On September 24, 2026, two resolutions were published in the Official Gazette of the Federation (DOF) that amend: (i) the official form for the registration of those engaged in vulnerable activities, and (ii) the official forms for the notices and reports that must be filed by those engaged in vulnerable activities.
Both amendments stem from the modifications to the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (LFPIORPI), published on July 16, 2025; from the amendments to its Regulations, published on March 27, 2026; and from the amendments to the General Rules (RCG), published on August 7, 2026.
The following is a summary of the most relevant changes and the effective dates for each form.
a) The previous form only recognized individuals and legal entities as types of registrable entities. The 2026 version incorporates trusts and other legal entities—such as joint ventures—as new, distinct categories, and includes detailed fields to identify the trust, trustee, delegated trustee, settlers, beneficiaries, and members of other legal entities.
b) In the section on data regarding vulnerable activities, public and private facilitators as defined in the General Law on Alternative Dispute Resolution Mechanisms (MASC) are added as new registrable entities, as well as customs agencies and individuals or legal entities that facilitate the clearance of goods without the involvement of a customs agent or agency.
c) Previously, in the section on vulnerable activities, the “type of public notary” was requested in general terms. The new version specifies two explicit options: notary public and public broker.
d) Those who have already registered under categories that now require clarification (trusts, customs agencies, or entities facilitating customs clearance without a customs agent) must deregister and reapply for registration, clearly identifying the capacity in which they carry out their acts or operations.
The new registration and filing form will take effect, as a general rule, on February 1, 2027. For public and private facilitators, the effective date will be June 1, 2027.
a) In previous versions, the Controlling Beneficiary section (formerly referred to as “beneficial owner”) was generally optional. The 2026 version strengthens this component by making it a mandatory element in various annexes, with specific fields to identify the individual who is the ultimate beneficiary and to indicate the number of legal entities involved before reaching the Controlling Beneficiary.
b) Annex 14-A is created for the filing of reports within 24 hours when there is suspicion or information based on facts or indications that the funds may be linked to crimes involving transactions with funds of illicit origin, even if the act or transaction did not take place.
c) Annex 12-C is created for the submission of reports corresponding to notarial acts performed by public and private notaries — those who participate in alternative dispute resolution mechanisms under the applicable law — in the transfer or creation of real property rights.
d) Article 3 Bis is added, which formally separates the handling of reports without transactions, which must be submitted using Annex 14.
e) A cross-cutting field titled “Aggregate Report” is incorporated into various annexes.
f) Annexes 1 through 16 are comprehensively revised, and Annex A on tariff subheadings is updated in accordance with the Seventh Amendment to the Harmonized System.
The format for notices and reports will take effect on June 1, 2027. As of that date, notices and reports must be filed using the new formats, even if the transactions pertain to a prior period.
Those who have submitted notices using the previous formats and need to file an amended notice may do so using those formats until June 30, 2027, provided they are within the 30-calendar-day period specified in Article 8 of the resolution. As of July 1, 2027, the previous formats will no longer be available on the website.
We recommend that those engaged in vulnerable activities promptly review their onboarding and registration processes, update their systems for generating XML-format reports, and verify that they have the necessary information to identify the Controlling Beneficiary in accordance with the new requirements.
At Mijares, we have extensive experience advising regulated entities on compliance with their anti-money laundering obligations. We are here to answer any questions you may have and assist you in adapting your organization to the new formats.
For any related inquiries, please contact our Compliance team.
Legal Notice: This Client Alert is for informational purposes only and does not constitute legal advice or a formal opinion on any specific matter. The information contained herein reflects a general analysis prepared by our attorneys based on information available at the time of publication. Any reproduction, citation, or reference to this content must be expressly attributed to Mijares and should not be construed as a public statement or comment made by the firm to the media.
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