LFPIORPI, Article 17, section XIII

AML compliance for nonprofits receiving donations in Mexico

If your non-profit association or society receives donations of 1,605 UMA or more, you must identify the donor and file a notice with the UIF from 3,210 UMA. SiennaDocs keeps every donor file and generates the notices.

Who is covered?

Article 17, section XIII of the LFPIORPI treats as a vulnerable activity the receipt of donations by non-profit associations and societies, for a value of 1,605 times the daily UMA or more.

XIII. La recepción de donativos, por parte de las Asociaciones y Sociedades sin fines de lucro, por un valor igual o superior al equivalente a mil seiscientas cinco veces el valor diario de la UMA.

Serán objeto de Aviso ante la Secretaría cuando los montos de las donaciones sean por una cantidad igual o superior al equivalente a tres mil doscientas diez veces el valor diario de la UMA;

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

Key points

The obligation lies with whoever receives the donation, not with the donor.
If several donations from the same donor, each of 1,605 UMA or more, reach or exceed 3,210 UMA within a period of up to six months, a notice is filed; the notice relates to the donation that reaches or exceeds the threshold, even if the six months have not elapsed (Art. 7 of the Regulations).
Under the General Rules, non-profit associations and societies also include religious associations and churches, political parties and groups, professional associations and labor unions (Art. 2, section I).

Typical businesses

Civil associations
Foundations
Non-governmental organizations
Non-profit societies

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
Donation received	≥ 1,605 UMA (≈ MX$188,282.55)	≥ 3,210 UMA (≈ MX$376,565.10)

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

Is my civil association covered?

Yes, if it receives donations of 1,605 UMA or more (about MX$188,282.55 in 2026); from that amount, it must identify the donor. From November 30, 2026, only if its corporate purpose is raising or disbursing funds or resources for altruistic purposes or for charitable, religious, cultural, educational or social purposes (General Rules, Art. 2, section I, as amended by Agreement 115/2026).

When is the notice due?

When the donation is 3,210 UMA or more (about MX$376,565.10), 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 donation is received and the notice threshold has been reached (General Rules, Art. 24 Bis, section VIII, as amended by Agreement 115/2026).

Must I identify the donor's beneficial owner?

Yes, when the donor is a legal entity, trust or other legal arrangement (Art. 18, section III LFPIORPI). If the donor is an individual, you collect their statement on whether they know of a beneficial owner and, where applicable, the documents to identify them.

Other vulnerable activities

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