Mexico's anti-money laundering reform requires every company to identify its beneficial controller
Mexico's reform of its anti-money laundering law (LFPIORPI), published on 16 July 2025, defines the beneficial controller (beneficiario controlador) as the individual who ultimately benefits from or controls a company. All commercial companies must identify their beneficial controllers, and businesses carrying out vulnerable activities must collect that information from clients. The reform also widens the list of vulnerable activities and toughens penalties.
The decree published in the Official Gazette (DOF) on 16 July 2025 amends the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) and article 400 Bis of the Federal Criminal Code.
What changed
- Definition: a beneficial controller is the individual, or group of individuals, who ultimately benefits from an act or transaction, or who exercises effective ultimate control over a legal entity.
- Companies: all commercial companies must identify their beneficial controllers, who must always be individuals.
- Vulnerable activities: businesses carrying out vulnerable activities must collect beneficial controller information about their clients. The list of vulnerable activities is expanded, including real estate development.
- Penalties: heavier administrative and criminal penalties, including for nominees.
- Virtual assets: obligated parties must pass on originator, recipient and beneficial controller details with virtual-asset transfers.
Who is affected
Mexican companies and their boards and company secretaries, and businesses subject to the anti-money laundering regime.
What to do
Keep an up-to-date record of each Mexican company's beneficial controllers with supporting documents. The tax code already requires companies to hold this information for the tax authority (SAT).