What anti-money-laundering obligations do you have if you lend money?

Quick answer

A lender's PLD (AML / anti-money-laundering) duties have two tiers: as a vulnerable activity (LFPIORPI / Mexican Anti-Money-Laundering Law, art. 17-IV) — registration in the SAT registry, identification on every transaction, a report from 1,605 UMA ($188,282.55 in 2026) and a 10-year file —; and, if you put on the SOFOM suit, the full financial-entity regime (LGOAAC / Mexican General Law of Auxiliary Credit Organizations and Activities, art. 95 Bis): manuals, a compliance officer and reports through the CNBV (Mexico's banking regulator). On both tiers the logic is the same: know your customer, document the source of funds and avoid cash.

Tier 1: the lender as a vulnerable activity

Anyone who grants credit habitually or professionally without being a financial entity falls under section IV of art. 17 of the LFPIORPI (text amended in the DOF / Federal Official Gazette, July 16, 2025). Their four operational duties:

  1. Registration in the vulnerable-activities registry (SAT portal) before operating.
  2. Identification on every transaction — no threshold —: official ID, address, occupation, and the mandatory question about the beneficial owner (are you acting on behalf of someone else?) (art. 18).
  3. Monthly report for transactions ≥ 1,605 UMA$188,282.55 with the 2026 UMA ($117.31) —, by the 17th of the following month at the latest, including the aggregation of transactions split up within the same six-month period.
  4. Custody of the file for 10 years and cooperation with the UIF (Mexico's Financial Intelligence Unit) / SAT in inspections.

The cost of ignoring it is counted per transaction and in UMA — and worse than the fine is the reading: a portfolio of loans without identification is, in the eyes of any authority, indistinguishable from a laundering machine.

Tier 2: a SOFOM's PLD

If it operates under a SOFOM registration, the lender exits the vulnerable-activities regime and enters the financial-entity regime (LGOAAC art. 95 Bis and its general-provisions rules): a compliance manual, a certifiable compliance officer, a customer risk matrix, reports of relevant/unusual transactions to the UIF through the CNBV, annual training and an audit. Since the recent reform, even registration with CONDUSEF (Mexico's financial consumer protection agency) requires a favorable technical opinion on the matter — PLD is no longer a follow-up formality: it is the front door.

The golden rules common to both tiers

  • Cash, the bare minimum: art. 32 LFPIORPI prohibits settling in cash real estate (≥ 8,025 UMA), vehicles, jewelry or shares (≥ 3,210 UMA); loans are not on that list, but disbursing and collecting by transfer is the practice that turns your compliance into evidence.
  • Documented source and use of funds: ask where the payment comes from and what the credit is for; keep the answer. The transaction you don't understand is the transaction you don't do.
  • Consistency: amounts in line with the customer's profile. The borrower who pays $2M in one go "from a deal that came through" is a 24-hour report (unusual transactions), not good news.
  • Collateral counts too: taking as pledge jewelry or a property of murky origin contaminates the transaction — KYC reaches the asset and whoever provides it.

Compliance as a competitive advantage

Looked at closely, the PLD file is the same file as good credit analysis: identity, income, source, use, a contract with certain date (fecha cierta). The firm that does it well not only avoids fines: it builds a sellable and fundable portfolio — banks, funds and portfolio buyers audit PLD before returns. At Tunton that standard is part of the method, not an appendix.

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Frequently asked questions
From how many loans am I 'habitual' for LFPIORPI purposes?
The law does not set a number: it speaks of habitual or professional offering. The practical indicators: recurrence, advertising or offering to third parties, an organization set up to lend, charging interest. When in doubt, the cost of registering and identifying is far lower than that of an inspection with per-transaction fines.
What is the difference between the LFPIORPI report and a SOFOM's report?
The vulnerable-activity report is filed by the non-financial lender with the SAT from 1,605 UMA per transaction. A SOFOM reports as a financial entity through the CNBV under art. 95 Bis of the LGOAAC: relevant transactions by threshold, unusual transactions by behavior (24 hours) and internal compliance structures. They are mutually exclusive regimes: you are in one or the other.
Is receiving a loan repayment in cash illegal?
Receiving loan payments in cash is not among the prohibitions of art. 32 (which covers real estate, vehicles, jewelry, shares and the like). But relevant cash forces you to intensify identification and can trigger reports — and it leaves you without the best proof of payment there is: the transfer. Sound private-credit practice is account-to-account, always.