Anti-Laundering Law Reform (LFPIORPI) 2025: A direct wake-up call to the real estate sector

A few days ago, the reform to the Federal Law for the Prevention and Identification of Transactions with Illicit Resources (LFPIORPI), also known as the Anti-Laundering Law, came into force, which radically modifies the rules of the game for real estate developers and builders, brokers, trustees and investment funds with operations in Mexico.

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The reform modifies and adds as a “vulnerable activity” in its article 17:

V. The regular or professional performance of construction activities, real estate development or brokerage in transactions for the purchase or sale of real estate.

V Bis. The receipt of resources destined for real estate development for the purpose of sale or rent.

Both cases require filing a Notice with the Ministry of Finance and Public Credit when the amount of the act or transaction exceeds 8,025 times the daily value of the UMA (approx. $907,000 MXN in 2025).

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What Many Are Ignoring

The 8,025 UMAs threshold is not a “high barrier”. Any down payment for a midsize apartment, or the first resource transferred to a housing development trust, can activate this obligation.

In addition, it is not only the amount that is relevant. It's the nature of the operation and the habit. This affects:

• To developers who receive payments from pre-orders,

• To trustees who manage resources for development,

• To brokers or advisors who usually broker transactions,

• To foreign companies that participate as real estate investors in Mexico.

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This is not an additional procedure: it is an obligation

Failure to comply with these obligations may result in:

• Freezing of accounts or movements by the FIU,

• High economic sanctions,

• Suspension of real estate transactions due to compliance issues,

• Reputational risks to partners, banks and investment funds.

But beyond punishment, there is a clear focus behind the reform: Pressure the formalization of the real estate sector and monitor the origin of the resources that enter the financial system through urban development.

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Why this matters beyond compliance

Here it's not just a matter of “complying by obligation”, but of understanding how this reform fits into a wider context:

• Projects with a trust structure, co-investment or institutional funding are under increased scrutiny. This can directly affect the speed with which resources can be executed.

• Funds and banks are already adjusting their risk matrices, which means that a project without clear compliance may simply be unfunded.

• This reform introduces a new legal “due diligence” for real estate transactions: it is not enough to review titles or licenses. It is now essential to map beneficiaries, flow contracts and tenure structures.

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What should a developer, builder or investor do today?

• Review pledge, investment and purchase contracts to identify when the warning obligation is triggered.

• Implement internal PLD (Money Laundering Prevention) policies if your trade falls within the threshold.

• Empower your legal, accounting and sales teams: this is not just a matter for outside counsel.

• If you are a trustee or manage third-party resources, your obligation is immediate.

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This reform is an invitation to professionalize the real estate operation from the root, with a vision of prevention and not just reaction. At Singular Law, we work with our clients to legally protect their developments from day one.

📩 If you regularly operate, fund, develop or market real estate: more than a recommendation, this is an operational need. Let's talk.

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