Mexico tightens AML rules for gaming and sweepstakes: LFPIORPI thresholds, SAT audits, and 2026 cash limits

Mexico’s July 2025 LFPIORPI reforms and the March 2026 changes to its Regulation raise the compliance bar for gaming and sweepstakes operators. For PSPs, acquiring teams, and banks touching this vertical, the practical question is no longer whether the activity is covered, but how quickly a merchant can identify customers, monitor transactions, and survive an SAT review.

1. Gaming with bets, contests, and sweepstakes — both in-person and online — is treated as a Vulnerable Activity under Fracción I of Article 17 of LFPIORPI. The framework is now built around an Enfoque Basado en Riesgos (risk-based approach), supervised by the Servicio de Administración Tributaria (SAT), with stronger internal controls and transaction monitoring.
2. The operational thresholds for 2026 are tied to the Unidad de Medida y Actualización (UMA), whose 2026 value is $117.31 MXN. The identification threshold is 325 UMA or $38,125.75 MXN, which triggers customer identification files (KYC) when selling tickets, chips, or paying prizes. The reporting threshold is 645 UMA or $75,664.95 MXN, which requires an individualized Aviso XML to the SAT/UIF.
3. Cash is capped at 3,210 UMA or $376,565.10 MXN. Above that limit, receiving or paying cash for chips, tickets, or prizes is prohibited. The rule is straightforward on paper and annoying in practice: if a user makes several transactions within a 24-hour period and the total reaches or exceeds 325 UMA, the operator must aggregate them and fully identify the customer, even if each transaction separately stays below the threshold.
4. Corporate operators must appoint a Representante de Cumplimiento with the Secretaría de Hacienda y Crédito Público (SHCP). Their core duties include implementing the risk-based approach, maintaining and updating internal compliance policies, running automated transaction monitoring, identifying Politically Exposed Persons (PEP), obtaining the declaration of the Beneficiario Controlador, and coordinating the mandatory annual audit.
5. The source says SAT verification visits to casinos and sweepstakes operators continue under a defined procedure, but the text provided cuts off before the full process is described. For payment providers, that is still enough to note one thing: this is not a paper-only compliance regime. If the merchant cannot show customer files, transaction aggregation, monitoring, and audit readiness, the SAT review becomes a payments problem fast.