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Secretaría de Gobernación — Dirección General de Juegos y Sorteos — Mexico online-gambling standards explorer (Ley Federal de Juegos y Sorteos of 1947, Reglamento of 17 September 2004, Decreto reformatorio del Reglamento of 23 November 2023 banning slot machines, LFPIORPI of 2012, Ley del IEPS, Código Penal Federal arts. 257-264, and the Sheinbaum-era reform pipeline before the Cámara de Diputados)

All 359 Mexican standards,
organised by theme

A searchable, filterable index of Mexico's federal gambling rulebook, drawn from the Ley Federal de Juegos y Sorteos of 31 December 1947, the Reglamento of 17 September 2004, the 23 November 2023 decree that banned electronic slot machines and triggered the still-running amparo wave, the LFPIORPI (2012) casino-AML regime administered by the SAT and UIF, the IEPS tax stack, and the Sheinbaum-era reform pipeline before the Cámara de Diputados. Standards are grouped by theme, tagged editorially and deep-linkable.

Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
Representative coverage
359 Standards
1133 Requirements
0 Flagged
5 Categories
Showing all 359 standards
1
Theme 1

SEGOB framework & permit regime

Mexico governs gambling under a 1947 framework statute that vests the Federal Executive, through the Secretaría de Gobernación, with the exclusive authority to grant, supervise and revoke gambling permits. The Reglamento of 2004 created the Dirección General de Juegos y Sorteos as the operational regulator, and no superseding federal gambling commission has yet been enacted.

23 standards 11 player-flagged
48%
player-flagged
Regulatory risks this theme addresses
  • Treating any state or municipal authorisation as a substitute for a federal SEGOB permit
  • Operating under a permit granted to a different legal person without SEGOB approval of the assignment
  • Assuming SEGOB powers transfer automatically to a future commission before the relevant statute is published in the DOF
LFJS art. 1

General prohibition with statutory exception

Player Rights

Article 1 of the Ley Federal de Juegos y Sorteos prohibits all games of chance and games with wagers (juegos con apuestas) on Mexican territory, subject only to the exceptions the law itself authorises. The general prohibition is the constitutional anchor on which every Mexican gambling permit ultimately rests.

Requirements
  • Operate only inside an exception expressly authorised by the LFJS or its Reglamento
  • Document the statutory basis for every permitted activity in the compliance file
  • Treat unlicensed offerings as criminally prohibited under arts. 257-264 of the Código Penal Federal
The general prohibition has stood unchanged since the original DOF publication of 31 December 1947.
LFJS art. 2

Permitted games of skill and federally authorised draws

Game Design

Article 2 lists the only activities lawfully exempt from the general prohibition: games of pure skill (ajedrez, dominó, billar and similar), athletic events with wagers, and sorteos (draws) expressly permitted by the Secretaría de Gobernación. Casino games and slot machines are not in the article 2 list — their permissibility derives entirely from interpretation of arts. 3 and 4 by SEGOB through the Reglamento.

Requirements
  • Map every product offering against the article 2 categories
  • Identify games of pure skill versus games of chance for permitting purposes
  • Avoid relying on a skill-game characterisation for a fundamentally chance-based product
The narrow article 2 list has been the principal target of every reform proposal since 2014.
LFJS art. 3

SEGOB as the sole federal regulatory authority

Player Rights

Article 3 vests the Secretaría de Gobernación with exclusive authority to regulate, authorise, control and supervise all games with wagers and draws within the federal territory. No state or municipal authority may issue parallel permits for activities reserved to the federal sphere.

Requirements
  • Apply only to SEGOB for federal gambling permits
  • Disregard purported municipal or state gambling licences for federal-reserve activities
  • Reference article 3 in any preemption defence against local rule-making
The federalisation principle has been reaffirmed by repeated Suprema Corte rulings.
LFJS art. 4

Permits granted, modified and revoked by the Executive

Player Rights

Article 4 confirms that gambling and draw permits are granted, modified and revoked by the Federal Executive acting through SEGOB. Permits are non-transferable without express SEGOB authorisation and may be revoked on the grounds listed in the Reglamento.

Requirements
  • Treat every permit as personal to the named permit holder
  • Request SEGOB authorisation before any change of control or assignment
  • Maintain documentary evidence of every permit modification published in the DOF
LOAPF art. 27

SEGOB powers under the Federal Administrative Organic Law

Article 27 of the Ley Orgánica de la Administración Pública Federal lists the powers of the Secretaría de Gobernación, including the regulation, authorisation, control and supervision of gambling and draws when such activities require federal intervention. This is the organic-law backstop for SEGOB's regulatory perimeter over the sector.

Requirements
  • Cite LOAPF art. 27 alongside LFJS art. 3 when defending SEGOB jurisdiction
  • Recognise the SEGOB perimeter as a federal exclusivity
  • Track any LOAPF reform that would reassign sectoral powers
A reassignment to a future gambling commission would require amendment of LOAPF art. 27 alongside the LFJS.
Reglamento Interior SEGOB art. 32 bis

DGJS as the operational regulator

Player Rights

The Reglamento Interior de la Secretaría de Gobernación designates the Dirección General de Juegos y Sorteos as the operational area responsible for permit administration, technical supervision, inspections and sanction proceedings. The DGJS is the day-to-day counterparty for every permit holder.

Requirements
  • Route permit filings, modifications and quarterly reports to the DGJS
  • Cooperate with DGJS inspectors and produce books and records on request
  • Maintain a designated representative for DGJS notifications
Acuerdo SEGOB DGJS

DGJS internal organisation and powers

The internal SEGOB acuerdos constituting the DGJS detail its sub-directorates: permit administration, inspection and vigilance, technical certification, and legal proceedings. Each sub-directorate is the formal point of contact for the matching compliance workstream.

Requirements
  • Address each filing to the correct DGJS sub-directorate
  • Maintain dedicated compliance liaisons for permits, inspections and tech certification
  • Track DGJS internal reorganisations announced through the DOF
Acuerdo SEGOB DGJS constitutivo

Acuerdo constituting the DGJS

The acuerdo by which the Secretaría de Gobernación constituted the Dirección General de Juegos y Sorteos is the institutional charter of the federal gambling regulator. It defines the DGJS as the area within SEGOB to which the permit-administration, technical-supervision, inspection and sanction functions of the LFJS and its Reglamento are delegated.

Requirements
  • Treat the constitutive acuerdo as the basis for DGJS sub-directorate competence
  • Recognise the DGJS as SEGOB's delegate for every LFJS function
  • Track any reform of the acuerdo that reassigns sub-directorate scope
RLFJS art. 20

Classes of permit recognised by the Reglamento

Game Design

Article 20 of the Reglamento defines the principal permit classes: cross-betting (apuestas remotas / sportsbook), number-draw centres (centros de apuestas y sorteo de números), traditional sorteos (de números, de símbolos, instantáneos, de propaganda comercial and transmitidos por medios de comunicación masiva). Each class carries its own technical, financial and operational obligations.

Requirements
  • Map every product to the correct article 20 permit class
  • Avoid operating activities outside the scope of the granted permit
  • File a permit modification before launching a new permit-class activity
The article 20 typology pre-dates the online channel and is interpretively extended via Reglamento art. 85.
RLFJS art. 22

Permit-holder eligibility and fit-and-proper

Player Rights

Article 22 sets the eligibility conditions for a permit holder: Mexican legal personality, corporate purpose covering the requested activity, evidence of technical and economic capacity, and absence of disqualifying criminal antecedents in the controllers. SEGOB exercises wide discretion in assessing the file.

Requirements
  • Form a Mexican sociedad mercantil before applying
  • Document technical and economic capacity in the permit file
  • Disclose every controlling shareholder, director and ultimate beneficial owner
  • Refresh fit-and-proper evidence on each permit modification
RLFJS art. 27

Permit term and renewal

Permits are granted for terms set in the resolution of grant, typically 25 years for sportsbook and number-draw centres, renewable at SEGOB's discretion subject to compliance history and renewed fit-and-proper review.

Requirements
  • Diary the permit expiry well in advance of renewal
  • Submit renewal files with full compliance history
  • Preserve evidence of continuous compliance to support renewal
The historic granting of 25-year permits to Codere, Caliente, Big Bola and PlayCity has been politically contested by every administration since 2012.
LFJS art. 5

SEGOB supervisory and vigilance functions

Player Rights

Article 5 confers on the Secretaría de Gobernación the function of vigilance, inspection and supervision over every game with wagers and every authorised draw, including the appointment of inspectors and interventors with full access to permitted establishments.

Requirements
  • Recognise SEGOB's permanent vigilance authority as a condition of every permit
  • Permit access to inspectors and interventors at every operating hour
  • Maintain a single point of contact for SEGOB supervisory notifications
Article 5 is the statutory hook for the inspection regime that the Reglamento operationalises through arts. 132-137.
LFJS art. 7

Conditions attached to every permit

Player Rights

Article 7 directs that every permit issued under the LFJS must set out the conditions to which the holder is subject, including the place, days and hours of operation, the participaciones owed to the federation and any other restrictions SEGOB considers necessary in the public interest.

Requirements
  • Operate strictly within the place, days and hours stated in the permit resolution
  • Settle the federal participación in full and on time
  • Treat every additional SEGOB condition as a binding permit term
LFJS art. 8

Federal participation on permit receipts

Article 8 reserves to the federation a participación on the proceeds of permitted games and draws, fixed in the permit resolution. The participación is independent of any tax payable under the IEPS or state-level statutes and is enforceable through the Tesorería de la Federación.

Requirements
  • Calculate and remit the federal participación as fixed in the permit resolution
  • Treat the participación as a permit obligation, distinct from tax
  • Maintain accounting that reconciles wagering receipts to the federal share
LFJS art. 9

Publicity of the permit resolution

Article 9 requires permit resolutions and their material modifications to be published in the Diario Oficial de la Federación as a condition of opposability against third parties. Unpublished modifications cannot be invoked against the federation or the public.

Requirements
  • Confirm DOF publication of each permit grant and every modification
  • Preserve the DOF citation in the compliance file
  • Refuse to rely on any unpublished permit amendment
LFJS art. 10

Inspector access without prior notice

Article 10 authorises SEGOB inspectors to enter establishments where permitted games or draws are held, at any operating hour and without prior notice, and to require the production of books, records and gaming equipment.

