In 2026, Mexico’s hotel sector will face intensified anti–money laundering and counter‑terrorist financing (AML/CFT) expectations. The authorities will concentrate supervision on vulnerable activities such as real estate development and leasing, as well as intercompany lending, demanding effective and auditable controls. This will require hotels and chains to strengthen the real‑world effectiveness of their compliance programs.
Mexico’s AML compliance agenda for 2026 will be demanding for hotels, resorts, and hotel chains, particularly with respect to vulnerable activities related to the leasing and development of real property and financing for the construction of hotels or of properties intended for lease or sale.
The Mexican authority expects obligated entities to implement effective and verifiable controls over real estate development transactions, leasing of space (real property), and intercompany loans, which are the highest‑risk activities directly linked to their core business. This is in addition to the obligation to identify and maintain an up‑to‑date file on the ultimate beneficial owner (the “UBO”).
- Hotel real estate development
The development of new hotels or the expansion of existing properties entails money‑laundering and terrorist‑financing risks, as it involves: (a) significant capital flows for development; (b) dealings with multiple intermediaries; and (c) the potential for complex corporate structures that complicate UBO identification.
Under Mexico’s Federal Law for the Prevention and Identification of Transactions with Funds of Illicit Origin (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, LFPIORPI, the “AML Law”), these transactions qualify as a vulnerable activity when acts or transactions are carried out to transfer or establish real rights over real property intended for hotel use. This triggers obligations to identify the customer and the UBO, compile and retain files, preserve information, and, as applicable, submit notices to the authority when relevant thresholds are exceeded.
- Leasing of entire hotels or commercial premises within them
Leasing real property to third parties constitutes another vulnerable activity under the AML Law when the transaction amount exceeds the statutory threshold, regardless of whether the lessee is an affiliate within the same group or an independent third party.
In such cases, the hotel must implement enhanced due diligence where there are complex corporate structures, cross‑border flows, or significant advance payments, and must report transactions that exceed the established thresholds.
The leasing of commercial premises, offices, restaurants, spas, and event spaces is likewise considered a vulnerable activity. Each contract must be analyzed individually for purposes of threshold calculation, customer identification, and, where applicable, submission of notices, and noting that is prohibited to split transactions to evade reporting obligations.
- Intercompany loans
Loans between companies within the hotel group must be assessed within the AML compliance program. While not all intercompany loans are automatically reportable activities, the authority expects documentation of their origin, economic purpose, financial terms, and UBO, particularly where the loans involve international flows, camouflaged capitalizations, or recurring financing.
A lack of traceability and economic substance can trigger scrutiny not only from an AML/CFT perspective, but also from tax and banking regulators.
For Mexico’s hotel sector, the 2026 priority will be to demonstrate the compliance program’s provable effectiveness:
- Effective integration of all vulnerable activities—development, full‑property leasing, third‑party leasing, and intercompany lending—into specific, up‑to‑date risk matrices is essential.
- Robust documentary evidence of due diligence, transactional monitoring, and decision traceability will be required.
- Organizations should maintain documented response capabilities for audits and information requests by the Mexican authority.
- Above all, operational effectiveness should be prioritized over merely formal compliance, aligning compliance with business strategy and expansion.
Additionally, obligated entities are advised to incorporate the identification and mitigation of terrorist‑financing (TF) risks, not only due to the Mexican authority’s agenda and its expectation that obligated entities implement effective, documented, and verifiable controls, but also due to pressure from the United States following its designation, by executive order, of certain Mexican cartels as Foreign Terrorist Organizations (FTOs). This has entailed prohibitions on providing material support or resources to these organizations, empowering the United States to freeze assets, block transactions, and pursue criminal and civil actions against those found to be linked, and has elevated this topic as a priority for the current U.S. administration. In the hotel sector, these risks typically materialize indirectly as a consequence of the absence of a risk‑based approach and insufficient controls to detect opaque corporate structures, interactions with high‑risk organizations, or UBOs who may have direct or indirect ties to persons or entities included on international sanctions lists, including those associated with FTOs.
Moreover, sanctions for AML non‑compliance in Mexico—or becoming involved in a related “scandal”—can have cross‑border effects ranging from reputational damage to restrictions on, or higher costs of, relationships with financial institutions by raising the perceived risk profile, with a potential impact on access to financing and on investment projects.
Hotel chains that implement these measures will be better positioned to operate, obtain financing, and expand sustainably within an increasingly scrutinized and complex regulatory environment in Mexico.
