Ultimate beneficial owner: what changed with the 25% threshold and how to build the file
With the AML reform, the equity control threshold dropped from 50% to 25%. How to document ownership chains, how to handle trusts, and how to verify compliance during a SAT inspection.
Identifying the natural person who ultimately owns or controls a business transaction is a cornerstone of AML compliance. Following the July 16, 2025 reform, the legal presumption of corporate control dropped from 50% to 25%, aligning Mexico with FATF international standards.
Definition of Beneficial Owner under Mexican Law
The law defines beneficial owners as individuals who: a) directly or indirectly benefit from transactions, or b) exercise control over a corporate entity through voting rights, contracts, or appointment of executives.
The Tiered Identification Cascade
1) Identify individuals holding 25% or more equity or voting rights. 2) If none reach 25%, identify individuals exercising effective control. 3) If still unidentified, identify the sole administrator or board of directors.
Evidence required in SAT audits
Verifications require corporate ownership charts tracing up to natural persons, certified shareholder registry entries, and official IDs with 10-year retention.
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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