Requirements
  • Treat unannounced inspector entry as a permit obligation
  • Make books, records and equipment available on demand
  • Train staff to verify inspector credentials before granting access
LFJS art. 11

Duty to cooperate with inspection

Article 11 obliges permit holders, their staff and any person present in an authorised establishment to cooperate with SEGOB inspectors, including providing information, allowing equipment to be examined and signing inspection minutes.

Requirements
  • Cooperate in good faith with every inspection
  • Provide truthful answers to inspector questions
  • Sign actas administrativas, noting reservations on the document itself
Obstruction of an LFJS inspection is itself a sanctionable conduct under arts. 12-15.
LFJS art. 12

Administrative sanctions for breach

Player Rights

Article 12 sets out the administrative sanctions for breach of the LFJS and its Reglamento: monetary fines calibrated to the gravity of the conduct, temporary closure of the establishment, and revocation of the permit. The sanction ladder is independent of any criminal liability under the Código Penal Federal.

Requirements
  • Treat sanction exposure as cumulative with criminal liability
  • Maintain a sanction-readiness file with mitigating evidence
  • Brief boards on the revocation risk attached to repeated breaches
LFJS art. 13

Fine tiers and calculation

Article 13 sets the monetary fine tiers for LFJS breaches, originally fixed in pesos and now applied by reference to the Unidad de Medida y Actualización (UMA). Fines are assessed in light of the gravity of the conduct, the economic capacity of the infractor and any recidivism.

Requirements
  • Track current UMA value when assessing fine exposure
  • Document mitigating circumstances for use in any sanction proceeding
  • Account for recidivism uplift in repeat-offence scenarios
The original peso amounts have been displaced in practice by UMA-indexed calculation following the 2016 constitutional reform.
LFJS art. 14

Temporary and definitive closure

Article 14 empowers SEGOB to order the temporary or definitive closure of any establishment where unauthorised games or draws are conducted, where the conditions of the permit have been breached, or where the public order is threatened.

Requirements
  • Recognise SEGOB's standalone closure power, independent of fines
  • Have business-continuity plans for sudden closure scenarios
  • Treat repeated breaches as a path to definitive closure
LFJS art. 15

Revocation of permits

Player Rights

Article 15 lists the grounds for revocation of a permit: serious or repeated breach of the LFJS or Reglamento, non-payment of the federal participación, transfer of the permit without SEGOB authorisation, and conduct that affects public order or morality.

Requirements
  • Maintain a revocation-trigger register tracking each statutory ground
  • Settle the federal participación on time, every time
  • Obtain prior SEGOB authorisation for any change of control
LFJS art. 16

Confiscation of equipment and proceeds

Article 16 provides for the confiscation of gaming equipment, instruments, wagers and proceeds found in unauthorised establishments or used in conduct that contravenes the LFJS. Confiscated assets are placed at the disposal of the Tesorería de la Federación.

Requirements
  • Operate only from authorised sites to avoid equipment confiscation
  • Segregate authorised equipment with documentary trace
  • Anticipate that wagering balances on illicit channels are non-recoverable
LFJS art. 17

Criminal referral for unauthorised conduct

Article 17 directs SEGOB to denounce to the Ministerio Público Federal any conduct that may constitute the offences described in the Código Penal Federal, in addition to administrative sanctions. Administrative and criminal proceedings run in parallel.

Requirements
  • Expect criminal-referral exposure to coexist with administrative sanction
  • Prepare legal coordination across administrative and criminal counsel
  • Treat findings in either forum as evidence in the other
The criminal layer is operationalised through Código Penal Federal arts. 257-264.
2
Theme 2

The 2004 Reglamento

The Reglamento de la Ley Federal de Juegos y Sorteos, published in the DOF on 17 September 2004, is the operational rulebook for the entire sector. It defines permit classes, sites authorised, technical approvals, anti-cheating duties, books-and-records and the sanction ladder — and is the instrument the 23 November 2023 decree reformed to ban slot machines.

126 standards 56 player-flagged
44%
player-flagged
Regulatory risks this theme addresses
  • Treating the 1947 LFJS as a self-contained rulebook without reference to the 2004 Reglamento
  • Operating outside the sites authorised in the permit resolution
  • Failing to obtain prior DGJS approval for new games, software or hardware
RLFJS art. 1

Object and scope of the 2004 Reglamento

Article 1 establishes the Reglamento as the instrument for the application of the LFJS, regulating permit administration, the operation of permitted establishments, the technical and operational requirements for games and draws, advertising, sanctions and inspection.

Requirements
  • Use the Reglamento as the operative compliance reference
  • Cross-check every LFJS obligation against the implementing Reglamento article
  • Monitor DOF for any reform of the Reglamento
RLFJS art. 4

Sites authorised in the permit resolution

Player Rights

Each permit lists the precise physical sites at which permitted activities may be conducted. Activities at any other site, even by the same permit holder, are unauthorised and may trigger revocation.

Requirements
  • Operate only at sites listed in the permit resolution
  • Request SEGOB authorisation for any new site before opening
  • Maintain a site register reconciled to the permit annex
RLFJS art. 11

Permit application file content

Article 11 lists the documents that must accompany a permit application: corporate documentation, controller identification, financial projections, technical description of the proposed games, security and surveillance plans, and a draft operating manual.

Requirements
  • Compile the complete article 11 file before lodging an application
  • Annex independent financial and technical evidence
  • Identify every controller and beneficial owner
RLFJS art. 30

Minimum age and identification at the door

RG Critical Player Rights

Article 30 prohibits access by minors to authorised establishments and obliges the permit holder to verify age and identity at entry. The minimum age for any wagering activity is 18.

Requirements
  • Block access by anyone under 18 to any wagering area
  • Verify age with an official identification document
  • Maintain CCTV evidence of access controls
  • Train front-of-house staff on age-verification procedures
RLFJS art. 31

Player-account books and records

Player Rights

Permit holders must keep individualised books and records of every player account, including identification, transactions, balances and wagering history, and produce them to SEGOB and the SAT on request.

Requirements
  • Maintain a per-player ledger with full transaction history
  • Preserve records for the period required by tax and AML law
  • Surrender records to SEGOB, SAT or UIF on lawful request
RLFJS art. 65

RNG and game-software certification

Game Design

Article 65 obliges permit holders to use only games whose software, hardware and random-number generators have been certified to standards accepted by the DGJS. Certification must precede any commercial launch.

Requirements
  • Certify every RNG with a DGJS-accepted laboratory before launch
  • Re-certify after any material software or hardware change
  • Keep certificates available for DGJS inspection
GLI-19, GLI-33 and BMM equivalents are the certifications commonly relied on by Mexican permit holders.
RLFJS art. 71

Anti-cheating and game-integrity duties

Game Design Player Rights

Permit holders must adopt measures to prevent cheating, collusion, money-laundering and any conduct affecting game integrity, and must report incidents to the DGJS.

Requirements
  • Implement an anti-cheating and surveillance programme
  • Investigate and document every integrity incident
  • Report serious incidents to the DGJS within the deadline set in the inspection rules
RLFJS art. 132

DGJS inspection powers

DGJS inspectors may enter any authorised establishment without prior notice during operating hours, examine books and records, test gaming equipment, interview staff and require production of documents and electronic data.

Requirements
  • Permit DGJS access at all operating hours
  • Designate a compliance officer to attend inspections
  • Produce books, records and electronic data on request
RLFJS art. 137

Inspection records and acta administrativa

Every inspection concludes with an acta administrativa setting out findings, signed by inspectors and a permit-holder representative. The acta is the procedural foundation for any sanction proceeding.

Requirements
  • Designate a representative empowered to sign the acta
  • Record observations and reservations on the acta itself
  • Retain a counter-signed copy of every acta
RLFJS art. 2

Definitions used throughout the Reglamento

Article 2 sets out the controlling definitions of the Reglamento, including apuesta, sorteo, juego con apuestas, establecimiento, permisionario, operador and máquina. Every operative obligation in the Reglamento is read through these definitions.

Requirements
  • Adopt the art. 2 definitions verbatim in internal manuals
  • Avoid drafting that conflates apuesta, sorteo and juego con apuestas
  • Map every product to the matching defined term
RLFJS art. 3

SEGOB competences under the Reglamento

Article 3 enumerates the regulatory competences of SEGOB under the Reglamento: granting, modifying and revoking permits; approving manuals and games; authorising sites; conducting inspections; and imposing sanctions. The article is the operational counterpart to LFJS art. 3.

Requirements
  • Address every regulatory matter to SEGOB via the DGJS
  • Distinguish SEGOB approvals from SAT or UIF requirements
  • Track Reglamento reforms that adjust the catalogue of competences
RLFJS art. 21

Criteria for granting a permit

Player Rights

Article 21 sets the criteria SEGOB applies when assessing a permit application: legality of the corporate vehicle, demonstrated technical and economic capacity, suitability of the proposed sites, and public interest in the proposed activity. SEGOB's resolution is discretionary but must be motivated.

Requirements
  • Build a permit file evidencing each art. 21 criterion
  • Document public-interest considerations explicitly
  • Expect a motivated resolution and preserve it for renewal
RLFJS art. 23

Controller and beneficial-owner disclosure

Player Rights

Article 23 requires permit applicants to disclose the identity of every controlling shareholder, director, statutory examiner and ultimate beneficial owner, supported by documentary evidence of legal capacity and absence of disqualifying antecedents.

Requirements
  • Map controllers, directors and UBOs before lodging the permit file
  • Refresh the disclosure on every change of control
  • Preserve antecedents evidence for the life of the permit
RLFJS art. 25

Permit modification procedure

Article 25 governs modifications to a permit during its term: changes to sites authorised, to the operating manual, to controllers or to the games offered must be filed in advance with SEGOB and approved by resolution published in the DOF.

Requirements
  • File modification requests in advance of any material change
  • Wait for SEGOB resolution before implementing modifications
  • Track DOF publication as the operative date
RLFJS art. 28

Grounds for revocation under the Reglamento

Player Rights

Article 28 expands the LFJS art. 15 revocation grounds: serious breach of permit conditions, sustained non-compliance with technical certification, non-payment of the federal participación, transfer without authorisation, and any conduct that compromises the integrity of permitted activities.

Requirements
  • Treat each art. 28 ground as a board-level risk indicator
  • Maintain quarterly compliance attestations covering each ground
  • Document remediation of any breach to support continued permit standing
RLFJS art. 32

Site authorisation procedure

Player Rights

Article 32 sets out the procedure for authorising each site at which a permit holder may operate: prior request to SEGOB, evidence of compliance with use-of-land and municipal rules, security and surveillance plan, and inspection of the site before commercial opening.

