What is a Politically Exposed Person?
In the Mexican framework, the PEP figure is defined by the position: the Ministry of Finance compiles and keeps an updated nominative list of public-servant positions that will be considered politically exposed. If your client's position is on that list, they are a Politically Exposed Person.
Unlike other frameworks, in Mexico a PEP is not determined “by eye”: it is anchored to an official list of positions the authority publishes and maintains.
Source: LFPIORPI, art. 51 Ter · DOF, Jul 16 2025.
Who compiles the list?
The Legislative and Judicial branches, the autonomous constitutional bodies, the agencies and entities of the Federal Public Administration and their counterparts in states and municipalities, the Attorney General's Office and local prosecutors, among others, submit their list of Politically Exposed Persons to the Ministry.
With that information, the FIU (Financial Intelligence Unit) compiles the List of Politically Exposed Persons, under the new chapter of the Regulations.
Source: LFPIORPI, art. 51 Ter · DOF, Jul 16 2025 · Regulations, art. 45 Bis (Ch. Sixth Bis) · DOF, Mar 27 2026.
What if you can't tell whether your client is a PEP?
The law provides a concrete path: if after identifying and verifying the identity of your Client or User you cannot determine whether they are a PEP, you may query the authority —through the electronic means established for that purpose— to check whether they are on the list, and thus continue meeting your obligations.
First you identify your client; only if you cannot resolve whether they are a PEP does the query to the authority apply. The technical procedure is set by the general rules.
Source: LFPIORPI, art. 51 Ter and art. 18, sec. VIII · Regulations, arts. 45 Ter and 45 Quáter · DOF 2025–2026.
Why it matters in AML
Determining whether a client is a PEP is part of knowing who you have in front of you and of your risk-based approach. Together with the beneficial owner, it helps you understand the real risk of a business relationship and document it in the file.
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Notice: informational content based on official sources (DOF). Not legal advice. The list of positions and the query procedure in force are defined by the authority; consult the official source and a specialist.
PLD Central, by CoreWorks, lets you flag and follow up on PEP clients within their file, alongside risk, beneficial owner and evidence — all traceable.