LFPIORPI, Article 17, section VII

AML compliance for the art market in Mexico

Galleries, auction houses and art dealers that auction or sell artwork on a regular or professional basis must identify the client from 2,410 UMA and file a notice with the UIF from 4,815 UMA. SiennaDocs keeps the file for every piece sold.

Who is covered?

Article 17, section VII of the LFPIORPI treats as a vulnerable activity the regular or professional auction or sale of artwork, in purchases or sales worth 2,410 times the daily UMA or more.

VII. La subasta o comercialización habitual o profesional de obras de arte, en las que se involucren operaciones de compra o venta de dichos bienes realizadas por actos u operaciones con un valor igual o superior al equivalente a dos mil cuatrocientas diez 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 cuatro mil ochocientas quince veces el valor diario de la UMA;

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

Key points

It applies to both auctions and sales, whether buying or selling.
Paying for works worth 3,210 UMA or more, or accepting payment for them, in bills and coins, in pesos or foreign currency, or in precious metals is prohibited, in one or several installments and even through a financial institution; consigning that payment in cash or precious metals is also prohibited (Art. 32, sections III and VIII).
Customs clearance (import or export) of works of 4,815 UMA or more per item is also a section XIV vulnerable activity, for the customs broker, attorney or agency, or whoever clears them without one.

Typical businesses

Art galleries
Auction houses
Art dealers
Art advisors who buy or sell works

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
Auction, purchase or sale of artwork	≥ 2,410 UMA (≈ MX$282,717.10)	≥ 4,815 UMA (≈ MX$564,847.65)

Cash limit · Art. 32, section III: Transfer of ownership of artwork. 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

Is a gallery covered?

Yes, if it sells artwork on a regular or professional basis and the transaction is 2,410 UMA or more (about MX$282,717.10 in 2026).

From what amount must I file a notice?

When the transaction is 4,815 UMA or more (about MX$564,847.65 in 2026), no later than the 17th of the month after the month in which the transaction took place (Art. 23 of the Act). Also when several transactions of the same type with the same client, each of 2,410 UMA or more, reach or exceed 4,815 UMA within a period of up to six months; 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). From November 30, 2026, the transaction date for the notice is the date on which it is deemed settled and the notice threshold has been reached (General Rules, Art. 24 Bis, section III, as amended by Agreement 115/2026).

Can I accept cash for a work of art?

Not when it is worth 3,210 UMA or more: Article 32, section III prohibits paying for 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).

Other vulnerable activities

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