SAT Steps Up Anti–Money Laundering Oversight: What the 17 “Vulnerable Activities” Mean for Businesses and Professionals
Amid heightened global scrutiny of illicit financial flows—and with a tax system looking to close gaps that enable tax evasion and the use of illegally sourced funds—Mexico’s Tax Administration Service (SAT) intensified its training and support efforts throughout 2025 for sectors legally classified as “vulnerable activities.” The tax authority reported that, since June, it has held virtual and in-person meetings with regulated parties—such as betting establishments, notaries, accountants, real estate firms, and vehicle dealers—to strengthen compliance with anti–money laundering (AML) obligations.
The legal framework is the Federal Law for the Prevention and Identification of Transactions Involving Illicitly Sourced Funds (LFPIORPI), which requires certain lines of business to identify customers, collect information on the beneficial owner, retain documentation, and file notices when transactions exceed thresholds or meet risk-based criteria. For Mexico’s economy, the issue is significant: money laundering distorts competition, raises the cost of financing, depresses tax collections, and adds reputational risk for entire industries—especially as the country seeks to attract investment tied to supply-chain realignment (nearshoring) and sustain export momentum.
Authorities classify 17 activities as vulnerable due to their exposure to cash transactions, asset intermediation, or the ease with which the origin of funds can be concealed. Key examples include: gambling and wagering; contests or raffles; prepaid cards and other value-storage instruments; traveler’s checks; non-financial lending; real estate construction and development, as well as receiving funds for developments intended for sale or lease; the sale and brokerage of precious metals and gemstones, jewelry, and watches; the regular auction or sale of artwork; the purchase/sale or distribution of vehicles (land, sea, or air); armored-vehicle services; the transportation and safeguarding of valuables; the provision of independent professional services; notarial services (public faith); receipt of donations by nonprofit organizations; foreign-trade services provided by customs brokers or authorized customs agents; the creation of rights to use or enjoy real property; and the regular exchange of virtual assets by non-financial entities.
For companies and professionals, the key question is the “how” of compliance. Authorities typically focus on three areas: 1) proper registration and correct operation within reporting portals; 2) strong customer files (identification, business activity or occupation, payment traceability, and, where applicable, beneficial owner information); and 3) retention and ready availability of documentary evidence for verification visits. In practice, that means strengthening internal processes, training front-desk and back-office staff, and standardizing know-your-customer (KYC) policies—even in businesses that historically operated with minimal controls.
The push comes at a time when digital transactions are gaining ground, but cash still plays a major role in higher-risk segments. Tax and financial authorities have promoted greater financial inclusion and payment traceability; however, industries such as real estate, car sales, and jewelry remain sensitive areas. From a macroeconomic perspective, AML supervision also functions as a stability tool: it reduces the likelihood that illicit flows inflate prices (for example, in real estate) and helps improve perceptions of country risk—an important factor for borrowing costs and capital inflows.
Another focal point is the growth of virtual assets. While Mexican regulation distinguishes between financial institutions and non-financial parties, the regular exchange of virtual assets was explicitly added to the list of vulnerable activities when offered by non-financial entities. That brings stricter requirements for user identification and monitoring in a market that has expanded due to technological adoption and the appeal of cross-border transactions. For businesses in the sector, the challenge will be balancing user experience with strong controls, especially for recurring or higher-value transactions.
In the short term, the main impact is operational and cost-related: more controls, more documentation, and greater exposure to penalties if reporting is not handled properly. In the medium term, the potential upside is a more level playing field for formal businesses, as the competitive advantages of operators using opaque funds are reduced. Looking ahead, the message is clear: Mexico is aiming to raise compliance and traceability standards—something that can help sustain the confidence of investors and international counterparties, but that also requires thousands of businesses to professionalize risk management and their engagement with the authorities.
In sum, SAT’s effort to train and oversee the 17 vulnerable activities is intended to reduce opportunities for money laundering and strengthen the integrity of the economic system. The challenge will be ensuring compliance is consistent and proportional to risk, without choking off legitimate business operations; the outcome will depend on the quality of private-sector internal controls and the government’s capacity to supervise and provide guidance.