Requirements
  • Lodge a separate site authorisation for every establishment
  • Annex municipal use-of-land authorisations
  • Pass the pre-opening inspection before serving any wager
RLFJS art. 35

Distance and location restrictions

RG Critical

Article 35 prohibits authorisation of establishments within minimum distances of schools, hospitals and religious sites, and requires consideration of the urban context. SEGOB may refuse authorisation on location grounds even where every other condition is met.

Requirements
  • Run a distance check against the protected categories before site selection
  • Preserve evidence of the distance analysis in the site file
  • Expect refusal of authorisation in densely sensitive urban contexts
RLFJS art. 40

Physical security and surveillance plan

Player Rights

Article 40 requires every authorised establishment to maintain a physical security and surveillance plan covering access control, CCTV, cash-handling, panic procedures and coordination with public-security authorities. The plan is reviewed at each inspection.

Requirements
  • Maintain a written security and surveillance plan for every site
  • Operate CCTV with retention periods that match inspection cycles
  • Coordinate panic procedures with local public-security authorities
RLFJS art. 41

Operating books and records

Article 41 obliges permit holders to keep operating books and records for every authorised establishment, covering wagering, payout, cash-handling, equipment movements and inspection events. The books must be available for SEGOB inspection at any time.

Requirements
  • Maintain per-site operating books reconciled daily
  • Record every equipment movement, including software updates
  • Produce books on demand at any inspection
RLFJS art. 45

Monthly reporting to the DGJS

Player Rights

Article 45 requires permit holders to file monthly reports to the DGJS covering wagering volumes, payout ratios, federal participación calculations, technical incidents and any sanction events. The reports are the principal supervisory input between inspections.

Requirements
  • File complete monthly reports within the regulatory deadline
  • Reconcile each monthly report to the operating books
  • Disclose technical and sanction incidents proactively
RLFJS art. 50

Record retention period

Player Rights

Article 50 fixes the minimum retention period for operating books, player-account records and supporting documentation, aligned with tax and AML retention obligations. Records may not be destroyed before the retention period elapses, even if commercial relations have ended.

Requirements
  • Apply the longest applicable retention across SEGOB, SAT and UIF rules
  • Document destruction events only after retention lapses
  • Maintain disaster-recovery copies through the retention period
RLFJS art. 60

Pre-launch approval of games

Game Design

Article 60 requires DGJS pre-launch approval of every game offered by a permit holder, supported by technical documentation, mathematical model, RTP, paytables and certification by an accepted laboratory. Commercial launch before approval is itself a sanctionable breach.

Requirements
  • Submit complete technical files for each new game
  • Withhold commercial launch until DGJS approval issues
  • Re-certify after any material parameter change
RLFJS art. 67

Accepted certification laboratories

Game Design

Article 67 confines RNG and game-software certification to laboratories formally accepted by the DGJS. The list of accepted laboratories is published and updated by SEGOB; certificates from non-accepted laboratories are not recognised.

Requirements
  • Use only DGJS-accepted laboratories for every certification
  • Verify the laboratory's accepted status on the certification date
  • Refresh certificates if a laboratory's status changes
GLI and BMM are typically among the accepted laboratories.
RLFJS art. 70

Equipment registry and traceability

Game Design

Article 70 requires every piece of gaming equipment to be registered with the DGJS, identified by serial number, software version and location, with traceable movement records between sites and warehouses.

Requirements
  • Register every machine, terminal and server with the DGJS
  • Maintain a movement log for each registered asset
  • Reconcile the registry to physical inventory at each inspection
RLFJS art. 72

Prohibition on collusion with players

Game Design Player Rights

Article 72 prohibits permit-holder staff and any person acting on their behalf from colluding with players, manipulating equipment or otherwise interfering with the integrity of permitted games. Detection triggers internal sanction and DGJS referral.

Requirements
  • Code anti-collusion rules into staff conduct policies
  • Operate independent surveillance of high-volume tables and terminals
  • Refer integrity breaches to the DGJS without delay
RLFJS art. 75

Game-incident investigation and reporting

Player Rights

Article 75 requires the permit holder to investigate every reported integrity incident, document findings in a written record and report material incidents to the DGJS within the deadline fixed in the inspection rules.

Requirements
  • Open a written investigation file for every reported incident
  • Preserve CCTV, logs and player communications relevant to the incident
  • Notify the DGJS of material incidents inside the regulatory window
RLFJS art. 80

Exclusion of staff from wagering

RG Critical Player Rights

Article 80 prohibits permit-holder staff, directors and family members of a defined degree from wagering at the establishment in which they work. The prohibition extends to remote channels operated by the same permit holder.

Requirements
  • Maintain a list of excluded staff and related parties
  • Block excluded persons at point of access and through the online account system
  • Audit the exclusion list at each personnel change
RLFJS art. 81

Pre-opening inspection

Player Rights

Article 81 requires a pre-opening inspection of every newly authorised establishment, covering site layout, equipment installation, security plan and books-and-records system. The DGJS may refuse to permit commercial opening until findings are remediated.

Requirements
  • Schedule the pre-opening inspection well before target opening
  • Resolve all findings before serving any wager
  • Document remediation in the site compliance file
RLFJS art. 83

Interventor appointment power

Article 83 empowers SEGOB to appoint an interventor at any authorised establishment where serious or sustained breach is suspected. The interventor has access to the site, books and equipment and reports directly to the DGJS.

Requirements
  • Recognise interventor appointment as a high-severity supervisory measure
  • Cooperate fully with the interventor
  • Treat findings in the interventor's report as evidence in any sanction proceeding
RLFJS art. 88

Electronic record integrity

Game Design Player Rights

Article 88 requires that electronic operating records be kept in a form that preserves integrity, time-stamping and tamper-evidence. Records altered after the fact without an audit trail are inadmissible at inspection and may themselves trigger sanction.

Requirements
  • Operate write-once or hash-chained logging for operating records
  • Maintain time-synchronised audit trails for every record change
  • Retain integrity evidence alongside the records themselves
RLFJS art. 90

Segregation of player funds

Player Rights

Article 90 requires permit holders operating accounts to segregate player-balance funds from operating funds, holding them in accounts identifiable as fiduciary in nature, so that player balances are recoverable in any insolvency scenario.

Requirements
  • Hold player balances in segregated accounts
  • Document the fiduciary character of the segregation arrangement
  • Reconcile player balances to the segregated accounts daily
RLFJS art. 92

Data residency and access for supervision

Game Design

Article 92 requires that the books, records and electronic data necessary for SEGOB supervision be accessible from Mexican territory, whether hosted locally or mirrored from foreign infrastructure. Offshore-only storage without a Mexican access point is non-compliant.

Requirements
  • Provide a Mexican access point for every regulated dataset
  • Document data residency and replication arrangements in the operating manual
  • Test inspector access to mirrored data at each supervisory cycle
RLFJS art. 5

Persons barred from wagering areas

RG Critical Player Rights

Article 5 prohibits access to or permanence in the wagering areas by minors (except when accompanying an adult to a live show, and never to place bets), persons under the influence of psychotropic or prohibited substances or alcohol, armed persons, uniformed police or military on duty (unless on official business), persons disturbing order, persons caught cheating and persons in breach of the internal rules approved by SEGOB.

Requirements
  • Block access to the wagering area by anyone falling within the article 5 categories
  • Operationalise refusal procedures and CCTV evidence at the door
  • Train staff to identify intoxication, weapons and disorderly conduct
  • Keep an internal rulebook approved by SEGOB and apply it consistently
Minors may enter live-show areas with an adult but can never participate in betting under any circumstance.
RLFJS art. 6

Permit holder liability for event breaches

Article 6 makes the permit holder responsible for every infraction committed in connection with an authorised event under the LFJS and this Reglamento.

Requirements
  • Treat permit-holder liability as strict for any in-venue breach
  • Maintain internal controls so that staff, contractors and third parties do not commit acts that expose the permit
  • Document remedial action whenever a breach occurs
Liability runs to the permit holder even where the operational fault was that of an employee or contractor.
RLFJS art. 7

Only LFJS art. 2 games may be operated, and only with a SEGOB written permit

Article 7 (as reformed 16 November 2023) restricts the lawful operation, organisation or running of betting games and draws to those expressly listed in article 2 of the LFJS and only with a prior written SEGOB permit. Anything outside this perimeter is unlawful.

Requirements
  • Confirm every product line maps to a category in LFJS art. 2
  • Obtain the written SEGOB permit before going live
  • Document the legal basis for each game in the operating manual
Reformed in the November 2023 decree to tighten language; the substantive rule has applied since 2004.
RLFJS art. 8

Federal participations determined by SEGOB

Article 8 (reformed 16 November 2023) provides that the federal participations referred to in LFJS art. 5 are determined by SEGOB according to guidelines it issues and the type of permit involved.

Requirements
  • Track SEGOB lineamientos that set the participation rate for each permit class
  • Reconcile participations payable on a per-permit basis
  • Pay federal participations on time to avoid an art. 151 grave infraction
This is the federal participations stack — separate from IEPS, ISR and state taxes.
RLFJS art. 10

Operations must be denominated in Mexican pesos

Player Rights

Article 10 requires all wagering and draw operations regulated by the Reglamento to be conducted in national currency (Mexican pesos).

Requirements
  • Denominate stakes, payouts and player balances in Mexican pesos
  • Reflect MXN as the operating currency on receipts and player accounts
  • Route FX conversions outside of the player wagering perimeter
RLFJS art. 14

Consejo Consultivo de Juegos y Sorteos

Article 14 creates the Consejo Consultivo de Juegos y Sorteos to assist the DGJS in implementing transparency and accountability policies under the LFJS and the Reglamento.

Requirements
  • Track Consejo Consultivo opinions, which feed into permit and renewal decisions
  • Engage with Consejo proceedings where invited
The Consejo is an internal advisory body — operators do not sit on it but its non-binding opinions influence permit outcomes.
RLFJS art. 15

Consejo Consultivo powers and remit

Article 15 lists the Consejo Consultivo's powers, including advising SEGOB on the exercise of DGJS faculties, recommending regulatory improvements, issuing non-binding opinions on the grant, modification, renewal, extension or wind-up of remote betting centres and number-and-symbol draw halls, conducting studies, certifying professional brokers, organising working groups and adopting its own rules of procedure.

