SAT Tightens Scrutiny on Private Loans: What’s Changing for People Borrowing Outside the Banking System
Anti–money laundering rules require non-financial lenders to verify customers and report certain transactions, increasing traceability for some loans.
In Mexico, taking out a loan is no longer synonymous with going only to a traditional bank. The market has diversified with Multiple Purpose Financial Companies (SOFOMEs), Savings and Loan Cooperatives (SOCAPs), Popular Financial Institutions (SOFIPOs), payroll-deduction arrangements, and even loans made by private individuals or other non-financial vehicles. In that last group, the Tax Administration Service (SAT) has strengthened oversight criteria under the anti–money laundering framework, which brings higher requirements for identification, documentation, and reporting for those who lend on a regular or professional basis without being a regulated financial institution.
The rationale behind the tighter approach is both financial and fiscal: when credit is originated outside the perimeter of supervised institutions, the government seeks to preserve traceability over the source and use of funds. In an environment where cash remains common in important segments, and where informal schemes tend to grow when bank credit becomes more expensive or more restrictive, control over these transactions becomes a key piece of financial integrity.
Under the criteria applicable to “Vulnerable Activities,” the habitual or professional granting of promissory loans, loans, or credit—secured or unsecured—by parties other than financial institutions is considered susceptible to being used to conceal proceeds from illicit activity. As a result, those carrying out these transactions must register in the SAT’s corresponding system and meet due-diligence obligations: identify the customer, compile customer files and retain them for an extended period, and submit notices when a transaction exceeds certain thresholds.
In practice, this means a “non-financial” lender that operates repeatedly (for example, someone who systematically lends capital within their community, a private trust financing projects, or a company that extends credit to third parties outside its employee base) must formally document the relationship and be ready to report relevant transactions. While the primary compliance burden falls on the lender, there’s an indirect impact on borrowers: more ID requests, greater need to provide supporting documentation, and a clearer paper trail.
The notice requirement is triggered when a transaction is equal to or greater than 1,605 times the daily UMA value. With the UMA set at 117.31 pesos for 2026, the reporting threshold is around 188,282.5 pesos. At that level, authorities expect enough information to reconstruct who is involved, how much is being lent, on what terms, and with what identity documentation—shrinking the room for opaque transactions.
Noncompliance is not minor: penalties can range from tens of thousands of pesos to multimillion-peso amounts, with ranges that escalate depending on severity, repeat offenses, and the complete failure to file notices. In the most serious cases, fines can be comparable to—or even exceed—the value of the transaction, increasing the risk of operating informally for anyone lending systematically.
What it means for consumers in a higher-cost credit environment
For households, this isn’t just about paperwork: it comes amid an environment where the cost of credit has been sensitive to interest-rate levels. Even when monetary policy easing occurs, the pass-through to consumer rates is often slow and uneven, especially for unsecured products. In that setting, many people look for quick alternatives outside banks or regulated institutions, accepting less transparent terms or greater exposure to abuse.
Greater SAT oversight of non-financial lenders tends to increase the formality of certain loans, but it can also have mixed effects: some providers may stop lending to avoid compliance burdens; others may pass administrative costs on to the borrower. For consumers, the practical advice is to distinguish between regulated credit (banks, SOFOMEs, SOCAPs, SOFIPOs) and informal schemes, where the lack of oversight can make disputes, billing clarifications, or renegotiations harder—while also increasing the risk of impersonation or identity theft if documents are handed over without proper safeguards.
There are also important exceptions: certain loans within corporate groups to employees—funded with workers’ resources and intended exclusively for them—as well as some transactions carried out by public trusts involving the Ministry of Finance and Public Credit (SHCP) and the Bank of Mexico (Banxico), may fall outside the notice requirements under the applicable terms. These nuances matter because they help avoid slowing internal financing mechanisms that, when well designed, can offer more affordable rates than informal alternatives.
The macro backdrop: formalization, revenue collection, and financial stability
Beyond regulatory compliance, monitoring non-financial loans ties into broader goals: expanding traceability in the economy, reducing room for cash-based transactions with no audit trail, and improving the quality of financial information. As more sizable credit transactions are documented, authorities gain additional signals about flows and risks, while the formal financial system competes on a more level playing field against opaque schemes.
For the country, the challenge is to balance integrity with access. Mexico has a longstanding lag in financial inclusion compared with peer economies, and part of the growth in consumer credit has occurred through non-bank channels. Anti–money laundering regulation—if implemented clearly and proportionately—can help bring order to the market without choking it; but if it turns into excessive costs for small formal or semi-formal lenders, it could push more activity underground, the opposite of what’s intended.
At the same time, Banxico’s role as an anchor of price stability influences financing costs and the health of consumer loan portfolios. Prolonged periods of high rates tend to increase payment stress and delinquency in vulnerable segments, creating room for informal loans with aggressive terms. In that context, tightening controls on credit outside the regulated system serves as an additional barrier against abusive practices and illicit flows, although it does not replace policies aimed at competition, financial education, and cost transparency.
In short, SAT’s tougher stance on loans made by non-financial parties is meant to increase money traceability and close off avenues for irregular transactions, directly affecting how certain loans are documented. For consumers, the most visible change will be more frequent requests for identification and supporting documents for higher-value transactions; for the market, the challenge will be to formalize without restricting access to legitimate financing in an environment where credit remains sensitive to rates and risk.
