LFPIORPI, Article 17, section I
AML compliance for gaming and raffles in Mexico
Casinos, betting venues and raffle organizers operating under a permit from the Ministry of the Interior (SEGOB), or as decentralized public bodies, must identify the player from 325 UMA and file a notice with the UIF from 645 UMA, both when selling tickets or chips and when paying prizes. SiennaDocs tracks every transaction.
Who is covered?
Article 17, section I of the LFPIORPI treats as a vulnerable activity selling tickets, chips or vouchers for betting games, contests or raffles, paying prizes and any financial transaction with participants, when carried out by decentralized public bodies or under permits from the Ministry of the Interior (SEGOB), from 325 times the daily UMA.
I. Las vinculadas a la práctica de juegos con apuesta, concursos o sorteos que realicen organismos descentralizados conforme a las disposiciones legales aplicables, o se lleven a cabo al amparo de los permisos o autorizaciones vigentes concedidos por la Secretaría de Gobernación bajo el régimen de la Ley Federal de Juegos y Sorteos y su Reglamento. En estos casos, únicamente cuando se lleven a cabo bajo las siguientes modalidades y montos:
La venta de boletos, fichas o cualquier otro tipo de comprobante similar para la práctica de dichos juegos, concursos o sorteos, así como el pago del valor que representen dichos boletos, fichas o recibos o, en general, la entrega o pago de premios y la realización de cualquier operación financiera, ya sea que se lleve a cabo de manera individual o en serie de transacciones vinculadas entre sí en apariencia, con las personas que participen en dichos juegos, concursos o sorteos, siempre que el valor de cualquiera de esas operaciones sea por una cantidad igual o superior al equivalente a trescientas veinticinco veces el valor diario de la UMA.
Serán objeto de Aviso ante la Secretaría las actividades anteriores, cuando el monto del acto u operación sea igual o superior al equivalente a seiscientas cuarenta y cinco veces el valor diario de la UMA;
Key points
- It only applies to betting games, contests or raffles run by decentralized public bodies or under a current permit or authorization from the Ministry of the Interior.
- It applies when the player buys tickets or chips, cashes in chips, receives a prize and in any other financial transaction with them.
- There is a series when you carry out two or more transactions with the same person at your venue or digital platform; it is a vulnerable activity if they add up to 325 UMA or more within 24 hours of the first (Art. 21 Bis of the Regulations).
- If several transactions of the same type with the same player, each of 325 UMA or more, reach or exceed 645 UMA within a period of up to six months, a notice is filed; the notice relates to the transaction that reaches or exceeds the threshold, even if the six months have not elapsed (Art. 7 of the Regulations).
- Paying for tickets or accepting payment for them, and delivering or paying prizes, of 3,210 UMA or more in bills and coins, in pesos or foreign currency, or in precious metals is prohibited (Art. 32, section IV).
Typical businesses
- Casinos
- Sports betting venues
- Online betting platforms
- Raffle organizers
- Lottery operators
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 |
|---|---|---|
| Sale of tickets or chips, prize payouts and transactions with players | ≥ 325 UMA (≈ MX$38,125.75) | ≥ 645 UMA (≈ MX$75,664.95) |
Cash limit · Art. 32, section IV: Ticket purchases and prize payouts. Paying or accepting payment in bills and coins (pesos or foreign currency) or in precious metals is prohibited when the transaction 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 amount must I identify the player?
From 325 UMA (about MX$38,125.75 in 2026) per transaction, or when two or more transactions with the same person add up to 325 UMA or more within 24 hours of the first (Art. 21 Bis of the Regulations).
When is a notice due?
When the transaction is 645 UMA or more (about MX$75,664.95), 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 sale of the ticket, chip or voucher is deemed settled, or the prize is delivered, and the notice threshold has been reached (General Rules, Art. 24 Bis, section I, as amended by Agreement 115/2026).
Can I pay prizes in cash?
Not from 3,210 UMA: Article 32, section IV prohibits delivering or paying prizes of that amount or more in bills and coins, in pesos or foreign currency, or in precious metals, and also paying for or accepting payment for tickets that way.
Other vulnerable activities
- Real estate sales
- Real estate leasing
- Real estate development
- Vehicle sales
- Precious metals and jewelry
- Cash and valuables transport or custody
- Loans and credit
- Armoring
- Donations
- Rebate and rewards cards
- Notaries and public brokers
- Customs brokerage
- Art
- Prepaid cards and vouchers
- Virtual assets
- Service and credit cards
- Professional services
- Traveler's checks