LFPIORPI and Vulnerable Activities: What They Are and When a Notice Is Due

Mexico's anti-money laundering law outside the financial system, explained: which activities it covers, the thresholds in UMA, and how and when notices are filed.

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The LFPIORPI (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita) is Mexico's anti-money laundering law. Its Article 17 lists the vulnerable activities, such as real estate, jewellery, vehicles, virtual assets and notarial services, whose operations above thresholds set in UMA must be identified and reported to the Ministry of Finance.

The Rules in Brief

The law

Published in the DOF on 17 October 2012 and last reformed on 16 July 2025. It sets which activities are vulnerable, the obligations of whoever carries them out, and the thresholds for identifying clients and filing notices.

The Regulation and the General Rules

The Regulation develops the law and was reformed in the DOF on 27 March 2026, in force the next day. The General Rules of the Ministry of Finance set the detail: how to identify, what to keep and how to report.

The authority

The law gives the powers to the Ministry of Finance (SHCP), which supervises and verifies compliance. Registration and notices go through its anti-money laundering portal, the SPPLD, run by the SAT.

What Counts as a Vulnerable Activity

Article 17 lists the activities and, for most of them, two amounts: from which one the client must be identified, and from which one the operation must be reported. Amounts are in times the daily value of the UMA, the reference unit that replaced the minimum wage.

Fraction	Activity	Identify from	Notice from
I	Games with bets, contests and raffles	325	645
II	Service and credit cards issued outside the financial system (monthly spending)	805	1,285
II	Prepaid cards and stored-value instruments	645	645
III	Traveller's cheques	Not set in Article 17	645
IV	Loans, credits and guarantees offered outside the financial system	Not set in Article 17	1,605
V	Construction, development and intermediation of real estate	Not set in Article 17	8,025
V Bis	Receiving funds for a real estate development for sale or rent	Not set in Article 17	8,025
VI	Precious metals, precious stones, jewellery and watches	805	1,605
VII	Auction or sale of works of art	2,410	4,815
VIII	Sale of new or used land, sea and air vehicles	3,210	6,420
IX	Armouring of vehicles and real estate	2,410	4,815
X	Transport and custody of cash or valuables	Not set in Article 17	3,210, or always when the amount cannot be determined
XI	Independent professional services on behalf of a client (real estate, managing assets or accounts, companies and trusts)	Not set in Article 17	When a financial operation is carried out on behalf of the client
XII	Notaries, public brokers and other holders of public faith	Not set in Article 17	Depends on the act: some are always reported, others from an amount
XIII	Donations received by non-profit associations and companies	1,605	3,210
XIV	Customs agents and agencies, for certain goods	Not set in Article 17	Always, for the goods listed
XV	Leases and other rights to use real estate (monthly value)	Above 1,605	3,210
XVI	Exchange, custody and transfer of virtual assets	Not set in Article 17	210 per client operation, or a fee of 4 or more

Figures copied from Article 17 as reformed in the DOF on 16 July 2025. Where the article sets no separate identification amount, the Regulation and the General Rules say when to identify. Whoever carries out these activities through a trust or any other legal figure is also covered.

How the Thresholds Work

Two amounts, two obligations

Reaching the identification amount obliges you to identify the client and keep the file. Reaching the notice amount also obliges you to report the operation. Below both, the law imposes no obligation for that operation.

Accumulation over six months

Operations below the threshold are not free of risk: if the same person adds up, within six months, an amount above the notice threshold, the operation may be subject to a notice. Since the 2026 reform of the Regulation, the notice is due when the threshold is reached, without waiting for the period to end.

Taxes do not count toward the threshold

Since the 2026 reform of the Regulation, the threshold is measured on the amount without taxes such as VAT. The notice, however, reports the full amount of the operation.

Linked operations in games and raffles

The reformed Regulation defines when a series of operations in games with bets, contests or raffles, digital platforms included, counts as linked: operations within 24 hours that together reach 325 times the daily UMA.

