Mariana Espinosa Ortega
On March 27, 2026, the Decree amending various provisions of the Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicitly Obtained Resources (“Anti-Money Laundering Law”) was published in the Official Gazette of the Federation.
Although it is formally an anti-money laundering reform, its scope reveals something much deeper: a new and reformed oversight model in Mexico, where authorities no longer limit themselves to reviewing isolated documents. They now seek to comprehensively reconstruct transactions and operations.
The regulatory message is clear: it is no longer enough to have contracts, CFDIs, customs declarations, or corporate records. Today, companies must be able to demonstrate that their transactions actually took place, that they have verifiable economic substance, and that they can withstand a comprehensive review by the authorities.
Likewise, on May 14, 2026, the First Resolution of Amendments to the General Foreign Trade Rules for 2026 (“RGCE 2026”) and its Annexes 5, 22, and 29 was published in the Official Gazette of the Federation. Through this resolution, among others, Rules 1.4.14 and 1.5.1 were amended, relating to electronic records, customs value declarations, and documentary evidence in foreign trade operations.
The recent modifications in AML (Anti-Money Laundering) matters and the 2026 RGCE (General Rules of Foreign Trade) share a common regulatory logic: to combat non-existent operations, simulated acts, and structures without real economic substance.
Regarding the PLD 2026 Reform, it significantly strengthened the powers of the SAT and the UIF concerning those carrying out Vulnerable Activities. Among other aspects:
“Materiality” has ceased to be an exclusively fiscal concept and has become a cross-cutting regulatory compliance criterion.
Regarding customs matters, amendments to rules 1.4.14 and 1.5.1 of the RGCE 2026 strengthened obligations related to documentary accreditation of foreign trade operations, requiring sufficient contractual, financial, logistical, and operational evidence to demonstrate the actual destination of the goods and the materiality of the operation.
The authority no longer solely checks if there is an invoice or a contract. It now analyzes: who contracted; who paid; who transported; where the goods were stored; what infrastructure was involved; who executed the production process; and what the actual flow of the operation was.
Another relevant example to analyze is the scope of Article 10 Bis of the Customs Law Regulations, which reiterates the SAT's powers to base its resolutions on CFDI, electronic files, databases, and other digital information available to the authority.
In parallel, Article 81-A of the aforementioned Regulation requires documented and sufficient internal control procedures to preserve and provide evidence related to foreign trade operations.
In other words, audits no longer depend solely on the documentation that the contributor exhibits during an audit. The authority can now reconstruct entire operations from existing digital and documentary traceability.
The trend is clear: compliance is no longer solely documentary; it has become an exercise in comprehensive traceability.
Today, a transaction may appear to be legally sound and yet still give rise to significant risks if there are insufficient elements to support: operational capacity; financial traceability; logistical support; internal controls; or verifiable economic substance.
Among the consequences of not complying with the modifications subject to this document, we have:
This new model particularly affects:
In HG Lawyers We assist companies, developers, trusts, and corporations in reviewing and strengthening their compliance, materiality, and document traceability structures, incorporating perspectives on foreign trade, anti-money laundering (AML), corporate structuring, and preventive mitigation of regulatory risks.
Mariana Espinosa Ortega
Corporate Lawyer at HG Abogados
June 9, 2026
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Mariana Espinosa Ortega
June 9, 2026
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