Mexico's new AML rules start Nov. 30, but gambling operators' KYC and risk-grading duties phase in from March 2027

Mexico's amended anti-money-laundering rules take effect on November 30, 2026, but the new customer risk-grading, KYC and beneficial-owner chapters do not start then. The Finance Ministry (SHCP) set the staggered dates in Acuerdo 115/2026, published in the Diario Oficial de la Federación (DOF) on August 7, 2026. The chapters on customer risk grading, customer knowledge and beneficial owners apply to acts and operations from March 1, 2027, and automated monitoring is due by June 1, 2027 (DOF, Acuerdo 115/2026, Transitory Articles 4 and 9).

Gambling is inside the rules. The Acuerdo amends the general rules under the anti-money-laundering law (LFPIORPI), which apply to "Actividades Vulnerables" (vulnerable activities). Its new Article 24 Bis, section I, ties the notice-date rule for Article 17, section I of the law to "games, contests or raffles."

The dates

The Acuerdo's transitory articles set these dates (DOF, Acuerdo 115/2026, Transitory Articles 1 to 11):

Suspicion notices have no fixed date. Under Transitory Article 5, operators may send the new-style notices (Articles 26 Bis, 26 Bis 1 and 26 Bis 2) six months after a UIF resolution amending the official notice formats takes effect. The Acuerdo does not say when that resolution will come.

What the text asks of operators

• Risk re-grading (from March 1, 2027). Operators must re-assess each customer's risk grade at least every six months, more often for higher-risk customers (Article 23 Bis 1).
• Alerts (from March 1, 2027). Operators need an alert system to detect changes in a customer's behaviour or transaction profile (Article 23 Ter 2). For high-risk customers they must ask for more information and monitor more closely (Article 23 Ter 3).
• Suspicion notices (date open, see above). A notice goes to the UIF within 24 hours of an operator recognising unusual behaviour (Article 26 Bis) or learning of facts that could link funds to illicit proceeds (Article 26 Bis 1). It can be filed even if the transaction is below the threshold or was never completed (Article 26 Bis 2).
• Gambling notice date. For games, contests and raffles, the date of the act is when the sale of the ticket, chip or similar voucher is settled or the prize is delivered, once the notice threshold has been reached (Article 24 Bis, section I).
• Audit. An annual audit review is required (Article 42). An internal audit unit can issue it for low- or medium-risk operators (Article 44). High-risk operators, or any operator that chooses to, need an independent external auditor with a relevant degree and at least three years of experience (Article 45).

SEGOB's separate bill

SHCP's rules sit on top of the 1947 Ley Federal de Juegos y Sorteos, which SEGOB administers. On September 3, Interior Secretary Rosa Icela Rodríguez was asked about casinos at President Claudia Sheinbaum's morning press conference. She said SEGOB's internal review was "almost finished," that "we already have a proposal for a law," and that "we still have to put it to the consideration of the Security Cabinet" (Presidency stenographic version, Sept. 3, 2026 press conference, her answer to the casino question). She said industry has also asked for the law to change, and that casino closures and sanctions, which she put at 13 "and others, maybe about 20," came through the Attorney General's office and SHCP's financial intelligence unit over money laundering and tax fraud. AskSpinner found no later official statement or published bill text as of November 12.

A congressional committee rejects an open-data request

On May 13, 2026, PRI deputy Rubén Ignacio Moreira Valdez asked the Permanent Commission to urge SEGOB to publish every current casino permit, the permit holders, and the number of licensed online betting platforms, in open-data format (proposal, Resolutivos Primero to Cuarto). On August 19, the Permanent Commission's Primera Comisión voted to reject it and close the file. Its reasoning: existing transparency law already requires permits to be published, and applying the AML law belongs to SHCP (Primera Comisión dictamen, "Consideraciones" and "Acuerdo, Primero").

SEGOB's permit lists remain the main public record. AskSpinner's Mexico permit guide explains how the permit system works, and its ranking of DGJS-listed permit holders uses the lists SEGOB's gaming directorate has published.