Mexico: A Compliance Overview

Background

Mexico has been undergoing a restructuring of its anti-corruption and financial crime framework in 2025, driven by both domestic political commitment and intense pressure from the US government. While this restructuring introduces major changes – such as the expansion of corporate criminal liability and a comprehensive overhaul of anti-money laundering (AML) laws – it is occurring amidst persistent challenges, including a significant drop in international corruption perception rankings and concerns over political interference in judicial and transparency institutions. The key takeaway for transnational companies is the urgent need to re-evaluate compliance protocols given the heightened enforcement risk and the direct alignment of new Mexican regulations with US priorities.

Key Legislative Changes

The Mexican Congress enacted significant amendments to the Federal Law for the Prevention and Identification of Transactions With Illicit Proceeds (LFPIORPI) and the Federal Criminal Code, effective in July 2025, to substantially fortify the nation’s AML regulatory structure. These reforms introduced stricter rules for identifying financial risk and tracking ownership. The definition of politically exposed persons (PEPs) is formally incorporated into the LFPIORPI, requiring the Ministry of Finance (SHCP) to maintain a public list of these individuals. Furthermore, the identification threshold for a company’s ultimate beneficial owner (UBO) has been significantly reduced from 50% to 25% of voting control. Commercial companies are required to register, identify and record all transfers of their UBOs through the Ministry of Economy’s electronic system. The legislation also establishes criminal liability for negligently providing false, altered or unreadable information in reports submitted to the SHCP, which is now formally recognised as a victim of the crime of money laundering, allowing it to actively participate in the criminal process.

These sweeping AML changes introduce substantial compliance burdens and risks for both domestic and transnational entities. New mandates include rigorous reporting and record-keeping requirements, such as ten-year record-keeping, 24-hour reporting notices, and the use of automated reporting systems. The law also enforces compulsory specialised personnel training and mandatory audits. This means that companies must overhaul their AML due diligence and know-your-customer (KYC) processes to meet the reduced UBO threshold and expanded PEP definition, while simultaneously upgrading reporting systems to mitigate the direct criminal liability now associated with negligence.

Mexico enacted a reform to the Amparo Law concerning the freezing of bank accounts. This reform prohibits injunctions (suspensiones) against the Financial Intelligence Unit’s (UIF) ability to freeze suspicious bank accounts. Previously, targeted individuals and entities often utilised the Amparo legal proceeding – a form of constitutional relief – to quickly unfreeze accounts, stalling investigations. By eliminating this avenue for injunctions, the reform significantly strengthens the UIF’s capacity to swiftly and decisively disrupt the financial operations of organised crime and money laundering networks. Companies must therefore ensure that their due diligence and reporting are robust, as the UIF now has greater power to immobilise assets identified as suspicious.

US governmental pressure, particularly from the Trump administration, is a major catalyst for change, compelling Mexico to align its compliance efforts with US priorities related to anti-corruption and drug-trafficking. Key US actions have included designating Mexican cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), and adjusting the application of the Foreign Corrupt Practices Act concerning these cartels, among other priorities.

In late June 2025, US authorities designated three prominent Mexican financial institutions – CIBanco, Intercam Banco and Vector Casa de Bolsa – as “primary money laundering concerns” due to alleged cartel transaction facilitation. This action caused significant market anxiety, leading to institutions divesting assets and to the banks being intervened by the Mexican National Banking and Securities Commission.

The Mexican Congress is poised to approve a significant Anti-Extortion Law that will nationally criminalise the offence of extortion, establishing a consistent, nationwide legal framework to combat this persistent and pervasive crime. This legislative measure aims to standardise the prosecution of extortion across all states, thereby fortifying the tools available to federal and state prosecutors and enhancing the government’s ability to effectively pursue and prosecute organised criminal activities. Companies operating in high-risk zones must reinforce security protocols and strengthen internal controls to address extortion threats as part of their broader anti-corruption and anti-money laundering programmes. This imperative is underscored by the FTO and SDGT designations, which indicate that enhanced due diligence is relevant to prevent regulatory violations and corporate criminal liability.

A decision by the First Chamber of Mexico’s Supreme Court of Justice significantly expanded the scope of corporate criminal liability. The Court ruled a provision of the Criminal Proceedings Code unconstitutional as it had previously restricted corporate liability in each state to a predetermined, “closed catalogue” of offences. This development broadens the legal risk and demands that companies conduct exhaustive, multi-jurisdictional legal risk assessments and ensure that their compliance programmes are designed to mitigate liability for a far wider array of potential state-level criminal offences.

The National Institute for Transparency (INAI) was dismantled, and most of its functions were transferred to a new unit, “Transparency for the People”, within the Ministry of Anti-Corruption and Good Governance (SABG). Critics warn that centralising control over public information access within the SABG compromises the necessary institutional autonomy previously afforded by INAI.

Judicial Reform

Mexico began implementing a judicial reform that will fundamentally alter the structure of its judiciary by requiring all judges to be elected by popular vote. The first elections took place in June 2025. The potential politicisation of the judiciary may create an unpredictable legal environment, requiring companies to conduct rigorous legal risk assessments and to diversify dispute-resolution strategies, including increased reliance on robust internal compliance to avoid litigation.

The anti-corruption campaign is characterised by fundamental institutional shifts, heightened external pressure and expanding legal liability. Companies operating in Mexico must treat compliance as a top operational priority, specifically by:

• reviewing internal controls and AML/UBO compliance programmes against the stringent new LFPIORPI requirements;
• assessing the heightened corporate criminal liability risk resulting from the Supreme Court ruling; and
• monitoring and adjusting to the constant shift in enforcement priorities influenced by US sanctions and designations.