Who falls under fracción IV?
The anti-money-laundering law considers a vulnerable activity to be "the habitual or professional offering of mutuo (loan agreement) operations or of guarantees or of the granting of loans or credit, 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; a recurring, organized transaction offered to the market does — whether you are an individual, an S.A., an S.A.P.I. or the "trade's lender".
The paragraph was amended on July 16, 2025, within the package that tightened the anti-money-laundering regime; if you read guides dated before then, check them against the text in force.
The three obligations (and their 2026 figures)
- Registration and enrollment in the SAT's registry of vulnerable activities (PLD portal), before operating as such.
- Identify the client in every transaction of the activity: a file with official ID, address, and —where it exists— the beneficial owner (art. 18). No threshold: identification is always required.
- Monthly report to the SAT/UIF for transactions that reach 1,605 times the daily UMA: with the 2026 UMA of $117.31 (INEGI, in force 1-feb-2026), the threshold is $188,282.55. Reports are filed no later than the 17th of the following month.
In addition: keep the documentation (10 years), train staff and appoint a compliance officer where applicable, and be careful with cash: art. 32 prohibits settling in cash transactions such as real estate (≥ 8,025 UMA) or vehicles, jewelry and shares (≥ 3,210 UMA). Loans are not on that list — but the sound practice of private credit is 100% transfer, which also gives you evidentiary traceability.
What happens if you don't comply
LFPIORPI fines are counted per omitted transaction and in UMA — the ranges go from hundreds to tens of thousands of UMA depending on the infraction, and repeat offenses make it worse. Worse still: a scheme of loans with no identification or reports looks, to the authority's eye, 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 credit already asks for: identification, source of funds, purpose, a contract with fecha cierta (certain date). Complying with LFPIORPI does not duplicate your work — it formalizes it. And in front of investors, banks and loan-portfolio buyers, an originator with 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.