AML in Mexico, 2023 to 2026: the cost of being unprepared

Anti-money-laundering (AML) prevention is an increasingly important component of risk management for companies operating in Mexico. For financial-system entities and for those who carry out Vulnerable Activities under the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI), compliance cannot be limited to filing reports and notices.

Between 2023 and 2026, this ecosystem has changed in more than volume. The reform to the LFPIORPI, the new General Rules, the amendments to the Amparo Law and the criteria adopted by the Supreme Court of Justice of the Nation have transformed the environment in which both obligated parties and the authorities responsible for preventing and combating transactions with illicit proceeds operate.

This report analyzes that transformation along three dimensions: the size and behavior of the AML ecosystem; the evolution of the actions of the Financial Intelligence Unit (UIF); and the regulatory and judicial changes that alter companies' economic and legal exposure to the risk of non-compliance.

Mexico's anti-money-laundering system comprises two large groups of obligated parties: the entities that make up the financial system, and the individuals and legal entities that carry out Vulnerable Activities.

The universe of Vulnerable Activities has continued to expand. In June 2026, during a webinar for obligated parties, the tax authority (SAT) and the UIF stated that the national registry had reached approximately 218,000 obligated parties registered for Vulnerable Activities.

The size of the system does not depend only on the number of participants. Every year, these parties generate millions of reports and notices that feed the UIF's analysis processes. Figure 01 distinguishes reports from financial-system entities from the notices filed by those who carry out Vulnerable Activities.

During the first half of 2023, the financial system generated approximately 14.2 million reports, a figure that rose to 15.3 million in 2024 and then fell to 13.6 million in 2025. Between January and July 2026, the UIF received 18.3 million reports from the financial system.

In parallel, Vulnerable Activities notices went from 4.1 million in the first half of 2023 to practically 5 million in 2024, reaching 8.5 million in 2025. Between January and July 2026, 7.3 million notices were received.

The data show a system that processes tens of millions of records every year. The observed variations must nevertheless be interpreted with caution. An increase in reports or notices does not necessarily represent an equivalent increase in money-laundering risk, just as a decrease does not necessarily imply a reduction in risk or in supervisory activity.

Although the 2026 figure includes an additional month and therefore does not allow a strictly comparable year-on-year variation to be calculated, the increase in financial-system reports is large enough to be a relevant indicator to monitor.

Receiving information is only the first stage of the process. The UIF structures its functions around a scheme of reception, analysis and dissemination, through which information from obligated parties can be processed, supplemented and used to generate financial-intelligence products and actions within the scope of its powers.

The evolution of criminal complaints, additions to the Blocked Persons List (Lista de Personas Bloqueadas, LPB) and judicial proceedings reveals a dimension distinct from the volume of reports.

In Figure 02, the data do not follow a linear path between 2023 and 2026. During the first half of 2023, the UIF filed 70 criminal complaints involving 727 persons. For the same period of 2024, both variables fell, to 42 complaints and 382 persons. In 2025 they rose again, to 77 complaints against 444 persons. The sharpest change is seen in 2026. Between January and July, the UIF filed 151 complaints against 1,768 persons.

Even allowing for the additional month in the 2026 figure, the differences are significant. The number of complaints practically doubled the figure for the first half of 2025, while the number of persons involved was almost four times higher.

The relationship between the two variables is also telling. The average number of persons involved per complaint was approximately 10.4 in 2023, 9.1 in 2024, 5.8 in 2025 and 11.7 in 2026. The latest available period shows the highest average in the series.

One of the most significant movements is seen in orders related to the LPB. In 2023, the UIF reported 30 blocking orders; 11 were recorded in 2024, and 13 in 2025. For January to June 2026, the figure rose to 187 domestic orders adding persons to the list, in addition to 12 international orders issued by the United Nations Security Council.

The magnitude of the change is considerable: the 187 domestic orders recorded during the first six months of 2026 are more than fourteen times the 13 recorded in the same period of 2025. This indicator is especially relevant to the analysis because it coincides in time with major changes to the legal framework governing financial freezes and the remedies against them.

Amparo suits went from 416 in the first half of 2023 to 551 in the same period of 2024, fell to 431 in the first half of 2025, and reached 750 between January and July 2026.

The remaining indicators reveal changes in the dynamics of these proceedings. In the first half of 2025, 183 final amparo rulings were granted, versus 137 between January and July 2026. Over those same periods, hearings rose from 24 to 175 and administrative-litigation cases from 53 to 102.

Definitive stays fell from 136 in the first half of 2025 to 31 in the same period of 2026, a decrease of approximately 77.2%. This reduction also coincides with the recent, significant transformation of the legal framework governing financial freezes. On its own, the series does not allow the decrease to be attributed to the reform of the Amparo Law or to the Supreme Court's new criteria; the coincidence is nonetheless relevant to understanding the environment in which the remedies currently operate.

The latest available period shows particularly high levels of criminal complaints, persons involved, amparo suits, hearings and additions to the LPB. For companies, AML risk does not depend solely on meeting the obligation to file information. It also depends on the possibility that this information, supplemented with other sources and analyzed by the authority, leads to actions with legal, financial and operational consequences.

