RFC for Foreigners
Most foreign property owners first hear about the RFC when a notary, a bank, or a rental platform asks for
Most real estate agencies, developers, and brokers in Mexico first think about anti-money laundering compliance when SAT schedules a verification visit or a notary requests client information they never collected. By then, the breach already exists. Mexico AML for real estate in 2026 is governed by the LFPIORPI, Mexico’s Federal Anti-Money Laundering Law, amended on July 16, 2025 to tighten obligations and supervision. In a high-value market like Los Cabos, virtually every sale falls within its scope.
A vulnerable activity is one that, by its nature, can be used to introduce illicit funds into the formal economy. Article 17 of the LFPIORPI treats as such, in real estate, the habitual or professional provision of construction or development services, as well as intermediation in the transfer of ownership of property or the creation of rights over it (section V). The 2025 reform added the receipt of funds for a real estate development intended for sale or rent (section V Bis), which directly reaches pre-sales.
The key concept is habitual or professional activity. An individual who occasionally sells their own home does not carry out a vulnerable activity; anyone who builds, develops, markets, or brokers property as part of their business does.
The following are obligated parties, whether individuals or companies:
Notaries have their own obligations at closing, but these do not replace those of the agency or developer. Each party in the transaction is accountable for its own part.
| Type of transaction | 2026 threshold | Notice |
|---|---|---|
| Brokerage of property sales (sec. V) | 8,025 UMA: MXN 941,412.75 | Identification always; notice from the threshold |
| Construction or development of property for sale (sec. V) | 8,025 UMA: MXN 941,412.75 | Identification always; notice from the threshold |
| Receipt of funds for a real estate development (sec. V Bis) | 8,025 UMA: MXN 941,412.75 | Identification always; notice from the threshold |
| Cash payment for property (art. 32) | 8,025 UMA: MXN 941,412.75 | Cash settlement prohibited from the threshold |
| Transaction with signs of illicit origin | Any amount | Notice within 24 hours |
Amounts calculated with the 2026 UMA of MXN 117.31; the threshold is roughly USD 50,000 at current exchange rates. The law also provides for aggregating split transactions that reach the threshold within a six-month period.
Compliance is not limited to filing a notice when a sale exceeds the threshold. It is a permanent system that includes:
An agency that only files notices, without client files, a policy manual, or training, remains exposed.
The LFPIORPI penalty regime is severe and is calculated in UMA, so it updates every year. At 2026 values:
On an MXN 8 million sale, a single omission can cost more than the entire commission on the deal, in addition to any criminal liability that may apply.
In Los Cabos, where a single unit easily exceeds MXN 941,000, real estate AML compliance is not an occasional obligation but part of daily operations. Agencies and developers that build client files, notices, and controls into the first client contact reduce their exposure to a fraction of the cost of a single fine.
Yes, if you habitually or professionally build, develop, or broker property. The law does not distinguish between individuals and companies. If you occasionally sell your own home, you are not carrying out a vulnerable activity.
Monthly, no later than the 17th of the month following the transaction. If there were no reportable transactions that month, a zero report is filed. Transactions with signs of illicit origin are reported within 24 hours.
Omitting a notice carries a fine of 10,000 to 65,000 UMA, MXN 1,173,100 to MXN 7,625,150 in 2026, or 10% to 100% of the transaction value, whichever is greater. Repeat offenses aggravate the penalty.
Yes. Tax Art can handle registration, client files, preparation and filing of notices and zero reports, the policy manual, and training. Legal responsibility remains with the obligated party, which is why a documented process is your best defense.
Is your agency or development compliant with the LFPIORPI? Speak with a specialist before the next verification. Tax Art assesses your compliance, builds client files, and files your monthly notices for real estate agencies, developers, and construction companies in Los Cabos and throughout Mexico. Contact our team to schedule an assessment.
Most foreign property owners first hear about the RFC when a notary, a bank, or a rental platform asks for
Most foreign buyers of Mexican property first think about fideicomiso tax when the closing statement arrives and the trust bank’s