Requirements
  • Monitor Consejo opinions on permit grants, renewals and modifications
  • Engage constructively where Consejo working groups address operator-facing issues
The opinion on grant, modification, renewal, extension or wind-up is non-binding but materially shapes DGJS decisions.
RLFJS art. 16

Consejo Consultivo composition

Article 16 (reformed 16 November 2023) sets the Consejo's membership: the heads of the SEGOB Unidad de Gobierno (chair), Unidad de Administración y Finanzas and Unidad General de Asuntos Jurídicos as voting members, plus the SEGOB internal-control head and three civil-society members as permanent invitees. Decisions are by majority; the DGJS head is non-voting secretary.

Requirements
  • Note the Consejo's voting structure for purposes of permit-related engagement
  • Identify the chairs and invitees when seeking pre-permit consultation
Civil-society invitees serve three-year honorary terms.
RLFJS art. 17

Base de Datos de Juegos y Sorteos — content

Article 17 requires the DGJS to maintain a Base de Datos containing, at minimum: granted permits and modifications, sanctions imposed, the identity of permit holders down to the last shareholder or beneficiary, directors and senior employees, professional brokers, names and photos of inspectors, sectoral statistics, permit-holder financial statements, ongoing sanction and litigation files, Consejo resolutions, technical-consultative-body information and anything else SEGOB determines.

Requirements
  • Supply ultimate-beneficial-owner data down to the last beneficiary
  • File quarterly and annual financial statements that feed the Base de Datos
  • Update director and senior-employee data on change
  • Report broker identities for inclusion in the database
Several fractions were reformed 16 November 2023 to widen beneficial-ownership and litigation-history transparency.
RLFJS art. 18

Publication of the Base de Datos online

Article 18 (reformed 16 November 2023) authorises the DGJS to publish Base de Datos content on the SEGOB website in line with transparency and access-to-information rules.

Requirements
  • Expect material Base de Datos content to be publicly disclosed
  • Mark commercially sensitive material accordingly when filing
Publication is at SEGOB's discretion but is the default for non-confidential entries.
RLFJS art. 19

Base de Datos update cadence — within 10 working days

Article 19 obliges the DGJS to keep the Base de Datos current and to clearly state the last update date, which may never be more than 10 working days behind the current date.

Requirements
  • File updated records promptly so the 10-working-day window is met
  • Verify Base de Datos accuracy against own records on a routine basis
RLFJS art. 26

Additional documentation for sorteos permits (LFJS art. 20.IV)

Article 26 lists additional documentation required for sorteos-class permits beyond the art. 21 baseline: participation mechanics and prize-delivery procedure, sample ticket with participation bases and dissemination media printed on the back, ticket-supplier identity for instant draws, replacement-value quotations for prizes (with appraisal for real-estate prizes) and a full prize structure.

Requirements
  • Submit a sample ticket showing participation bases and result channels
  • Annex prize replacement-value quotations and an appraisal for real-estate prizes
  • Identify the ticket supplier for instant-draw applications
  • Specify prize brand, model, quantity and unit value
RLFJS art. 29

Permit-holder ongoing obligations (hipódromos, galgódromos, frontones, centros de apuestas remotas, salas de sorteos)

RG Critical Player Rights

Article 29 imposes the operational obligations on permit holders for racetracks, jai alai, remote betting centres and number-and-symbol draw halls: quarterly and annual audited financial statements, annual insurance and civil-liability policy filings, denunciation of suspected organised-crime or money-laundering activity, participant-security measures, art. 5 access screening, monthly revenue and participations reports, notification of share transfers and beneficial-ownership changes, capital maintenance, prohibition on tax-haven shareholders, prohibition on opaque trust holdings, adoption of BMV best-practice corporate governance, a 25% independent-director floor, an ongoing prize-payment bond covering 60 operating days and annual labour-relations updates.

Requirements
  • File quarterly statements within 20 working days and audited annual statements within six months
  • File insurance and civil-liability policies annually in the first 30 working days
  • Denounce suspected organised-crime or money-laundering activity to authorities and notify SEGOB
  • Screen entrants against the art. 5 categories
  • Maintain the prize-payment bond covering 60 days of average annual operation
  • Block tax-haven and opaque-trust shareholdings
  • Maintain 25% independent directors on the board
This is the operational backbone for the regulated betting-venue permit classes; failure is a grave infraction under art. 151.II that triggers permit revocation.
RLFJS art. 33

Permit terms by category — including 15-year cap and renewal

Article 33 (reformed 16 November 2023) caps permits for racetracks, jai alai, remote betting centres and number-and-symbol draw halls at a maximum of 15 years (minimum one). Permits for fairs, cockfights and temporary horse races run for up to 28 days or the authorised season; commercialisation-system draws run for the time needed to award the underlying good or service; draws with or without ticket sales and instant draws run for up to one year. Class-I permits may be extended for further 15-year periods if the holder is fully compliant.

Requirements
  • Plan investment and exit on a 15-year horizon for the regulated betting-venue permit classes
  • Schedule renewal applications well ahead of expiry — full compliance is the precondition
  • Track the 28-day cap for fair, cockfight and temporary horse-race permits
  • Cap sorteo-class permit terms at one year
The 15-year cap is the headline rule from the November 2023 decree; previous practice tolerated indefinite renewals.
RLFJS art. 34

Permit extinction causes

Article 34 lists the four causes that extinguish a permit: term expiry, completion of the event, revocation, and bankruptcy, dissolution, liquidation or extinction of the permit holder (or, for natural persons, bankruptcy or death).

Requirements
  • Trigger wind-up procedures at expiry, completion, revocation or insolvency
  • Notify SEGOB and trigger the finiquito process on extinction
RLFJS art. 36

Organiser staff barred from participating in draws

Player Rights

Article 36 (reformed 23 October 2013 and 16 November 2023) bars persons who organise draws or employees of permit holders involved in ticket production or in the event determining winning tickets from participating in those draws.

Requirements
  • Maintain a participation-bar list covering employees involved in ticket production or draw events
  • Build participation screening into draw entry procedures
  • Document compliance in the draw act
RLFJS art. 37

Definition of winner and complaint route to SEGOB

Player Rights

Article 37 defines the winner as the person who, by hitting or achieving the object of the event, becomes entitled to the prize and can prove it either by holding the ticket or participation receipt or by establishing winner status via suitable evidence. A self-styled winner who is not paid may complain to SEGOB, which will decide and where appropriate sanction the permit holder and order prize delivery.

Requirements
  • Define winner criteria and acceptable evidence in the operating manual
  • Make a complaint route to SEGOB clear to players
  • Maintain records adequate to defend or admit prize disputes
RLFJS art. 38

Venue location — authorised address and 200-metre buffer

Player Rights

Article 38 requires venues to be located exactly where SEGOB authorises and prohibits installation within 200 metres of basic, upper-secondary and higher education institutions or of registered places of worship. Where a draw is organised by such an institution, SEGOB may authorise the event at its own premises.

Requirements
  • Measure 200 metres from every nearby school and registered place of worship before site selection
  • Hold the venue at the exact authorised address
  • Re-apply for any address change
This is the headline land-use rule for casinos and draw halls; non-compliance is a frequent revocation trigger.
RLFJS art. 39

Permit documentation held on site

Article 39 requires the permit holder to keep current permit documentation at the place the events are held, available for inspection by any duly authorised public official.

Requirements
  • Keep an up-to-date copy of the permit at the venue
  • Train front-of-house staff to produce it on inspector request
RLFJS art. 42

Consequences of non-compliance — denial of new permits and bond enforcement

Article 42 enables SEGOB to deny new permits, demand prize delivery to winners or treasury payment of amounts owed, and call the bond where a permit holder fails to comply. Non-compliance is notified to other competent authorities.

Requirements
  • Treat unpaid prizes and outstanding obligations as a bar to any new permit
  • Maintain the bond at a level sufficient to absorb enforcement
  • Settle outstanding obligations before applying for renewals or new permits
RLFJS art. 43

Bet system integrity and equal information

Game Design Player Rights

Article 43 requires the betting system to handle information adequately, avoid inducing error or being manipulated, and ensure adequate and timely dissemination of event information to the public on equal terms.

Requirements
  • Document system controls preventing error or manipulation
  • Publish event information simultaneously to all in-venue and remote players
  • Log changes to odds, lines and event status
RLFJS art. 44

Broker and frontón intendant — personal eligibility

Article 44 requires a natural person providing brokerage, bet-taking or frontón intendant services in an authorised venue to be of legal age, hold Mexican nationality (or lawful migratory status with a work permit), demonstrate the necessary technical or professional knowledge, have no conviction for intentional property, tax or organised-crime offences. Supervisors, hall managers and intendants must post a bond and provide data for the Base de Datos.

Requirements
  • Pre-screen brokers and intendants against the art. 44 criteria
  • Obtain bonds from supervisors, hall managers and intendants
  • Update broker data in the Base de Datos on hire and on departure
RLFJS art. 46

Broker conflict of interest — no personal stake or payment

Player Rights

Article 46 bars brokers, intendants, their supervisors, other bet-related staff and customer-service personnel from participating personally (directly or through intermediaries) and from receiving any consideration from bettors for brokerage or bet-taking services, with the sole exception of tips.

Requirements
  • Prohibit staff from placing bets in their own venue and from accepting payment beyond tips
  • Run a periodic conflict-of-interest attestation
  • Discipline breaches consistently to defend the permit
RLFJS art. 47

Technical consultative bodies — composition

Article 47 requires the órganos técnicos de consulta to organise so that they incorporate as members most participants in horse and greyhound racing and jai alai: trainer, owner, jockey, judge, frontón player and permit-holder associations. The general public is excluded.

Requirements
  • Engage with the relevant technical consultative body for racing or frontón permits
  • Note that its opinion feeds into the permit decision under art. 49
RLFJS art. 48

Permit terms for racetrack, greyhound and frontón venues

Article 48 provides that the permit fixes the terms and conditions for operating bet-taking at racetracks, greyhound tracks and frontones. Where the venue sits on federal property, federal-asset concession rules apply in addition to the gambling permit.

Requirements
  • Read the permit's terms and conditions as binding alongside the Reglamento
  • Layer federal-asset concession compliance for venues on federal land
RLFJS art. 49

Application procedure for racetrack, greyhound and frontón permits

Article 49 requires the DGJS to refer racetrack, greyhound and frontón applications to the technical consultative body and the Consejo Consultivo, each with a 60-working-day opinion window. During that window SEGOB and the consultative body verify the applicant's technical conditions. SEGOB grants or denies the permit on the merits and the verification result. The permit fixes a reasonable start-of-operations deadline; missing it triggers revocation.

