On April 6, 2026, the Plenary of the Supreme Court of Justice of the Nation (SCJN) confirmed the validity of administrative bank account freezing as a preventive measure in money laundering matters. Days earlier, on March 27, the Official Gazette of the Federation published the reform to the Regulations of the Federal Law for the Prevention and Identification of Operations with Illicitly Sourced Funds (LFPIORPI). Both events mark a before and after in anti-money laundering compliance in Mexico.
This article analyzes what changes in practice, what new obligations regulated entities face, and how to prepare for an increasingly demanding regulatory environment.
The Court held that bank account freezing does not constitute a criminal sanction nor does it imply a declaration of guilt. It is, according to the criterion adopted in Unconstitutionality Action 58/2022, a preventive tool to protect the financial system and fulfill Mexico's international commitments regarding the prevention of money laundering and terrorist financing.
In practical terms, this means that the Financial Intelligence Unit (FIU) can promote the inclusion of an individual or legal entity on the Blocked Persons List when sufficient risk elements exist, without the need to obtain prior judicial authorization. From that moment on, financial institutions are obliged to restrict the disposition of funds belonging to that person or entity.
The SCJN clarified that the right to a hearing, the possibility of presenting evidence, and access to means of defense must be guaranteed. In other words, freezing is not an irreversible or automatic measure: the affected party has the right to challenge it and to provide evidence demonstrating the legality of their operations.
However, the practical burden falls on the affected party, who must demonstrate that their resources are not linked to illicit activities, a process that can be lengthy and costly. Therefore, proactive prevention and compliance are more critical than ever.
After more than a decade without significant changes, the amendment to the Regulations published on March 27, 2026 aims to align the secondary regulatory framework with recent amendments to the law, strengthen the powers of the SAT and UIF, and provide greater operational clarity to obligated parties.
The amendment equips the authority with more robust auditing tools: verification visits with broader scope, information requests with 10-business-day deadlines, and the ability to use various sources to support its resolutions. This should be understood in light of the criteria of the SCJN: the authority can not only review in greater depth but also react more immediately to indications of money laundering.
Obligated parties must submit their reports as soon as applicable thresholds are met, without waiting for the end of the period. Furthermore, the 24-hour notice becomes particularly important when there are indications of operations involving illicit funds, even if the transaction is not completed.
In practice, this requires commercial, operational, and compliance areas to have real-time communication, clear internal escalation criteria, and tools to react quickly to risk signals. The electronic channel of the UIF is consolidated as the sole mandatory reporting channel.
The amendment raises the documentation requirements for obligated parties. It establishes the obligation to obtain and retain audit reports, whether internal or external, depending on the risk level associated with the client or the operation. In higher-risk scenarios, the audit must be external.
Additionally, a minimum retention period of 10 years is set for notices, supporting documentation, and acknowledgments, in line with last year's amendment to the LFPIORPI. The full text of the decree can be consulted in the Official Gazette of the Federation.
The reform includes a specific chapter on Politically Exposed Persons (PEPs), aligned with the 40 FATF Recommendations which Mexico has committed to implementing. It also introduces clarifications for vulnerable activities such as real estate transactions, loans, gaming and betting, and establishes new restrictions on the use of cash and other payment methods.
Real estate purchase and sale transactions continue to be one of the vulnerable activities subject to the highest scrutiny. The new documentary and audit obligations require reviewing client identification processes, verification of source of funds, and reporting of relevant transactions. The restriction on cash use becomes stricter.
Institutions that already have compliance systems must adapt their processes to the new reporting deadlines and to the possibility of receiving information requests from the FIU in shorter timeframes. Fintechs and non-bank entities must pay special attention to adapting their AML/CFT programs to the new standards.
This sector faces additional restrictions regarding accepted payment methods and must strengthen its client identification mechanisms, especially for high-value transactions. The inclusion of PEPs as a specific category requires reviewing due diligence protocols in this segment.
Who are obliged entities under the LFPIORPI?
They are individuals or legal entities that carry out activities considered vulnerable by law, such as real estate transactions, vehicle ownership transfers, loans, gaming and betting, trade in jewelry and art, among others. They have obligations to identify clients, submit notices, and retain documentation.
Can my account be blocked without my prior knowledge?
Yes. Administrative blocking can be executed immediately once the UIF includes a person or company on the Blocked Persons List, without prior judicial authorization. However, the SCJN guaranteed the right to a hearing and defense after the blocking.
What happens if I don't submit my notices on time and in the correct format?
Non-compliance can result in administrative sanctions, fines, and even the suspension of operations. Additionally, the omission of reports can be considered a risk indicator that triggers an inspection visit. Consult the reform decree in the DOF to learn about the specific deadlines.
How long must I keep documents related to my notices?
The amendment to the Regulations sets a minimum period of 10 years for retaining notices, supporting documentation, and acknowledgments of receipt, counted from the operation carried out as of July 17, 2025.
What is a Politically Exposed Person (PEP) and why does it matter?
It is any individual who holds or has held high-level public functions. Their involvement in a transaction implies higher risk and requires the application of enhanced due diligence measures, in line with the FATF's 40 Recommendations that govern the international anti-money laundering standard.
The criterion of the SCJN and the amendment to the LFPIORPI Regulations point in the same direction: greater supervision, increased traceability, and higher demands for obligated parties. AML compliance has ceased to be a merely formal exercise and has become a strategic function that requires a comprehensive review of processes, internal controls, and reporting mechanisms.
These changes align with the international standards of the FATF, an organization recognized by Mexico, whose recommendations have guided recent reforms. In this context, specialized advice can be crucial for correctly interpreting new obligations and implementing timely adjustments.
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