Introduction by Fernando Buenrostro, Legal Counsel of JLL Mexico
In an increasingly interconnected global financial world, cross-border capital flows necessitate equally global supervision and transparency mechanisms. Strategically, Mexico has aligned itself with the highest international standards by publishing a significant reform to the Federal Law for the Prevention and Identification of Operations with Illicitly-Obtained Resources in the Official Gazette of the Federation on July 16, 2025. This reform is not merely a burdensome bureaucratic requirement for the private sector, but rather a formalization of a new pact of credibility for the national economy and an opportunity for the real estate sector, which has historically been vulnerable to money laundering.
Double Impact of the Reform
The reform has a dual impact. Firstly, it introduces a specific vulnerable activity: the receipt of resources for real estate developments intended for sale or rent, with a reporting threshold set at 8,025 UMA (approximately $900,000 pesos). This measure, long-requested by the GAFI (Group of Action on Money Laundering), addresses a weak point by regulating cash flows that, due to their volume and nature, could previously go unnoticed.
Secondly, and perhaps more profoundly, the reform elevates obligations that were previously secondary through general rules or not even contemplated in the anti-money laundering framework to legal requirements. Concepts such as registering vulnerable persons, creating an internal policies manual, and strengthened internal controls cease to be mere administrative directives and become legal mandates. This consolidates a robust and standardized compliance framework, eliminating ambiguities and strengthening the legal architecture against money laundering.
Strategic Perspective vs. Short-term View
While one might argue that regulatory burden increases in the short term, a strategic perspective reveals the opposite. The reform institutionalizes the sector through international standards—independent audits, automated controls, risk-based approach—acting as a shield. It tangibly reduces the risk of a company, unknowingly, becoming entangled in illicit operations and suffering the devastating reputational, financial, and legal consequences.
Global Credibility Passport
This synchronization with GAFI standards is essentially a global credibility passport. For subsidiaries of international companies, it simplifies operations by allowing them to align with corporate policies of their parent companies. For national firms, it elevates their compliance level, making them more attractive to foreign investors and business partners who demand these guarantees.
One of the reform’s most notable successes is its pragmatism. It recognizes that many of these obligations were already common practice for serious and rigorous actors due to their previous establishment in regulatory provisions. Incorporating them into law provides legal certainty without necessarily duplicating efforts for those already operating with integrity and high standards.
Moreover, strengthening the voluntary compliance framework is a crucial legal engineering piece. By clarifying processes and offering benefits for voluntary regularization, it fosters a culture of self-correction and proactive collaboration with authorities, which is more efficient than a purely punitive model.
Implementation and Next Steps
The publication of this reform marks the beginning, not the end. Its proper implementation depends on the issuance of general rules that will detail operational aspects. The call to the sector and vulnerable activities is clear: instead of viewing this as a burden, it should be understood as an investment in legitimacy.
Organizations will subsequently require immediate diagnostics to identify which aspects are already complied with and where efforts should be focused. This is not a race to avoid penalties but an opportunity to comply with regulations, fortify oneself, modernize, and compete in a global market that no longer tolerates opacity. Mexico has taken a firm step towards financial maturity; it is now the real estate sector’s turn to walk with the same determination.
About JLL
For over 200 years, JLL (NYSE: JLL), a world-leading professional services firm specializing in real estate and investment management, has assisted clients in purchasing, developing, occupying, managing, and investing in a wide range of commercial, industrial, hotel, residential, and retail properties. As a Fortune 500 company with annual revenues of $23.4 billion and operations in more than 80 countries worldwide, our over 112,000 employees bring the power of a global platform combined with local expertise. Driven by our purpose to shape the future of real estate for a better world, we help our clients, people, and communities see a brighter way.
For more information regarding this press release or the topics it addresses, please contact:
Carolina Fernández
JLL Mexico | Director of Public Relations and Media
M 55 43 42 91 22
[email protected]
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