Requirements
  • Plan for at least a 60-working-day opinion window in racetrack and frontón permit applications
  • Prepare technical-verification documentation in advance
  • Meet the start-of-operations deadline written into the permit
RLFJS art. 51

Racetrack annual season — authorisation

Article 51 obliges the racetrack permit holder to apply to SEGOB for authorisation of its annual season, stating the number and modality of races, the industry-support and promotion mechanisms and the technical elements securing the certainty of results. SEGOB requests an órgano técnico opinion before authorising.

Requirements
  • Submit the annual-season application with race count, modality and technical elements
  • Describe industry-support and promotion measures
  • Allow time for the órgano técnico opinion
RLFJS art. 52

Out-of-season or unscheduled race authorisation

Article 52 requires SEGOB authorisation for races held outside the season or not included in the season authorisation, considering the órgano técnico opinion and any technical verification.

Requirements
  • Apply ahead for any race added outside the authorised season
  • Provide technical-verification material on request
RLFJS art. 53

Definition of galgódromo

Article 53 defines a galgódromo as the permanent or temporary venue where greyhound races are run, including the track, stands and ancillary installations. Operation is subject to the Reglamento and SEGOB rules.

Requirements
  • Apply the Reglamento and any SEGOB technical rules to greyhound-track operations
RLFJS art. 54

Galgódromo — cross-application of racetrack rules

Article 54 subjects galgódromo permit holders to the obligations in Sections I and II of the racetrack chapter, where applicable.

Requirements
  • Apply racetrack Section I and II obligations to greyhound-track operations
RLFJS art. 55

Definition of frontón

Article 55 defines a frontón as the open or closed venue where the frontón game is habitually and formally played by professional pelotaris, including ancillary installations.

Requirements
  • Operate the frontón only at the authorised venue and in defined modalities
RLFJS art. 56

Frontón season — 20-working-day notification

Article 56 obliges the frontón permit holder to notify SEGOB at least 20 working days before the start of each season, stating the number of games and the season duration.

Requirements
  • Notify SEGOB at least 20 working days before each frontón season
  • Specify game count and season duration
RLFJS art. 57

Frontón — continuous operations duties

Player Rights Game Design

Article 57 requires the frontón permit holder at all times to maintain continuous video and audio recording of every betting game, conserve those recordings at least 90 working days post-event, hold operating guidelines listing bet types, broker and supervisor names and the responsible judge and intendant, publish the day's programme with player names, approximate game times and yearly records, keep a public complaints book brought to the inspector's attention, and engage a qualified judge to officiate.

Requirements
  • Maintain video and audio recording of every betting game
  • Keep recordings for at least 90 working days
  • Maintain a public complaints book and surface complaints to the inspector
  • Publish the day's programme with player records
RLFJS art. 58

Frontón intendant — SEGOB prior approval

Article 58 allows the permit holder to designate the frontón intendant, who must have prior written SEGOB approval before taking up the role.

Requirements
  • Obtain prior written SEGOB approval before appointing the frontón intendant
  • Keep the approval on file at the venue
RLFJS art. 59

Definition of feria — annual regional event 21-28 days

Article 59 (reformed 16 November 2023) defines a feria as a temporary regional event promoting economic, tourist, agricultural or other activity, expressly authorised by the state and municipal/alcaldía government, held once a year for 21 to 28 calendar days. Smaller civic, social or religious local celebrations do not qualify.

Requirements
  • Hold the feria within the 21-to-28-calendar-day window once a year
  • Secure state and municipal/alcaldía authorisation before applying to SEGOB
RLFJS art. 61

Feria — minimum 250,000 certified visitors threshold

Article 61 requires the feria of the immediately preceding year to have had at least 250,000 certified visitors. Otherwise SEGOB will not grant the bet-taking permit.

Requirements
  • Evidence at least 250,000 certified visitors in the prior year before applying
  • Maintain visitor-certification documentation alongside the application
RLFJS art. 62

Cap of four feria permits per state per calendar year

Article 62 allows SEGOB to authorise bet-taking at no more than four ferias per state per calendar year.

Requirements
  • Track the four-permit cap per state when planning fair-season activity
  • Coordinate with state competitors and authorities where the cap is reached
RLFJS art. 63

Bet types permissible at fairs

Article 63 restricts in-fair bet-taking to: temporary-scenario horse races, cockfights, card and dice games, roulette and symbol-and-number draws. Symbol-and-number draws may only be held at the cockfight palenque while open. Any other bet-taking spectacle is prohibited.

Requirements
  • Restrict bet-taking at fairs to the five authorised modalities
  • Hold symbol-and-number draws only at the cockfight palenque
RLFJS art. 64

Feria — installation suitability

Article 64 requires adequate installations for the proper operation and conduct of the authorised games before bet-taking can take place at a fair.

Requirements
  • Provision suitable installations for each authorised game type
  • Document installation suitability ahead of the inspector visit
RLFJS art. 66

Temporary horse-race permits — 28-day cap

Article 66 caps permits for bet-taking at temporary horse races at 28 days or less.

Requirements
  • Hold temporary horse-race events within the 28-day cap
RLFJS art. 68

Temporary race permit must specify race count

Article 68 requires the bet-taking permit to specify precisely the authorised number of races.

Requirements
  • State the precise race count in the application and reconcile to the permit
RLFJS art. 69

Temporary race — application requirements

Article 69 requires the applicant for temporary horse-race bet-taking to comply with the Title II Chapter I baseline and additionally to file the proposed race programme and a written communication from the órgano técnico de consulta certifying that the temporary scenario meets the necessary technical requirements.

Requirements
  • File the race programme alongside the application
  • Obtain a written órgano técnico certification of the temporary scenario
RLFJS art. 73

Cockfight bets only through authorised brokers

Player Rights

Article 73 requires bets in the cockfight scenario to be arranged exclusively by brokers authorised by the permit holder. No other person, employed or not, may arrange or assist with brokerage. The permit holder is responsible for paying brokered bets and for the resulting obligations.

Requirements
  • Channel all cockfight bet-taking through authorised brokers
  • Prevent unauthorised on-floor brokerage by staff or third parties
  • Settle brokered bets through the permit-holder's account
RLFJS art. 74

Palenques over 300 people — continuous video and audio recording

Article 74 requires permit holders of palenques with capacity above 300 to maintain continuous video and audio recording of every cockfight and to retain recordings for 30 working days post-event for use in disputes.

Requirements
  • Record video and audio continuously where palenque capacity exceeds 300
  • Retain recordings for 30 working days post-event
RLFJS art. 76

Definition of centro de apuestas remotas (libro foráneo)

Article 76 defines a centro de apuestas remotas (also known as libro foráneo) as the SEGOB-authorised venue that takes and operates bets on lawful events, competitions and games — held in Mexico or abroad — transmitted in real time in video and audio, and that runs the number-draw modality referred to in art. 124.IV.

Requirements
  • Operate only on real-time video-and-audio feeds for permitted events
  • Confine number-draw activity at the venue to the art. 124.IV modality
RLFJS art. 77

Co-location of remote-betting and number-draw halls

Article 77 (reformed 23 October 2013) permits remote-betting centres to share a location with number-and-symbol draw halls.

Requirements
  • Operate the two formats at one site only where both permits are held
  • Maintain separate operational records for each format
RLFJS art. 78

Special or promotional events — 30-day advance authorisation

Bonus & Ads

Article 78 (reformed 16 November 2023) obliges the permit holder to seek SEGOB authorisation at least 30 days in advance for any special or promotional event at the remote-betting centre.

Requirements
  • Lodge any special-event or promotion request at least 30 days ahead
  • Document the event scope in the application
RLFJS art. 79

Non-televised events — cross-reference to art. 83

Article 79 requires sports events without available television imagery to comply with art. 83.

Requirements
  • Apply art. 83 procedural rules where a televised feed is not available
  • Document the basis for the non-televised event in the betting record
RLFJS art. 82

No aggregation with foreign pools — visible rules and limits

Player Rights

Article 82 allows bet-taking and prize-paying at remote-betting centres against the rules and limits authorised by SEGOB. The rules must be visible to the public. Aggregation with parimutuel or remote-betting pools located outside Mexico is forbidden.

Requirements
  • Display authorised rules and limits to the public
  • Do not aggregate liquidity with foreign parimutuel pools
RLFJS art. 89

Cashed-ticket register retained 90 working days

Article 89 obliges the permit holder to keep a register of cashed winning tickets for 90 working days to support any subsequent inquiry or complaint.

Requirements
  • Retain cashed-ticket records for at least 90 working days
  • Make the register available to authorities on request
RLFJS art. 91

Modalities of sorteos

Article 91 enumerates the lawful draw modalities: draws with ticket sales, without ticket sales, instant draws, draws in commercialisation systems, symbol or number draws and draws transmitted by mass media. Card and equivalent betting games, dice, roulette and slot machines may not be reclassified as sorteos.

Requirements
  • Map every product to one of the six lawful sorteo modalities
  • Do not reclassify cards, dice, roulette or slots as draws
Fraction VI was repealed 16 November 2023; the bar on reclassifying casino games as sorteos was added in the same reform.
RLFJS art. 93

Sorteo permit — additional content

Article 93 requires sorteo permits to state, in addition to art. 32 content, the prize description and value, ticket price and quantity, draw procedure and mechanic, geographic promotion area, communication channels and dates for publishing results, and proposed advertising media.

Requirements
  • Cross-check the sorteo permit against the art. 93 content list
  • Document prize, mechanic, geographic scope and result-publication channels
RLFJS art. 94

Ticket-volume increase — proportional prize uplift required

Player Rights

Article 94 lets the permit holder request a ticket-volume increase once the sorteo is authorised, provided the prize amount is proportionally increased and the change is advertised in the authorised media. No ticket-price changes and no prize-amount reductions are allowed.

Requirements
  • Lift prizes proportionally to any volume increase
  • Announce changes through the authorised channels
  • Never cut the prize fund or change ticket pricing
RLFJS art. 95

Pre-draw disclosure to the public

Player Rights

Article 95 requires the permit holder, at the start of the draw event, to announce the permit number, the inspector's name, the ticket count and unit price, the number of prizes and the draw procedure.

Requirements
  • Read out the five required disclosures before the draw begins
  • Record the disclosure in the act
RLFJS art. 96

Sorteo tickets must be nominative

Article 96 requires sorteo tickets and stubs to be nominative, except for the cases in Chapters II and III of the Title.