Obligations of Whoever Carries Out a Vulnerable Activity

Article 18 of the law lists them. In summary:

Identify and know the client directly, verify their identity with official documents and keep a copy
In a business relationship, ask for the client's activity or occupation
Identify the beneficial owner of legal entities and trusts, and ask individuals whether one exists
Keep the supporting information and documents for at least ten years
Register in the register of persons carrying out vulnerable activities, through the portal
File the notices and reports with the Ministry of Finance

Carry out a risk-based assessment of the business and of its clients
Keep a manual of internal policies, including the follow-up of politically exposed persons
Train directors, the compliance representative and client-facing staff every year
Have automated monitoring that detects operations outside the client's profile and those that must be accumulated
Have compliance reviewed every calendar year, by internal audit or an independent external auditor depending on risk
Legal entities and trusts: appoint a compliance representative before the Ministry of Finance

When and Where a Notice Is Filed

By day 17 of the following month

Article 23 sets the deadline: no later than day 17 of the month after the operation. The Ministry of Finance's 2026 calendar keeps an administrative facility that moves the date between one and five business days, depending on the sixth digit of the RFC, and it only applies on the exact day that corresponds.

Through the SPPLD portal, as an XML file

Notices go through electronic means and in the official formats published in the DOF: in practice, an XML file per activity uploaded to the SAT's anti-money laundering portal, the SPPLD.

Months without notices: the zero report

A month without reportable operations is not a month without obligations: the calendar of the Ministry of Finance also sets the dates for zero reports.

Suspicion: a notice within 24 hours

If there is suspicion, or facts suggesting that the funds may come from or go to a crime, the law requires a notice within the 24 hours after learning of it, even if the operation was not carried out.

What the 2026 Reform of the Regulation Changed

Published in the DOF on 27 March 2026 and in force since the next day, it aligns the Regulation with the 2025 reform of the law. The article numbers below are those of the Regulation.

Article 6: thresholds are measured without taxes
Article 7: accumulation over up to six months, with the notice due when the threshold is reached
Article 7 Bis: notice of attempted operations that were not concluded, when there is information on who attempted them
Article 12 Bis: an annual compliance audit, internal or external
Article 21 Bis: linked operations in games and raffles within 24 hours, from 325 times the daily UMA
Chapter Six Bis: a regime for politically exposed persons, with a list published by the UIF that is updated within five business days of any change

Several of these points depend on General Rules and formats that the authority publishes separately: check whether each one is already enforceable before relying on it.

The Operation of the LFPIORPI, in COX

Client files with identification and beneficial owner, PEP and restrictive list screening, a documented risk matrix, transactions evaluated against the UMA threshold of each activity, six-month accumulation, and notices exported as XML for the SPPLD, with an immutable trail of every decision. The compliance representative and the decisions stay with your company.

COX for the LFPIORPI The 2026 reform, step by step

Frequently Asked Questions

An economic activity that the LFPIORPI considers exposed to money laundering, listed in its Article 17: among others, games with bets, real estate, jewellery and precious metals, vehicles, works of art, armouring, virtual assets, donations, leases, customs agents and the services of notaries and public brokers.

When the operation, or the sum of operations of the same person within six months, reaches the notice threshold of the activity. It is filed no later than day 17 of the following month. When there is suspicion of illicit origin, within 24 hours, even if the operation did not take place.

In the SAT's anti-money laundering portal, the SPPLD, where you also register as a person carrying out vulnerable activities. Notices are uploaded as XML files in the official format of each activity.

The UMA (Unidad de Medida y Actualización) is the reference unit that Mexican laws use instead of the minimum wage. Its value is updated every year, so the peso amount of each threshold changes too: multiply the number of times by the daily UMA value in force on the date of the operation.

The law says that whoever carries out the vulnerable activity must refrain from the operation, without any liability, when the client refuses to provide the information or documents it requires.

This guide is for informational purposes only and does not constitute legal advice. It summarises the LFPIORPI and its Regulation without replacing them: confirm thresholds, deadlines and formats in the official texts published in the DOF, with the SAT or with a Mexican adviser.

File Every Notice on Time

Thresholds, accumulation and the day 17 deadline, handled from the client file. Start with the files.

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