Crypto Law Profile

Mexico LFPIORPI Regulation: AML Rules for Vulnerable Activities and Virtual Assets

Mexico’s LFPIORPI regulation operationalizes AML obligations for vulnerable activities, including registration, notices, recordkeeping, SAT/UIF oversight, and procedures affecting virtual-asset services.

Mexico Effective Regulation Sep 1, 2013

At a glance

Jurisdiction Mexico federal AML regulation for vulnerable activities under LFPIORPI.
Status In force; latest reform generally effective Mar. 28, 2026.
Crypto hook Parent law covers certain virtual-asset exchange, custody, storage, and transfer services.
Regulators SHCP, UIF, and SAT administer formats, registration, notices, verification, and sanctions.

Overview

The Regulation of the Federal Law for the Prevention and Identification of Transactions with Resources from Illicit Sources is Mexico’s federal implementing regulation for the LFPIORPI anti-money-laundering regime. The official Spanish title is Reglamento de la Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita. It applies nationally and sets operational rules for vulnerable activities, including registration, notices, information retention, and supervisory procedures administered through the Secretaría de Hacienda y Crédito Público, the Unidad de Inteligencia Financiera, and the Servicio de Administración Tributaria.

For crypto-law tracking, the regulation matters because the parent LFPIORPI treats certain virtual-asset services as vulnerable activities. The current law covers habitual and professional virtual-asset exchange, custody, storage, and transfer services provided through electronic, digital, or similar platforms, including certain operations involving Mexican citizens from another jurisdiction. The regulation supplies the procedural layer that determines how notices, registration, verification, alternative compliance methods, and recordkeeping operate.

Key provisions of the Mexico LFPIORPI Regulation

Administrative scope and authorities

The regulation is designed to establish the bases and provisions needed to observe the LFPIORPI. The 2026 reform states that authority powers under the law and regulation are directed toward collecting useful elements to prevent, investigate, and pursue operations involving illicit-source resources and related criminal financing structures.

The regulation allocates important operational powers across the SHCP, UIF, and SAT. It addresses administrative interpretation, official formats, registers of vulnerable-activity participants, receipt of notices and reports, verification visits, information requests, electronic notices, and sanctions. These provisions make the regulation central to how the AML framework is implemented in practice, even though the parent law defines the primary vulnerable activities and sanctions.

Registration, notices, and records

Those carrying out vulnerable activities must use the SAT registration process and official formats, including electronic registration, updates, or deregistration through the relevant portal. The regulation also addresses how the date and value of acts or operations are determined for notice purposes, how certain transactions are accumulated, and how notices can be required even when an operation has not been completed but suspicious facts or indicators exist.

Recordkeeping is a core operational requirement. The regulation, as reformed in 2026, requires vulnerable-activity participants to retain copies of notices and reports, supporting documentation, and electronic acknowledgments for at least ten years. This is directly relevant to virtual-asset businesses because the parent law requires precise information about virtual-asset transactions involving originators, recipients, and, where applicable, beneficial owners.

Crypto and virtual-asset relevance

Article 17, fraction XVI of the LFPIORPI is the main crypto-facing hook. It covers certain virtual-asset exchange and custody-type services conducted outside the financial-entity perimeter and sets notice thresholds based on UMA values. It also defines virtual assets as electronic representations of value used by the public as a means of payment and transferred only by electronic means, excluding legal tender, foreign currency, and assets denominated in those currencies.

The regulation adds a narrower but important notice-coordination point. Article 31 Bis, added in the 2026 reform, provides that where operations meet both covered virtual-asset notice scenarios under Article 17, fraction XVI, only the notice under subsection (a) must be filed. This rule is procedural, not a separate licensing regime, but it helps define how overlapping virtual-asset notice triggers are handled.

Status and timeline

The original regulation was published in the Diario Oficial de la Federación on Aug. 16, 2013, and generally took effect on Sept. 1, 2013. Mexico’s official PLD legal-framework page lists the original regulation and the March 27, 2026 reform, while noting that compiled texts are only informational and that DOF decrees should be used for application of the rule.

The latest reform decree was published in the DOF on Mar. 27, 2026, and its first transitory article provides that it enters into force the day after publication. As of Jun. 30, 2026, this profile treats the regulation as in force, with editor review recommended for future updates to general rules and official notice formats. The parent 2025 LFPIORPI reform required general rules to be modified within twelve months after that decree entered into force, making mid-July 2026 an important review point.

Key provisions

Purpose and AML object

Establishes operating rules for applying LFPIORPI and collecting information useful to prevent, investigate, and pursue illicit-source transactions.

AML/CFT Sep 1, 2013 Source

Authority roles

Allocates functions to SHCP, UIF, and SAT, including official formats, registers, notices, reports, verification visits, electronic notices, and sanctions.

AML/CFT Mar 28, 2026 Source

Registration and official formats

Requires vulnerable-activity participants to register, update, or deregister through SAT portal processes using information and formats determined by UIF/SHCP.

Licensing & Registration Mar 28, 2026 Source

Notice timing and accumulation

Sets procedural rules for dates, values, transaction accumulation, 24-hour notices, and official notice/report channels.

AML/CFT Mar 28, 2026 Source

Virtual-asset notice coordination

For operations meeting both Article 17, fraction XVI virtual-asset scenarios, Article 31 Bis requires only the subsection (a) notice.

Custody Mar 28, 2026 Source

Recordkeeping and audit trail

Requires copies of notices, reports, support files, and electronic acknowledgments to be retained for at least ten years.

AML/CFT Mar 28, 2026 Source

Risk-based and alternative methods

Provides simplified measures for low-risk vulnerable activities and UIF-recognized alternative means for presenting equivalent notice information.

AML/CFT Mar 28, 2026 Source

PEP list and consultation

Creates procedures for a UIF list of politically exposed persons and consultation mechanisms for regulated parties.

AML/CFT Mar 28, 2026 Source

Timeline

  1. Original regulation published

    DOF published the regulation implementing LFPIORPI.

    Enacted Source
  2. Original regulation in force

    General effective date; UIF/SAT powers began earlier under transitory provisions.

    In force Source
  3. Virtual assets added to LFPIORPI

    Parent law added Article 17, fraction XVI for virtual-asset activity.

    Enacted Source
  4. Virtual-asset activity operative

    SAT portal states the Article 17, fraction XVI addition entered into force on this date.

    In force Source
  5. Parent law reform published

    Reformed virtual-asset scope, UMA notice thresholds, and related AML obligations.

    Enacted Source
  6. Regulation reform published

    DOF published a decree reforming, adding, and repealing regulation provisions.

    Enacted Source
  7. 2026 reform generally in force

    First transitory article states the decree enters into force the day after publication.

    In force Source

Who it affects

Actors

Banco de México, Secretaría de Hacienda y Crédito Público, Servicio de Administración Tributaria, Unidad de Inteligencia Financiera

Asset classes

Crypto assets, Virtual assets

Official sources

Editorial note

ACF import uses the Spanish official title; the English title is descriptive. The effective-date field reflects the original regulation’s general effective date; the status-date field reflects the 2026 reform’s general effective date.

Use official DOF texts for legal application. SAT/PLD compiled materials state that compilations are informational only.