Requirements
  • Issue nominative tickets and stubs for sorteos
  • Treat instant-draw and commercialisation-system tickets under their special rules
RLFJS art. 97

Stub concentration at the draw site

Article 97 requires sold ticket stubs to be concentrated at the draw site. Where a winning ticket's stub is not concentrated, the permit holder must inform the inspector at the draw itself and produce evidence that the ticket was sold beforehand. If pre-sale cannot be evidenced, the prize is treated as an unsold ticket.

Requirements
  • Concentrate sold stubs at the draw site before the event
  • Surface any missing stub to the inspector during the draw
  • Hold pre-sale evidence for cases where the stub is missing
RLFJS art. 98

Permitted draw mechanics — tómbola, number formation, Lotería Nacional terminations, RNG software

Game Design

Article 98 lists the four lawful draw mechanics: tómbola, number formation, Lotería Nacional sorteo terminations, and approved RNG software. The RNG modality requires SEGOB pre-approval of the software with the permit application; the inspector must verify correct functioning and may operate the program at the draw. SEGOB may develop its own RNG software.

Requirements
  • Pre-submit the RNG program to SEGOB with the permit application
  • Allow the inspector to operate or verify the RNG on the day
  • Default to the four authorised mechanics — no others are permitted
RLFJS art. 99

Draw order — major to minor (except instant draws)

Article 99 requires, except in instant draws, the prizes to be drawn in descending order, from largest to smallest.

Requirements
  • Draw prizes from the largest to the smallest
RLFJS art. 100

Result publication — three calendar days (15-day cadence for instant draws)

Player Rights

Article 100 requires results to be published at the permit-holder's cost within three calendar days of the draw, naming the winners, prizes won and the permit number, via the channels set in the permit. For instant draws, the holder must publish prizes cashed and delivered every 15 calendar days, in the same media used to promote the draw.

Requirements
  • Publish ordinary-draw results within three calendar days
  • Publish instant-draw status every 15 calendar days
  • Use the channels authorised in the permit
  • Include the prize-claim location, deadline and complaints authority
RLFJS art. 101

No sorteos promoting harmful products

RG Critical Bonus & Ads

Article 101 prohibits authorising sorteos that promote tobacco, alcoholic beverages, medicines or products and articles harmful to health under the Ley General de Salud.

Requirements
  • Screen sorteo prizes and themes against the art. 101 prohibitions
  • Document the absence of harmful-product promotion in the application
RLFJS art. 102

Mandatory SEGOB inspector at every sorteo

Article 102 requires a SEGOB-designated inspector to attend every sorteo and certify it. If the inspector cannot attend for force-majeure reasons, the holder may hold the draw before a public notary and deliver the notarial act to the DGJS. SEGOB ensures transparency in inspector assignments.

Requirements
  • Plan every sorteo around inspector attendance
  • Maintain a public-notary fallback for force-majeure cases
  • File the notarial act with the DGJS when used
RLFJS art. 103

Draw act signed by inspector, permit holder and two witnesses

Article 103 requires the act of the draw to be signed by the inspector and the permit holder (or representative) before two witnesses, listing winning tickets and any prize-number incidents, and recording all permit-holder statements.

Requirements
  • Sign the draw act before two witnesses
  • Record all prize-number incidents and statements
RLFJS art. 104

Internet and telephone participation — folio number

Player Rights

Article 104 requires sorteos held in Mexico and captured via internet or telephone to assign each participant a folio number. After acquiring the participation the participant must be able to consult and print, via internet, a folio constancia and the corresponding rights.

Requirements
  • Issue a folio number on every internet or telephone participation
  • Provide a downloadable folio constancia on demand
RLFJS art. 105

Inspector-witnessed prizes — minimum 1,500 daily UMAs

Article 105 (reformed 16 November 2023) sets at 1,500 daily UMAs the minimum value of any prize that must be handed over in the inspector's presence.

Requirements
  • Identify prizes at or above 1,500 daily UMAs and schedule inspector attendance
  • Document the inspector-witnessed handover
UMA = Unidad de Medida y Actualización; the daily value is set annually by INEGI.
RLFJS art. 106

Free public access to the draw event

Player Rights

Article 106 requires the draw event (except instant draws) to give free and open public access, with that fact stated on the participation tickets.

Requirements
  • Open the draw venue free of charge to the public
  • Print the free-access notice on tickets
RLFJS art. 107

Taxes and delivery costs included in prize value

Player Rights

Article 107 conditions ticket-sale-sorteo authorisations on prizes including taxes, duties and delivery costs.

Requirements
  • Price the prize gross of taxes, duties and delivery costs
  • Reflect the gross-up in the published prize value
RLFJS art. 108

Ticket and printed-advertising content

Bonus & Ads Player Rights

Article 108 requires sorteo tickets and every form of printed advertising to display: ticket-issue volume, nominal ticket value, total issue value, prize count, top-prize value, permit number and validity, draw date, place and mechanic, and the channels and dates for publishing results.

Requirements
  • Show all eight art. 108 data points on every ticket and printed ad
  • Validate ticket artwork against the permit before printing
RLFJS art. 109

Sorteos without ticket sales — promotional purpose only

Bonus & Ads

Article 109 restricts sorteos without ticket sales to natural persons engaged in business activity and mercantile companies, and only to promote their activities.

Requirements
  • Hold sorteos without ticket sales only as promotion of own activities
  • Document the promotional purpose in the application
RLFJS art. 110

Sorteo without ticket sales — maximum ticket count

Bonus & Ads

Article 110 requires the application and permit to state the maximum number of tickets to be distributed, with that information communicated on the participation receipt and in the publicity of the promotion.

Requirements
  • Specify and publish the maximum ticket count
  • Print the cap on the participation receipt
RLFJS art. 111

Permit must state ticket quantity and distribution window

Article 111 requires SEGOB to state in the permit the ticket quantity and the period for their distribution, also shown on the participant receipts. Once that period expires, ticket distribution must stop.

Requirements
  • Stop distributing tickets once the permitted window closes
  • Print quantity and window on the participant receipt
RLFJS art. 112

Instant draws — additional requirements

Player Rights

Article 112 (reformed 16 November 2023) requires the instant-draw applicant, in addition to the Title II Chapter I baseline, to provide the name, address and telephone of the permit-holder's authorised representatives in each state where tickets will be distributed, printed on the ticket alongside the DGJS address, and to comply with SEGOB-issued requirements on ticket production, sale control and validation that ensure confidentiality and verifiability.

Requirements
  • Name authorised state representatives on the ticket
  • Print the DGJS address on the ticket
  • Comply with the SEGOB ticket-production, sale-control and validation requirements
RLFJS art. 113

Sorteos in commercialisation systems — federal authorisation required

Article 113 requires a SEGOB permit and a copy of the federal authority's authorisation for commercialisation-system operations before a sorteo in any lawful commercialisation system can take place.

Requirements
  • Hold the upstream federal commercialisation-system authorisation before applying
  • File its copy with the SEGOB application
RLFJS art. 114

Commercialisation-system permit — duration and per-group notification

Article 114 requires the permit duration to match the time needed to award the good or service, with the number of consumer groups and draws stated. The permit holder must notify SEGOB of each per-group draw on the cadence SEGOB sets.

Requirements
  • Match permit duration to the award timeline
  • Notify SEGOB of each per-group draw on schedule
RLFJS art. 115

Commercialisation-system mechanic — tómbola

Game Design

Article 115 sets the mechanic for commercialisation-system draws: a tómbola containing spheres or similar objects identifying the group participants' numbers, drawn until a winner is determined.

Requirements
  • Use a tómbola with identifying spheres for the draw
  • Document the mechanic in the operating procedure
RLFJS art. 116

Commercialisation permit holder — obligations

Article 116 prohibits the holder from modifying the draw conditions without prior written SEGOB authorisation and obliges it to send SEGOB the consumer group's composition within five working days before the first draw of each group.

Requirements
  • Get prior SEGOB written approval for any change of draw conditions
  • File the consumer group composition at least five working days before the first draw
RLFJS art. 118

Unsold tickets — redraw procedure

Article 118 requires prizes that fall on unsold or undistributed tickets to be redrawn, either at the moment the fact is known during the draw or before the prize-delivery deadline. SEGOB must approve the redraw procedure or permit drawing an excess of numbers for replacement. If a redraw allocates a prize to a ticket that already won, the holder keeps the larger prize and the smaller one is redrawn.

Requirements
  • Build a redraw procedure into the operating manual
  • Apply the larger-prize rule when redraws collide with prior winners
RLFJS art. 119

Unsold-ticket treatment by mechanic

Article 119 governs unsold tickets by draw mechanic: tómbola draws exclude unsold tickets; Lotería Nacional-tied draws use the next Lotería Nacional sorteo for the unsold-ticket prize and the new date is published; number-formation draws re-run until a sold ticket wins; in every case, winning tickets must be inscribed in the winner's name before prize delivery.

Requirements
  • Apply the per-mechanic unsold-ticket procedure consistently
  • Inscribe winning tickets in the winner's name before delivery
RLFJS art. 120

Instant-draw tickets — evidence of prize delivery

Article 120 requires the permit holder to evidence prize delivery to SEGOB for instant-draw tickets that have been used or sold in whole or in part.

Requirements
  • Maintain documented evidence of instant-draw prize delivery
  • File the evidence with SEGOB as required
RLFJS art. 121

Prizes only on clean, properly completed tickets

Player Rights

Article 121 only allows prize delivery where the winning ticket is free of crossings, amendments or other serious alterations that cast doubt on winner identity or ticket authenticity, and has been properly completed with identifying details.

Requirements
  • Reject altered or improperly completed winning tickets
  • Document the basis for any non-payment
RLFJS art. 122

Insubstantial name errors — exception to art. 121

Player Rights

Article 122 excepts insubstantial errors in name or surname where the participant is identifiable via photo ID.

Requirements
  • Allow ID-based identification where name errors are insubstantial
  • Document the identification step in the prize-payment record
RLFJS art. 123

Unclaimed prize — 20-working-day deadline

Player Rights

Article 123 defines an unclaimed prize as any good, service, cash or use-right that has not been claimed by a legitimate entitled person within an unextendable 20-working-day period from the draw date.

Requirements
  • Apply the 20-working-day claim window strictly
  • Document the treatment of unclaimed prizes in line with the permit
RLFJS art. 124

Symbol and number draws — four modalities

Game Design

Article 124 defines symbol-and-number draws as those in which participants receive a set of characters and the winner is the first to complete the sequence drawn. It enumerates four modalities: traditional Mexican lotería symbol draw; number raffle (rifas de números, only in fairs and cockfight palenques); pre-printed number cards (only in salas de sorteos de números); and participant-selected number draw at remote-betting centres.

