Risk-based approach: first steps for Mexican reporting entities under the 2027 reform
The 2026 General Rules mandate an EBR risk assessment methodology starting March 1, 2027. What the methodology must contain, the four key factors, and how to begin.
With the 2025–2026 regulatory overhaul (Agreement 115/2026), the Risk-Based Approach (EBR) transitions from an international best practice into a mandatory legal obligation with strict deadlines.
Key Enforcement Milestones
March 1, 2027: Risk assessment methodology, customer classification model, CDD policies, and AML manual ready for SAT inspection. June 1, 2027: Automated monitoring mechanisms. 2027: First annual staff training program. 2028: First annual compliance audit.
The Four Risk Factors
Entities must evaluate four risk factors: 1) Customers (type of legal person, PEP status, country of origin), 2) Products & Services offered, 3) Delivery channels (face-to-face, remote), and 4) Geographic risk zones.
Inherent risk vs. Residual risk
Methodologies must score inherent risk, apply verifiable internal mitigants (KYC, screening, cash caps), and calculate residual risk, with mandatory annual reviews by the compliance officer.
Descarga la Guía Ejecutiva de Cumplimiento LFPIORPI en PDF
Compendio técnico y normativo para blindar las operaciones de tu empresa ante el SAT con las tasas actualizadas de la UMA 2026 ($117.31 MXN).
- Metodología de cumplimiento preventivo
- Umbrales en UMA 2026 y plazos legales
- Directrices oficiales de identificación KYC
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Reviewed by Compliance Officer · BDUnity.
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