaluate contingencies.
• Implement the electronic inquiry protocol before the UIF and update identification files with the controlling beneficiary declaration through official documents.
• Retain documents evidencing enrollment, deregistration, and other documentation evidencing compliance with their obligations, as well as keeping the information updated on the SAT portal and other authorities for a 10-year term.

We trust this information is useful. Should you require any assistance or specific advice regarding the matters mentioned above, please do not hesitate to contact us. We will be pleased to support you.