Requirements
  • Map symbol-and-number formats to one of the four art. 124 modalities
  • Hold rifas de números only in fairs and palenques and pre-printed number cards only in salas de sorteos
Modalities III and IV are the bingo-style perimeter; modality IV is what makes the regulated online-style number draw lawful at remote-betting centres.
RLFJS art. 125

Operational transparency of symbol and number draws

Player Rights Game Design

Article 125 requires permit holders to ensure operational transparency, correct functioning of symbol-and-number draws, and proper dissemination among participants of the drawn symbols and numbers and prize amounts.

Requirements
  • Publicise drawn symbols and numbers to all participants in real time
  • Document operational controls preventing manipulation
RLFJS art. 126

Inspector and permit-holder representative at every event

Article 126 allows a SEGOB inspector and requires a designated permit-holder representative (identified to SEGOB in advance) at every symbol-and-number draw event. The representative must conduct the event strictly per the permit and maintain order.

Requirements
  • Designate and notify SEGOB of the on-site representative
  • Conduct events strictly per the permit
RLFJS art. 127

SEGOB may send inspectors at any time

Article 127 lets SEGOB send one or more inspectors at any time during the permit term to verify the proper conduct of events.

Requirements
  • Be inspection-ready at all times during the permit term
  • Cooperate with unannounced inspector visits
RLFJS art. 128

Symbol and number draws — cash participation before draw

Article 128 obliges participants in symbol-and-number draws to pay in cash and before the draw begins.

Requirements
  • Collect participation in cash ahead of the draw
  • Document the timing in the event procedure
RLFJS art. 129

Used cards and tickets retained by permit holder

Article 129 places used cards, tickets and receipts at the permit holder's disposal at the end of each draw.

Requirements
  • Retain used cards, tickets and receipts at the end of each draw
  • File them in line with the operating manual
RLFJS art. 130

Winner determined by first to announce

Player Rights

Article 130 awards the symbol-and-number draw to the participant who first announces or 'sings' the winning phrase. Where more than one announces simultaneously, prizes are split proportionally.

Requirements
  • Use the first-to-announce rule consistently
  • Apply proportional splits on simultaneous wins
RLFJS art. 131

Failed winner validation — draw resumes

Article 131 requires the draw to resume until a winner is produced if validation reveals faults, errors or inaccuracies on the card, ticket or receipt.

Requirements
  • Resume the draw where a putative winner fails validation
  • Document validation outcomes
RLFJS art. 133

Suspension and refund — 25-minute rule

Player Rights

Article 133 provisionally suspends a draw on installation faults or incidents preventing continuation. If unresolved after 25 minutes, the full price of cards and tickets must be refunded as they are returned to the table. Voluntary withdrawal does not trigger a refund but allows transfer of cards to other participants.

Requirements
  • Refund stakes after a 25-minute unresolved suspension
  • Do not refund voluntary withdrawals, but permit transfer
RLFJS art. 134

Dispute resolution by permit-holder representative

Player Rights

Article 134 requires the permit-holder representative to take note of disputes between organiser and participants and to give the complainant available information, including the permit text, so they can pursue applicable remedies.

Requirements
  • Maintain a documented dispute-resolution procedure
  • Make the permit text available to complainants
RLFJS art. 135

Event irregularities — 5-calendar-day report to SEGOB

Article 135 requires the permit holder (or inspector if present) to report event irregularities to SEGOB within five calendar days of occurrence.

Requirements
  • Report event irregularities to SEGOB within 5 calendar days
  • Keep records supporting each notification
RLFJS art. 136

Traditional Lotería Mexicana symbol draw — venue rules

Article 136 permits the traditional Lotería Mexicana symbol draw at feria installations or local celebrations. No SEGOB permit is needed where the per-person, per-game participation cost does not exceed one daily UMA.

Requirements
  • Hold traditional lotería draws only at ferias or local celebrations
  • Treat the one-daily-UMA threshold as the permit-exemption ceiling
Reformed 16 November 2023 to express the threshold in daily UMAs.
RLFJS art. 138

Control and vigilance — defer to LFJS and applicable rules

Article 138 obliges control and vigilance acts to follow the LFJS and other applicable rules.

Requirements
  • Treat LFJS and supplementary administrative rules as the framework for inspections
3
Theme 3

Online gambling under extended permits

Mexico has no dedicated online gambling statute. The online channel is operated by existing land-based permit holders whose permits were administratively extended to cover internet and mobile distribution under Reglamento art. 85 and the operating manual approved by SEGOB. The regime is a contested grey area that has survived multiple political administrations.

22 standards 13 player-flagged
59%
player-flagged
Regulatory risks this theme addresses
  • Operating an .mx-facing site without an underlying SEGOB land-based permit and an art. 85 extension
  • Marketing in Spanish to Mexican residents from an offshore licence without local presence
  • Assuming the absence of a dedicated statute means the online channel is unregulated
RLFJS art. 85

Authorisation for remote and electronic wagering

Game Design Player Rights

Article 85 of the Reglamento authorises permit holders to receive wagers through electronic, computerised, telecommunications or satellite means, subject to inclusion in the operating manual approved by SEGOB. This is the article on which the entire Mexican online sector rests.

Requirements
  • Request inclusion of remote channels in the SEGOB-approved operating manual
  • Operate online only as an extension of a valid land-based permit
  • Disclose every domain, app and white-label arrangement in the operating manual
Codere, Caliente, Big Bola, PlayCity and a small number of additional permit holders rely on art. 85 to operate the .mx market.
RLFJS art. 85 — operating manual reference

Operating-manual reference to the remote channel

Player Rights Game Design

Article 85 only authorises remote and electronic wagering insofar as the activity is expressly described in the SEGOB-approved Manual Operativo. Any product, domain, mobile app or third-party platform that is not catalogued in the manual is treated as operating outside the perimeter of the permit, even where the holder is otherwise validly permitted.

Requirements
  • Catalogue every domain, app, white-label brand and content provider in the Manual Operativo
  • File a manual amendment before launching any new vertical, supplier or geo-targeted brand
  • Reconcile the live commercial offering against the manual at least quarterly
  • Retain SEGOB acknowledgement letters confirming each manual update
The DGJS treats omissions from the manual as material non-compliance under arts. 151 and 155 of the Reglamento.
RLFJS art. 85 — white-label and skin arrangements

White-label and skin arrangements under the extended permit

Player Rights

Where a permit holder operates the .mx site as a white-label or skin of a foreign brand, the permit holder remains the regulated entity for all SEGOB purposes — player liabilities, AML obligations, advertising compliance and tax. Commercial arrangements with the brand owner do not displace the permit holder's accountability.

Requirements
  • Execute a written intra-group or third-party agreement assigning operational responsibility to the Mexican permit holder
  • Ensure the permit holder is the contracting counterparty for every player in Mexico
  • Hold player funds in accounts controlled by the permit holder
  • Avoid commercial structures that route player payments to the offshore brand owner first
The DGJS has scrutinised skin arrangements where the brand owner is a Curaçao or Costa Rica-licensed operator, treating them as offshore operations if player contracts are not visibly with the permit holder.
RLFJS art. 85 bis

Centralisation of remote operations

Game Design

Permit holders operating remote channels must centralise wagering systems on infrastructure accessible to SEGOB for inspection and audit, including replication of player-account and transaction data.

Requirements
  • Host or mirror systems on infrastructure accessible to SEGOB
  • Provide read access to wagering and account databases for inspection
  • Document data residency and backup arrangements
RLFJS art. 85 bis — Mexican-territory data residency

Mexican-territory transaction-log residency

Player Rights Game Design

Permit holders extending operations to the online channel must centralise the wagering-transaction log and player-account database on infrastructure physically located in Mexican territory, or on infrastructure replicated in real time to a Mexican mirror accessible to SEGOB and the SAT. The duty is the operational backbone of the regulator's audit and tax-verification rights over the .mx channel.

Requirements
  • Place the primary or mirror copy of the transaction log on infrastructure located in Mexico
  • Document the data-residency topology in the Manual Operativo technical annex
  • Provide SEGOB and SAT inspectors with credentialled read access to the Mexican copy
  • Retain logs for at least the LFPIORPI five-year period
The centralisation duty is read together with LFPIORPI art. 18 record-keeping and LIEPS art. 19 tax record-keeping — all three regimes converge on the same database.
DGJS oficio — domain disclosure

Domain and mobile-app disclosure to the DGJS

Player Rights

DGJS oficios require permit holders to notify each URL, sub-domain and mobile-application bundle identifier through which Mexican wagering is offered, together with the underlying licence reference. Unregistered domains are treated as operating outside the permit perimeter.

Requirements
  • Maintain an internal domain register reconciled to DGJS notifications
  • Notify new domains and app bundle IDs before any commercial launch
  • Retire domains formally with DGJS and document take-down evidence
  • Audit DNS, SSL and app-store metadata against the disclosed list quarterly
The DGJS uses the disclosed list as a whitelist when coordinating with payment-service providers on offshore enforcement.
Manual Operativo SEGOB

SEGOB-approved operating manual

Player Rights

The Manual Operativo is the bespoke instrument SEGOB approves for each permit holder. It governs sites authorised, games offered, technical infrastructure, RG measures and remote-channel parameters. Material amendments require prior SEGOB authorisation.

Requirements
  • Maintain a current Manual Operativo on file
  • Request SEGOB approval before launching new games or channels
  • Reconcile every commercial offering against the manual
Manual Operativo — remote technical schedule

Remote technical schedule inside the operating manual

Game Design

The Manual Operativo carries a technical annex for the remote channel detailing the wagering platform, RNG suppliers, payment-service providers, KYC vendors, hosting topology and incident-response procedures. The annex is the working artefact DGJS inspectors review when auditing the .mx offering of a permit holder.

Requirements
  • Maintain a current technical annex listing every platform, supplier and PSP
  • Update the annex within the deadline set by DGJS following any material change
  • Make the annex available on-site and electronically to DGJS inspectors
  • Reflect certification reference numbers (GLI, BMM) inside the annex
Codere, Caliente, PlayCity and Big Bola each maintain a separate technical annex per online brand operated under their permit.
RLFJS art. 12 — registered foreign branch alternative

Registered Mexican branch of a foreign entity as permit holder

Player Rights

The Mexican-legal-personality requirement is also satisfied where a foreign company has established and registered a Mexican branch (sucursal) under the Ley General de Sociedades Mercantiles and the Código de Comercio, with the branch acting as the SEGOB-registered permit holder. The branch must carry its own RFC, statutory representative and registered domicile in Mexico.