The changes observed in the UIF's indicators are taking place within a regulatory and judicial environment that is itself in transformation.

The LFPIORPI was reformed in July 2025. Subsequently, on August 7, 2026, the Ministry of Finance and Public Credit published Acuerdo 115/2026, which amended the General Rules applicable to that Law.

The new framework develops, among other elements, specific chapters on the risk-based approach, risk classification of customers and users, know-your-customer, Politically Exposed Persons, the Controlling Beneficiary, internal policy manuals, prevention mechanisms, training, automated mechanisms and audit.

The transformation matters because it progressively shifts the emphasis from compliance understood exclusively as filing notices toward a system for managing, identifying, assessing and documenting risk.

On April 6, 2026, the Supreme Court sitting en banc resolved cases concerning the inclusion of persons on the Blocked Persons List and upheld the constitutionality of freezes ordered by the UIF in domestically originated investigations.

The criterion is significant because it changes the restrictive understanding that had prevailed in prior years regarding unilateral action by the UIF in cases that did not stem from international requests or commitments.

Under the new understanding, the freeze is conceived as an administrative, preventive measure, not as a final criminal sanction. The action remains subject to subsequent review and to the corresponding remedies; however, judicial control no longer operates under the standard that had previously predominated.

On August 12, 2026, in resolving Suspension Incident Review 1/2026, the Supreme Court reiterated that the UIF may order freezes arising from domestically originated investigations where there are reasonable and sufficient indicia of possible transactions with illicit proceeds.

The Court also held that a freeze does not necessarily require a prior hearing. Subsequent review must verify whether the authority properly grounded and reasoned the measure, had reasonable and sufficient indicia, and whether effective means exist to challenge it.

The new criterion is directly related to the reform to the Amparo Law published on October 16, 2025, which provides that a stay must be denied where it could facilitate the carrying out or continuation of transactions with illicit proceeds, or conduct that harms the financial system.

This substantially changes the economic risk of a freeze. Previously, a stay could allow certain effects of the measure to be temporarily paused while the case continued. Under the new criterion, that possibility is considerably restricted where lifting the freeze could harm the public interest or allow the circulation of funds presumably linked to illicit activities.

The amparo suit does not disappear: it remains possible to challenge the constitutionality and legality of the action on the merits. The difference is economically fundamental: judicial review may take place once the financial harm has already materialized.

The interaction between the preventive regime and the available remedies has consequences that go beyond procedural law. An account freeze can immediately affect liquidity, payroll and supplier payments, performance of contractual obligations, access to financing and operational continuity.

This changes the economics of compliance. The 2025 data themselves give a sense of the economic magnitude these proceedings can reach. Compliance with definitive stays during that year involved releasing frozen funds of 22.9 billion pesos, 127.7 million US dollars and 20.4 thousand euros.

These amounts are neither fines nor losses attributable to non-compliance, but they illustrate the volume of assets that can become tied up in disputes over financial freezes.

From an economic perspective, a company's exposure to AML risk depends not only on the probability of being the subject of an action by the authority, but also on its capacity to absorb the financial and operational consequences that action could generate. Two companies subject to the same measure may face substantially different effects depending on their available liquidity, working-capital structure, access to alternative sources of financing, banking concentration and dependence on certain counterparties.

A temporary restriction on certain funds does not necessarily imply a definitive loss; it can, however, generate opportunity costs, pressure on cash flow and constraints on meeting short-term obligations. The magnitude of the impact will depend both on the measure adopted and on each company's financial and operational structure.

As a conceptual tool, Figure 03 organizes this exposure into five dimensions that allow AML analysis to move from the strictly regulatory sphere to its possible economic effects.

These variables are not meant to replace the risk-assessment methodologies required by the regulatory framework, but to add a complementary economic dimension. Analyzing them helps identify how vulnerable a company's operations would be to an AML-related contingency and, in particular, which mechanisms could reduce the transmission of a legal event into liquidity, financing or operational-continuity problems.

Anti-money-laundering prevention in Mexico is moving from a formal compliance model to comprehensive risk management. The recent reforms develop obligations of identification, assessment, documentation and control. Filing notices is therefore no longer sufficient as a compliance strategy.

The UIF's activity shows a significant intensification in 2026, particularly in criminal complaints, persons involved and domestic additions to the LPB. Reading these indicators requires keeping the differences between periods in mind and recognizing that the volume of information received is not, in itself, equivalent to the level of risk.

For companies, AML risk carries operational and financial consequences. Remedies still exist, but judicial review may come once the economic impact has already materialized. The criteria on domestically originated freezes and the restrictions on stays under certain conditions make prevention more important.

The cost of reacting to a risk that has materialized can be significantly higher than the cost of preventing it. Identifying customers, assessing risks, monitoring transactions, documenting decisions and implementing effective controls should therefore be understood not merely as a regulatory obligation, but as a strategic investment in operational continuity, asset protection and stronger corporate governance.

From this perspective, the economic discussion should not be limited to how much compliance costs, but should extend to how much it could cost not to have a solid preventive structure in place before risks materialize.