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What are vulnerable activities?

By: Karla Valdés


This week in the blog we are going to discuss an issue of concern for the SAT (Mexican Tax Administration Service) and many entrepreneurs, regarding the topic of vulnerable activities (this is a Mexican concept that describes financial activities that present a higher risk for financial crime such as money laundering). Who defines them? What are the obligations surrounding them? These are some of the topics that we will take a look at.


What kinds of activities fall into the “vulnerable” category?

The SAT has defined a series of activities that fall into this category:

  • The purchase and sale of virtual assets that are carried out through digital electronic platforms used to facilitate or carry out the purchase and sale of said assets.
  • The commercialization or habitual distribution of vehicles, new or used, whether for air, sea or land transport.
  • Gambling games, contests and raffles carried out by decentralized organizations.
  • Development of real estate, involving purchase or sale.
  • The commercialization or intermediation of the purchase and sale of metals or precious stones, jewelry, watches, and works of art.
  • Receiving donations from non-profit associations.
  • The issuance or commercialization of prepaid credit cards or non-bank credit, also the commercialization of traveler’s checks by non-financial entities.
  • Public accountants, lawyers, architects and others.


What should these companies do?

According to the Ministry of Finance, as of February 3, 2020, accountants must complete the registration and registration process as a Vulnerable Activity (Actividad Vulnerable) according to SAT law, through the Money Laundering Prevention portal. The SAT has indicated that those who do not register will be sanctioned.

Another obligation for those who carry out Vulnerable Activities, is to submit notices to the Ministry of Finance and Public Credit about the operations that their clients or users carry out for any amount greater than was is established in the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin.

Similar to the requirement to identify activities, notice can be given for some activities simply by carrying them out, while for others there is a time limit to give a warning.

Here are some examples:

  • If your clients make operations with virtual assets that exceed 57,000 pesos, a notice must be presented.
  • If your company is dedicated to armoring cars, you must submit a notice to the SAT when your client’s transaction exceeds 431,000 pesos.
  • If you sell real estate for an amount equal to or greater than 719,000 pesos, you must also present a notice.
  • If you receive donations from non-profit organizations greater than 287,000 pesos, you must inform the SAT.


We hope this blog has been useful, at Miranda Compliance we can support and advise you on the management of vulnerable activities. We are always happy to help your company.



Miranda – Compliance

Karla Valdés Posada



Ernesto Gómez Gallardo