LFPIORPI, Article 17, section V Bis

AML compliance for real estate developments in Mexico

Since the 2025 reform, receiving funds for a real estate development intended for sale or lease is a vulnerable activity in its own right. SiennaDocs identifies whoever provides those funds and prepares your UIF notices.

Who is covered?

Section V Bis, added to Article 17 in July 2025, treats as a vulnerable activity receiving funds intended for a real estate development whose purpose is sale or lease. The Act defines a real estate development as a project to build property or subdivide land intended for sale or lease (Art. 3, section IV Bis).

V Bis. La recepción de recursos que se destinen para llevar a cabo un Desarrollo Inmobiliario cuya finalidad sea su venta o renta.

Serán objeto de Aviso ante la Secretaría cuando el acto u operación sea por una cantidad igual o superior al equivalente a ocho mil veinticinco veces el valor diario de la UMA;

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

Key points

This is a new section: before the 2025 reform it did not exist as a separate activity.
There is no minimum amount for identification: all funds received for the development are a vulnerable activity (Art. 7, third paragraph, of the Regulations).
The regular or professional purchase or sale of the development's units is a section V activity.
The Act sets no cash limit of its own for this section; if property rights over real estate, or rights over shares or equity interests, are created or transferred in exchange for the contribution, the Article 32 limits apply (section I, 8,025 UMA; section VI, 3,210 UMA).

Typical businesses

Housing developers
Subdivision developers
Industrial park developers
Shopping center developers
Mixed-use projects (residential and commercial)

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
Receiving funds for the development	All transactions	≥ 8,025 UMA (≈ MX$941,412.75)

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

What changed with the 2025 reform?

Section V Bis was added: receiving funds for a real estate development intended for sale or lease is now a vulnerable activity, with a UIF notice from 8,025 UMA.

What counts as a real estate development?

A project to build property or subdivide land intended for sale or lease (Art. 3, section IV Bis LFPIORPI).

From what amount must I file a notice?

When the transaction is 8,025 UMA or more (about MX$941,412.75 in 2026), or when several contributions from the same client reach or exceed that amount within a period of up to six months; since there is no identification amount, all of them count toward the total, and the notice relates to the contribution that reaches or exceeds the threshold, even if the six months have not elapsed (Art. 7 of the Regulations). It is due no later than the 17th of the month after the month in which the transaction took place (Art. 23 of the Act). From November 30, 2026, the transaction date for the notice is the date on which the last contribution of the calendar month was received and applied to the development, and you may report that month's transactions for the same development in a single notice, as long as you meet the Article 23 deadline for each contribution (General Rules, Art. 24 Bis, section IV, and Art. 24 Bis 1, third paragraph, as amended by Agreement 115/2026).

Other vulnerable activities

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