LFPIORPI, Article 17, section XV

AML compliance for property leasing in Mexico

If you lease warehouses, offices, retail space or apartments, the Anti-Money Laundering Act requires you to identify the tenant when monthly rent is above 1,605 UMA and to file a notice with the UIF when it is 3,210 UMA or more. SiennaDocs keeps every tenant file and generates your notices month after month.

Who is covered?

Article 17, section XV of the LFPIORPI treats as a vulnerable activity the creation of personal rights of use or enjoyment over real estate — such as leasing — for a monthly value above 1,605 times the daily UMA, measured on the day payment is made or the obligation is met.

XV. La constitución de derechos personales de uso o goce de bienes inmuebles por un valor mensual superior al equivalente a mil seiscientas cinco veces el valor diario de la UMA, al día en que se realice el pago o se cumpla la obligación.

Serán objeto de Aviso ante la Secretaría las actividades anteriores, cuando el monto del acto u operación mensual sea igual o superior al equivalente a tres mil doscientas diez veces el valor diario de la UMA;

LFPIORPI, Article 17, section XV. Official Spanish text in force; latest amendment to the Act: DOF, July 16, 2025.

Key points

The threshold is the monthly value, that is, the rent for one calendar month, not the total value of the lease; if rent is agreed on another schedule, its monthly equivalent is calculated (Art. 31 of the Regulations).
Identification applies when monthly rent is above 1,605 UMA; the notice, when it is 3,210 UMA or more.
If you carry out the activity through a trust or any other legal arrangement, you are also deemed to carry it out (Art. 17, third-to-last paragraph, of the Act).
No notice is filed if you and the tenant are legal entities in the same business group and all rent was paid through financial system institutions, or there was no flow of funds (General Rules, Art. 27 Bis, section V). The tenant is still identified; if you had no other reportable transactions that month, you state so in the monthly report (General Rules, Art. 25).
From November 30, 2026, if the property is leased by several co-owners, each one complies separately: it uses the total agreed monthly rent as the amount and states in its own notice the rent payment it received (General Rules, Art. 24 Bis 6, as amended by Agreement 115/2026).

Typical businesses

Industrial warehouse lessors
Corporate office lessors
Retail space lessors
Apartment lessors
FIBRAs and real estate trusts
Storage rental companies

Identification and notice thresholds

In multiples of the daily UMA. Peso amounts use the 2026 UMA of MX$117.31.

Case	Identification	Notice to the UIF
Monthly rent	> 1,605 UMA (≈ MX$188,282.55)	≥ 3,210 UMA (≈ MX$376,565.10)

Cash limit · Art. 32, section VII: Use or enjoyment of real estate (monthly rent). Paying or accepting payment in bills and coins (pesos or foreign currency) or in precious metals is prohibited when the monthly rent is worth 3,210 UMA or more (≈ MX$376,565.10) on the day payment is made or the obligation is met, including taxes and other charges, in one or several installments and even when that cash payment is made through a financial institution. The prohibition also applies when a set of transactions is paid and a single person provides the funds to pay them (Art. 32 of the Act; Arts. 6 and 42 of the Regulations). Consigning that payment in cash or precious metals is also prohibited (Art. 32, section VIII).

Source: LFPIORPI (current text, amended in the DOF on July 16, 2025), its Regulations (amended in the DOF on March 27, 2026) and the General Rules. See the full list of vulnerable activities for 2026

Your obligations as an obligated party

Identify the client: Identify and know the client directly, verify their identity with documents or other officially recognized means of identification, and obtain a copy of them. (Art. 18, sec. I)
Business or occupation: Ask for it whenever there is a business relationship. (Art. 18, sec. II)
Beneficial owner: If the client is a legal entity, trust or other legal arrangement, obtain documents or other officially recognized means of identification that identify its beneficial owner. If the client is an individual, obtain their statement on whether or not they know that a beneficial owner exists and, where applicable, the documentation to identify them. (Art. 18, sec. III)
Keep records 10 years: Keep the information on every transaction and the client's identification for at least ten years from the transaction date. (Art. 18, sec. IV)
Registry enrollment: Register in the Registry of Persons Carrying Out Vulnerable Activities through the online portal, and update or cancel your registration when applicable. (Art. 18, sec. IV Bis)
Notices to the UIF: Filed through the SAT portal by the 17th of the following month. If there is suspicion, within 24 hours of it arising or of learning the information on which it is based, even if the transaction did not take place. (Arts. 18, sec. VI and 23)
Nil report: If there were no reportable transactions in the month, you file a report saying so. (General Rules, Art. 25)
Risk-based approach: Assess your own risks and those of your clients. The assessment must be available from March 1, 2027. (Art. 18, sec. VII)
Internal policy manual: Criteria and procedures, including monitoring of politically exposed persons. Today, the General Rules require a policy document 90 days after registration (Art. 37); the manual with the risk methodology, from March 1, 2027. (Art. 18, sec. VIII)
Annual training: Annual training programs for the board or sole administrator, management, the compliance officer and staff who deal directly with clients, plus staff selection processes. First annual training period: 2027. (Art. 18, sec. IX)
Automated monitoring: Detect out-of-profile transactions, aggregate totals over up to six months where applicable and apply enhanced monitoring to politically exposed or high-risk clients. Today, tracking and aggregation (Regulations, Art. 7; General Rules, Art. 19); automated mechanisms by June 1, 2027. (Art. 18, sec. X)
Annual audit: Internal or independent external review; external if your risk is high. First audited year: 2028. (Art. 18, sec. XI)
Compliance representative: Legal entities and those acting through trusts or any other legal arrangement appoint one before the Ministry of Finance and keep the appointment current. Individuals comply personally and directly, unless they file their notices through a collegiate entity (entidad colegiada). (Art. 20)

How SiennaDocs helps

KYC files: One file per client with documents, expiry dates, approvals and audit log.
Document reading: Extracts data from IDs and documents so you don't type it by hand.
Watchlists: Screening against OFAC, the UN, the SAT 69-B and 69-B Bis lists and countries on the FATF lists.
Beneficial owner: Record of who controls each legal entity or trust.
Client risk: Risk-based assessment with a traffic-light score per client.
Thresholds and aggregation: Flags when a transaction, or a six-month total, reaches the threshold.
XML notices: Generates the notice in the official format, ready to file with the UIF through the SAT portal.
Alerts and audit trail: Alerts on expiries and incidents, and traceability of every action.

Frequently asked questions

From what monthly rent am I covered?

You must identify the tenant when monthly rent is above 1,605 UMA (about MX$188,282.55 in 2026). A notice to the UIF is due when monthly rent is 3,210 UMA or more (about MX$376,565.10).

Can I collect rent in cash?

Not when monthly rent is 3,210 UMA or more: Article 32, section VII prohibits paying it or accepting payment for it in bills and coins, in pesos or foreign currency, or in precious metals, even through a financial institution. Consigning that payment in cash or precious metals is also prohibited (section VIII).

When is the notice due?

No later than the 17th of the month after the month in which you received the funds for the reportable monthly rent payment (Art. 23 of the Act and Art. 5, fourth paragraph, of the Regulations).

Other vulnerable activities

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