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2026 Changes to Mexico’s Anti-Money Laundering Law

This page will be updated as new information becomes available. Please bookmark it for future reference. Last updated August 26, 2026.

Mexico’s Federal Law for the Prevention and Identification of Transactions with Illicitly Sourced Funds (LFPIORPI) is the country’s primary anti-money laundering law and regulates certain activities considered vulnerable to money laundering, including donations received by nonprofit organizations above specified thresholds.

The new General Rules generally take effect November 30, 2026, with several requirements phased in during 2027 and 2028.

The donation thresholds have not changed, but organizations will face more extensive donor due diligence, including a new 25% beneficial ownership threshold and requirements to assess donors based on risk.

The full General Rules are available through Mexico’s Official Gazette. For additional context, we recommend Baker McKenzie’s analysis of the new requirements.

U.S. foundations are significant donors to Mexican nonprofits having granted nearly $700 million to the country between 2020-2023. We expect that these new rules will have a chilling effect on cross-border giving, especially grants made by U.S. foundations directly to Mexican-registered organizations. These changes may therefore result in the increased usage of specialized intermediary organizations, who would then undertake these enhanced due diligence requirements. If you are looking for advice on potential intermediaries with experience in Mexico that you could engage, please contact engagement@cof.org.

What Funders Need to Know

The reforms do not change the basic donation thresholds, but they significantly expand what organizations must do once Mexico’s anti-money laundering requirements apply. Several changes are particularly relevant to grantmakers.

Donation Thresholds Remain the Same. The 2025 reform did not change the thresholds for donor identification and reporting. In 2026, nonprofits must identify donors for donations of approximately US$10,000 or more and report donations of approximately US$20,000 or more to the Tax Administration Service (SAT). What has changed is the scope of donor information and compliance required.
More Detailed Beneficial Ownership Requirements. The beneficial ownership threshold has been lowered from more than 50% to 25% or more. If no owner meets that threshold, organizations must identify who exercises effective control or, if none, the highest-ranking management official. Grantees may request additional identification from foreign funders. These requirements take effect March 1, 2027.
More Ongoing Donor Monitoring. Organizations will need to monitor donors beyond initial onboarding, including expected transactions and unusual activity. Funders may be asked for additional information about their organizational structure, ownership or control, senior officers, and grant funds.
Handling Sensitive Donor Information. Beneficial ownership documentation may include passports, driver's licenses, addresses, or other sensitive information. The rules require organizations to safeguard this information. Before providing sensitive personal information, funders may want to confirm what documentation is actually required.
Broader Internal Compliance Requirements. Organizations must maintain policies covering donor identification, risk assessment, monitoring, reporting, recordkeeping, training, and audits, with some also required to use automated monitoring systems. For funders, this could mean additional questionnaires and periodic requests to update donor information.
Training and Audits Will Become Part of Compliance. Annual AML training begins in 2027, followed by annual compliance reviews, including external audits for high-risk organizations. The first audit period begins in 2028.

Key Dates to Know

The General Rules take effect November 30, 2026, but several requirements will be phased in over the following two years.

November 30, 2026: General effective date of the new Rules.
March 1, 2027: Major requirements related to beneficial ownership, risk-assessment methodologies, donor risk classification and due diligence, and updated internal policies take effect.
June 1, 2027: Required automated monitoring mechanisms must be implemented.
2027: First annual training period.
2028: First annual compliance audit period.

Funders should expect implementation practices to continue developing as Mexican organizations, legal counsel, and government authorities begin applying the new framework.

AML Requirements That Remain in Effect

The new rules build on the existing AML framework rather than replacing it. Requirements already in place include:

Certain nonprofit donations are considered Vulnerable Activities: Receipt of donations at or above the statutory identification threshold triggers AML obligations regardless of whether the donor itself is a nonprofit entity.
Donor identification and recordkeeping remain required: Organizations must collect and retain required information when applicable thresholds are reached.
Certain donations must be reported to the government: Donations reaching the applicable notice threshold must be reported through the relevant AML reporting system.
Beneficial ownership requirements are expanding: The 2025 reform introduced a 25% ownership threshold, while the 2026 Rules provide more detailed procedures for determining, documenting, and maintaining information about the individuals who ultimately own or control an entity.
Compliance is becoming risk-based: The overall direction of the reforms is away from a primarily transactional reporting system and toward an ongoing preventive framework built around risk assessment, due diligence, monitoring, internal controls, training, and audits.

Further reading on Mexico’s Anti-Money Laundering Rules: