The Anti-Money Laundering module brings together your customers' files, the operations of each branch, thresholds in UMA, the six-month accumulation and 27 Bis zero filings, and generates the FIU XML already validated against the official schema. And for the SAT inspection visit: a command center, estimated fines, provable accumulation and transaction monitoring.
The reform to the LFPIORPI published in the Official Gazette of the Federation (DOF) is the deepest since the law has existed. Four figures sum it up.
Filings are submitted no later than the 17th of the month following the operation that gives rise to them (art. 23).
The information and documentation supporting each vulnerable activity must be kept for at least ten years, in paper or electronic form (art. 18, sec. IV).
Anyone who holds the vote over more than 25% of the share capital counts as a beneficial owner and must be identified.
A filing that arrives more than thirty days late is no longer penalized as late, but as omitted (art. 53, sec. III).
The reform also introduced a risk-based approach, registration in the Registry of vulnerable activities and the ability to suspend operations with a customer. Compliance stopped being "upload a file once a month": it is proving, with evidence, that you identified, measured and reported.
Own work based on the current text of the LFPIORPI (Chamber of Deputies, last reform published July 16, 2025).
What happens every month in a company with several branches that carries out vulnerable activities.
Each branch sends its Excel its own way, and someone puts them together by hand in the last week before the 17th.
Thresholds are set in multiples of the UMA, the UMA changes every year, and nobody keeps track of the six-month accumulation per person.
One accent, one lowercase letter or a 17-character CURP and the portal rejects the whole file, when there is no time left.
A branch with no operations must also file. It is the easiest omission to commit and the one nobody checks.
Representatives, attorneys-in-fact and beneficial owner scattered across ID copies and emails.
When the inspection visit comes, you have to reconstruct operations from years ago, with the receipt of each filing.
A single branch without a filing for the month is an omission, and omission is the costliest infraction in the law: up to 65,000 times the UMA or 100% of the value of the operation.
Fines are set in multiples of the daily UMA value, and falsehood in a filing is already a crime, even if by carelessness.
| Infraction | Legal basis | Fine | Scale | In pesos (UMA 2026) |
|---|---|---|---|---|
| Omitting filings, or submitting them more than 30 days lateAlso taking part in prohibited cash operations (art. 32) | Art. 54, sec. III | 10,000 – 65,000 UMA | $1.17 – $7.63 Mor 10 – 100% of the value of the act | |
| Beneficial owner of commercial companiesObligations under arts. 33, 33 Bis and 33 Ter | Art. 54, sec. II | 2,000 – 10,000 UMA | $234,620 – $1.17 M | |
| Submitting filings late, within 30 daysArt. 53, sec. III | Art. 54, sec. I | 200 – 2,000 UMA | $23,462 – $234,620 | |
| Filings without the requirements of art. 24Data of the obligated party, the customer, the beneficial owner and the operation | Art. 54, sec. I | 200 – 2,000 UMA | $23,462 – $234,620 | |
| Failing art. 18 obligationsIdentify the customer, their activity and the beneficial owner, keep records for 10 years, register in the Registry | Art. 54, sec. I | 200 – 2,000 UMA | $23,462 – $234,620 | |
| Not responding to requests from the authorityArt. 53, sec. I | Art. 54, sec. I | 200 – 2,000 UMA | $23,462 – $234,620 |
Amounts using the 2026 daily UMA of $117.31 (INEGI, 2026); these are the legal ranges and the authority sets the amount for each case. The fine applies per infraction: ten branches without a filing are ten omissions. Article 55 allows no penalty, one time only, if the situation is spontaneously regularized before the inspection. Bars on a logarithmic scale.
Each activity in article 17 has a threshold to identify the customer and another to file the report. The system stores them in multiples of the UMA and recalculates the peso amounts when the UMA changes.
| Activity | XML code | Identify from | Report from |
|---|---|---|---|
| Real estate leasingArt. 17, sec. XV · per month | ARI | 1,605 UMA · $188,282.55 | 3,210 UMA · $376,565.10 |
| Real estate: construction, development and brokerageArt. 17, sec. V | INM | Always | 8,025 UMA · $941,412.75 |
| Air, sea and land vehiclesArt. 17, sec. VIII | VEH | 3,210 UMA · $376,565.10 | 6,420 UMA · $753,130.20 |
| Precious metals, stones, jewelry and watchesArt. 17, sec. VI | MJR | 805 UMA · $94,434.55 | 1,605 UMA · $188,282.55 |
| Loans, credit and guaranteesArt. 17, sec. IV | MPC | Always | 1,605 UMA · $188,282.55 |
| Donations received by non-profit associationsArt. 17, sec. XIII | DON | 1,605 UMA · $188,282.55 | 3,210 UMA · $376,565.10 |
| Betting games, contests and rafflesArt. 17, sec. I | JYS | 325 UMA · $38,125.75 | 645 UMA · $75,664.95 |
| Service or credit cardsArt. 17, sec. II | TSC | 805 UMA · $94,434.55 | 1,285 UMA · $150,743.35 |
| Prepaid cards, vouchers and couponsArt. 17, sec. II | TPP | 645 UMA · $75,664.95 | 645 UMA · $75,664.95 |
| Reward wallets and cardsArt. 17, sec. II | TDR | 645 UMA · $75,664.95 | 645 UMA · $75,664.95 |
| Independent professional servicesArt. 17, sec. XI · accounts, companies, real estate, outsourcing | SPR | Always | When operating on behalf of the customer |
Amounts using the 2026 daily UMA of $117.31. Thresholds are edited under Catalogs → Business lines and thresholds, and the "Recalculate" button brings them up to date with the current UMA. The system also includes the shielding XML format (BLI).
Screenshots of the platform running with fictitious demo companies and people; RFCs, CURPs and receipt numbers are blurred. Click any of them to see it larger.
The same routine every month, for all branches and all activities.
Register the individual, company or trust, with representatives, attorneys-in-fact and their branches.
The month's filing and its operations, with the form the activity dictates, or by upload from Excel.
Identification threshold, filing threshold, foreign currency and six-month accumulation per person.
One XML per branch, validated against the official XSD; if something fails, you know the line and the reason.
It is uploaded to the SPPLD, the SAT receipt number is recorded and the filing is marked as sent.
The step that costs the most each month, turned into two buttons: preview and generate.
The General Rules of the LFPIORPI (art. 27 Bis) require filing even when there were no reportable operations in the month. The system works out which active branches have no filing for the month and creates theirs in one click:
The identification required by article 18, ready for the filing and for the inspection visit.
Individual, company and trust in the same file, with the data each one carries in the XML.
The system will not generate the filing for a company without its representative, or for a trust without its attorney-in-fact.
Beneficiaries, guarantors and other roles in a filing, and the relationships between persons.
A snapshot of the file at every change: what data the person had when each filing was submitted.
All reports respect the scope of whoever views them and can be exported to CSV.
Almost every system ends at the XML. Here there is also a screen for the compliance officer: it reads what the module already captures, compares it with the current LFPIORPI and leaves the evidence ready for the SAT inspection visit. It does not change the filings, the XML or their validations.
Command center, accumulation, snapshot at a date, monitoring, inspection visit, record and parameters.
With the current UMA and grouped by infraction, as the authority individualizes it: it doesn't count a hundred customers as a hundred fines.
"How were we doing on June 30?" What was filed after that date doesn't count.
It reads, compares and warns. Nothing corrects itself: the decision belongs to the compliance officer.
Appointment of the compliance representative, training, policy manual with its versions, risk assessment and audits, each with its file. Nothing is deleted: a new version closes the previous one.
The daily UMA of each year (2016 to 2026 with its DOF date), thresholds per activity in multiples of the UMA with their section and validity, and each rule with its severity, its fine and when it becomes enforceable.
If the 17th is a non-business day, it falls due on the next business day; and filing on the day assigned by the sixth digit of the RFC also counts as on time, but only that day. Non-business days are entered by you.
"How much did X accumulate between January and June?", "did they have valid identification on March 3?", "where do I have fine risk?" The copilot answers by only reading, and with the same scope as you.
A duplicated person splits their accumulation in two and can leave a filing unsubmitted. This screen finds them, compares them and merges them without rewriting what you already filed.
The same beneficiary or related party added twice, a representative repeated or who already exists as an individual. Legitimate cases appear as informational and do not count as errors.
Who is a beneficiary or representative of several persons at once: what is worth knowing for the real owner.
With a scheduled task and a "Recalculate now" button. Also from the console (aml:duplicates) and with Bastino: "do I have repeated persons?" Bastino only reads: it never merges.
The import from the previous system says what it was silently combining, does not discard repeated persons and, when finished, calculates the report and says how many remained.
The module works on its own, but each link you turn on saves the compliance officer a step. Everything comes switched off until you decide otherwise.
The persons you report are your customers: from the record the customer is created, linked to an existing one or imported, without duplicating by RFC.
When a person is registered or changed, it is automatically checked against sanctions lists and politically exposed persons. See Fisher Comply.
The person's ID and liveness check are read and, only if you mark it, applied to their file.
Internal notice to whoever handles each person when their ID expires, there is a list match or a filing is about to fall due.
What in other systems is a software update, here is a screen.
Professional services, outsourcing, real estate and brokerage from .xlsx templates: a preview of what will be created and the per-row errors before anything is written.
Alert types, ID types, economic activity, business line, countries, currencies and collegiate bodies, editable.
Each year the new UMA is entered and the thresholds are recalculated; what was already filed keeps its own.
The underlying benefit: anti-money laundering compliance stops depending on one person and one rushed week a month, and becomes a process with evidence that any auditor can follow.
Switching systems cannot mean losing ten years of evidence.
Companies, branches, persons, filings, operations and XML from your current system, including SISPRE.
Each migrated filing keeps its number: it is the reference that travels in the XML and the one the FIU returns in its acknowledgments.
Historical XML files are brought in with their content and can be revalidated against the current schema.
Anti-Money Laundering is a module of Fisher Platform: it shares users, roles, the customer record, document storage, email, artificial intelligence and the REST API with the rest of the platform. The obligated company can be a customer of your firm, with its Anti-Money Laundering tab inside the record.
Four steps to reach the next 17th with everything in order.
We show you a complete month-end close with your vulnerable activity: from filing to validated XML.
Based on your obligated companies, branches and activities, and whether you need to migrate your history.
Setting up companies and branches, migration, role permissions and training.
Your first month-end close on the platform, supported by our team.
No. The system generates the XML for each branch and validates it against the official schema; uploading it to the SPPLD portal is done by the obligated party with their e.firma. The receipt number returned by the SAT is then recorded and the filings are marked as sent.
Real estate leasing, real estate and developments, vehicles, metals and jewelry, loans, donations, gaming and raffles, service and credit cards, prepaid cards and vouchers, reward wallets and cards, and professional services, plus the shielding format.
With one click the system creates the no-activity filing (article 27 Bis of the General Rules of the LFPIORPI) for every branch that does not yet have a filing for the month and generates its XML. It can also be scheduled to happen automatically on the 1st of each month.
Each activity has its identification and filing thresholds in multiples of the UMA. Operations of the month that reach the threshold or that are in a currency other than pesos are included in the filing, and the accumulation adds up, per person and branch, the last six months.
Yes. AML Compliance compares filings, operations, submitted XML and files with the current law: a command center with the estimated fine, provable accumulation operation by operation, a snapshot of the file at a past date, and the list of what is usually requested during the visit, with its answer and its CSV.
Yes. Monitoring rebuilds each customer's profile every day and alerts on amounts well above the norm, operations just under the threshold, cash close to the limit, sudden changes in frequency, third parties and list matches. Each alert comes with its explanation and its evidence.
Data quality finds them (same RFC or CURP, RFC with and without homoclave, name with or without accents or with reversed surnames), compares them side by side and merges them without rewriting filings already submitted: the XML and receipt do not change. Everything can be undone and is kept in the person's change history.
Yes. It extended record retention to ten years, strengthened beneficial owner identification, added registration in the Registry of vulnerable activities and toughened the late filing rule: after thirty days it is penalized as an omission. Fines range from 200 to 65,000 times the UMA.
Yes. We migrate companies, branches, persons, filings, operations and XML, keeping the number of each filing, which is the reference that travels in the XML.
We can support the implementation, the migration and the first month-end closes. Legal responsibility for submitting the filings remains with the obligated party.
See it close a full month of your vulnerable activity: filings, thresholds, 27 Bis and validated XML.
The screenshots are from a demo environment with fictitious companies and people; no data corresponds to a real customer, and RFCs, CURPs and receipt numbers are blurred. This page is informational and does not constitute legal advice.