Who falls under fracción IV?
The anti-money-laundering law considers a vulnerable activity to be "the habitual or professional offering of mutuo (loan-for-consumption) transactions, or of guarantees, or of the granting of loans or credits, with or without collateral, by parties other than Financial Entities" (LFPIORPI art. 17, fracc. IV). The key words are habitual or professional: an isolated loan to a family member does not make you an obligated party; an operation that is recurring, organized, or offered to the market does — whether you are an individual, an S.A., an S.A.P.I., or the "lender to the trade".
The paragraph was amended on July 16, 2025, as part of the package that tightened the anti-money-laundering regime; if you are reading guides published before that date, check them against the text now in force.
The three obligations (and their 2026 figures)
- Registration and enrollment in the vulnerable-activities registry kept by the SAT — Mexico's tax authority — through its PLD (anti-money-laundering) portal, before you start operating as one.
- Identify the client in every transaction of the activity: a file with official ID, address, and — where one exists — the beneficial owner (art. 18). No threshold: identification is always required.
- Monthly report to the SAT/UIF — the Financial Intelligence Unit — for transactions that reach 1,605 times the daily UMA (Mexico's inflation-indexed reference unit): with the 2026 UMA of $117.31 (INEGI, effective February 1, 2026), the threshold is $188,282.55. Reports are due no later than the 17th of the following month.
On top of that: retain the documentation (10 years), train staff and appoint a compliance officer where applicable, and be careful with cash: art. 32 prohibits settling transactions such as real estate (≥ 8,025 UMA) or vehicles, jewelry, and shares (≥ 3,210 UMA) in cash. Loans are not on that list — but sound private-credit practice is 100% bank transfer, which also gives you an evidentiary trail.
What happens if you don't comply
LFPIORPI fines are assessed per omitted transaction and in UMA — ranges run from hundreds to tens of thousands of UMA depending on the violation, and repeat offenses carry heavier penalties. Worse still: a lending scheme with no identification and no reports looks, in the authorities' eyes, like a laundering machine — exactly the suspicion a legitimate lender cannot afford.
The upside: compliance is an asset
The PLD file the law requires is almost the same file that serious lending already asks for: identification, source of funds, purpose, a contract with fecha cierta (certain date). Complying with the LFPIORPI does not duplicate your work — it formalizes it. And to investors, banks, and loan-portfolio buyers, an originator with its PLD in order is worth more than a "nimble" one that cannot withstand a verification visit. At Tunton, that standard is part of the method.