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Beneficial Owner: what it is and how to identify it.

The Beneficial Owner is the individual who, ultimately, benefits from or controls your client. Identifying it is a core piece of AML compliance — and the 2025 reform strengthened it.

Art. 3, sec. III LFPIORPI · DOF, Jul 16 2025 Informational · not legal advice

What is the Beneficial Owner?

Under the LFPIORPI, the Beneficial Owner is the individual (or group of individuals) who, through a Client or User, ultimately obtains the benefit —enjoyment, use, exploitation or disposal— derived from an act or operation, or who ultimately exercises effective control of the legal entity acting as the client.

For the Law, the Beneficial Owner (Beneficiario Controlador) is equivalent to “ultimate beneficial owner” and “real owner.” In practice, they are the same concept.

Source: LFPIORPI, art. 3, sec. III · DOF, Jul 16 2025.

How is “effective control” determined?

The law states that a person ultimately exercises effective control over a legal entity when, through the ownership of securities, by contract or by any other act, they can —among other scenarios— hold the rights that allow voting over more than 25% of the share capital, in the terms of the applicable general rules.

There are other control scenarios beyond the capital percentage. The exact scope is defined by the Law and the general rules; consult them in the official source.

Source: LFPIORPI, art. 3, sec. III · DOF, Jul 16 2025.

Why it matters in AML

Identifying the Beneficial Owner aims to prevent the real control of an operation from being hidden behind structures or intermediaries. That's why obligated parties must identify it within their client's file.

The 2025 amendment to the Anti-Money Laundering Law strengthened this figure, adding a chapter dedicated to the Beneficial Owner with specific obligations and rules.

Source: LFPIORPI, Chapter IV Bis · DOF, Jul 16 2025.

Read also

Notice: informational content based on official sources (DOF). Not legal advice. To correctly apply Beneficial Owner identification, consult the current text and a specialist.

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