Requirements
  • Register the branch with the Registro Público de Comercio before applying
  • Obtain a dedicated RFC for the branch from the SAT
  • Appoint a Mexican statutory representative with full powers
  • File branch financial statements with SEGOB on the same cadence as a Mexican subsidiary
In practice all current online permit holders use a Mexican sociedad anónima rather than a foreign branch — the branch route is recognised in theory but rarely chosen.
RLFJS art. 24

Surety bonds for permit operation

Player Rights

Permit holders must post and maintain surety bonds (fianzas) in favour of the Tesorería de la Federación, calibrated to the permit class and to estimated tax and player liabilities.

Requirements
  • Post the surety bond before commencing operations
  • Maintain the bond at the level required by SEGOB
  • Refresh the bond on permit modification or renewal
DGJS Comunicado offshore

DGJS position on offshore operators

The DGJS has stated publicly that any site accepting wagers from Mexico without an underlying SEGOB permit operates illegally, regardless of any foreign licence. Action against offshore operators relies on payment-channel and ISP cooperation rather than dedicated statutory blocking powers.

Requirements
  • Do not market to Mexican residents without a SEGOB-backed permit
  • Avoid local payment integration without permit-backed authorisation
  • Expect referral to the Fiscalía General de la República for criminal investigation
Statutory ISP blocking comparable to Spain's DGOJ or Colombia's Coljuegos has been proposed in the reform pipeline but is not yet in force.
DGJS Comunicado — Curaçao and Costa Rica position

DGJS position on Curaçao and Costa Rica-licensed sites

Player Rights Affiliate Rules

The DGJS has repeatedly issued public communications stating that sites licensed in Curaçao, Costa Rica, the Isle of Man or other foreign jurisdictions that accept wagers from Mexican residents — including via Spanish-language landing pages, MXN deposits or .mx-targeted advertising — operate illegally under Mexican law regardless of the validity of their foreign licence. Permit holders are warned not to enter commercial relationships with such operators.

Requirements
  • Treat foreign-only-licensed inbound .mx operators as unlicensed in Mexico
  • Decline affiliate, supplier or marketing relationships with Curaçao or Costa Rica-licensed brands targeting Mexico
  • Document the DGJS position in counterparty due-diligence files
  • Refer Mexican-resident player complaints against offshore sites to the Fiscalía General de la República
The DGJS does not yet have statutory ISP-blocking powers comparable to Spain's DGOJ or Colombia's Coljuegos; enforcement against offshore operators relies on payment-channel cooperation, criminal referrals and advertising sanctions.
ISP blocking — statutory authority pending

ISP blocking — statutory authority not yet in force

Unlike Brazil's ANATEL programme, Spain's DGOJ regime under RD 958/2020 or Colombia's Coljuegos blocking power, Mexico has no statutory ISP-blocking authority for unlicensed gambling sites. Proposals to grant SEGOB this power have appeared in successive reform initiatives before the Cámara de Diputados since 2014 but have not been enacted. Enforcement against offshore .mx operators therefore relies on indirect levers — payment-channel pressure, advertising sanctions, criminal referrals and the LFPIORPI vulnerable-activity regime.

Requirements
  • Do not assume URL takedown can be obtained through SEGOB administrative request alone
  • Plan offshore-enforcement programmes around payment-rail and advertising levers
  • Track the legislative pipeline for the long-promised ISP-blocking authority
  • Coordinate with the IFT, the Fiscalía General de la República and the UIF on offshore action
Reform initiatives by Morena, PRI and PAN deputies between 2018 and 2025 have each contained an ISP-blocking authority clause; none has reached promulgation.
Permit holder — Aristocrat México (supplier perimeter)

Aristocrat México and the supplier perimeter

Aristocrat's Mexican arm is the most prominent example of an upstream gaming-equipment supplier whose Mexican-territory business is materially conditioned by the 2023 slot-ban decree. Aristocrat does not itself hold a SEGOB operating permit but supplies machines and content to permit holders and is exposed to amparo outcomes through its customer base.

Requirements
  • Distinguish supplier liability from permit-holder liability — suppliers operate under contract, not under a SEGOB permit
  • Track the amparo umbrella of the customer permit holder before delivering slot product
  • Decommission inventory tied to non-amparoed customers within the phase-out window
  • Coordinate with permit-holder customers on DGJS notifications affecting the supplier
The amparo wave's principal commercial effect on suppliers has been to fragment the Mexican slot-equipment market between amparo-covered customers and non-covered customers.
Permit holder — Big Bola

Big Bola as art. 85 extended-permit holder

Big Bola operates land-based salas across Mexico and a .mx online product under an art. 85 extension of its SEGOB permit. The group is part of the wider permit-holder cohort exposed to the 2023 slot-machine ban and is a regular participant in DGJS industry consultations.

Requirements
  • Recognise Big Bola as a permit-backed art. 85 operator
  • Apply full extended-permit compliance regardless of land-based or online channel
  • Reconcile Big Bola domains against the SEGOB-disclosed list
  • Track residual slot phase-out windows against Big Bola's permit term
Permit holder — Caliente Interactive

Caliente Interactive as art. 85 extended-permit holder

Caliente, through its Mexican operating entities, is the largest .mx-facing online operator and runs sportsbook, casino and live-dealer products under an art. 85 extension of a long-standing land-based permit. The group is the lead amparo plaintiff against the 2023 slot-ban decree and has obtained provisional suspensions in multiple proceedings.

Requirements
  • Treat Caliente as the dominant onshore counterparty for affiliates and content suppliers
  • Verify each Caliente-branded surface against the SEGOB-disclosed domain list
  • Apply full LFPIORPI, IEPS and advertising compliance regardless of amparo coverage
  • Track the status of Caliente's amparo suspensions when assessing slot-product exposure
Caliente's amparo strategy has produced several of the most heavily cited suspension orders in the slot-ban litigation.
Permit holder — Codere México

Codere México as art. 85 extended-permit holder

Codere México operates online sportsbook and casino offerings under an art. 85 extension to a long-standing land-based permit covering centros de apuestas remotas y salas de sorteos de números. The operator is one of the principal amparo plaintiffs against the 2023 slot-machine ban.

Requirements
  • Recognise Codere México as a permit-backed operator on the .mx perimeter
  • Treat any Codere-branded site outside the SEGOB-disclosed domain list as unauthorised
  • Apply LFPIORPI and IEPS obligations notwithstanding amparo coverage
  • Reconcile counterparty due diligence against the publicly disclosed permit reference
Codere has been listed on the public DGJS register of permit holders since the early 2000s under successive resolutions of grant.
Permit holder — Logrand Entertainment

Logrand Entertainment as art. 85 extended-permit holder

Logrand operates the Winpot brand land-based salas and a .mx online product under an art. 85 extension of its SEGOB permit. Logrand is a documented plaintiff in the post-2023 amparo wave.

Requirements
  • Treat Logrand and Winpot-branded surfaces as art. 85 onshore offerings
  • Apply the full extended-permit compliance stack
  • Diary the residual slot phase-out window against Logrand's permit term
  • Track Logrand's amparo status when assessing third-party slot exposure
Permit holder — PlayCity

PlayCity as art. 85 extended-permit holder

PlayCity, controlled by Televisa-Univision affiliates, operates a network of land-based salas and a .mx online site under an art. 85 extension of its SEGOB permit. PlayCity is materially exposed to the 2023 slot-ban decree and has participated in the amparo wave.

Requirements
  • Treat PlayCity-branded online surfaces as art. 85 onshore offerings
  • Apply the full extended-permit compliance stack
  • Diary the residual slot phase-out window against PlayCity's permit term
  • Track PlayCity's amparo status when assessing third-party slot exposure
Conamer / Cofemer Lineamientos sec. 5

Conamer regulatory-impact review applies to gambling regulation

The Ley General de Mejora Regulatoria and the Lineamientos of the Comisión Nacional de Mejora Regulatoria (Conamer, the successor to Cofemer) require federal regulations of general application — including reforms to the LFJS Reglamento — to undergo a Manifestación de Impacto Regulatorio (MIR) before publication in the DOF. Omission of the MIR is a procedural-defect ground that may invalidate the regulation.

Requirements
  • Track the Conamer expediente number for every gambling-regulation reform
  • Cite the LGMR and the Conamer Lineamientos in any procedural-defect amparo
  • Monitor Conamer consultas públicas as an early signal of forthcoming reform
  • Distinguish between MIR-exempt acuerdos and MIR-required reglamentos
The Conamer MIR omission is the principal procedural attack vector in the 2024-2026 amparo wave against the 2023 slot-ban decree.
Ley General de Responsabilidades Administrativas

Anti-corruption discipline over permit-grant decisions

Player Rights

The Ley General de Responsabilidades Administrativas (LGRA) of 2016 — the operative statute of the Sistema Nacional Anticorrupción — disciplines public officials who grant, modify or renew SEGOB permits in violation of the legality, impartiality and objectivity principles. The LGRA also reaches private parties who induce administrative misconduct, including through facilitation payments, undue benefits or collusion.

Requirements
  • Maintain a written anti-bribery policy covering interactions with SEGOB and DGJS officials
  • Prohibit gifts, hospitality or facilitation payments to public officials beyond statutory de minimis
  • Document every contact with permit-granting officials in the compliance register
  • Train regulatory-affairs staff on LGRA private-party offences and self-reporting incentives
Permit grants and renewals during politically contested periods have repeatedly been the subject of LGRA-based denuncias before the Auditoría Superior de la Federación.
4
Theme 4

The 2023 slot-machine ban + amparo wave

On 23 November 2023 President López Obrador published a decree reforming the Reglamento to prohibit electronic slot machines (máquinas tragamonedas) in all SEGOB-permitted establishments, with a phase-out timeline. Permit holders responded with a wave of amparo proceedings that remain unresolved into the Sheinbaum administration.

18 standards 13 player-flagged
72%
player-flagged
Regulatory risks this theme addresses
  • Continuing to operate prohibited machines outside an amparo umbrella
  • Relying on an amparo granted to a different permit holder
  • Assuming the ban will be repealed before the phase-out date
Decreto 23-Nov-2023 art. 1

Prohibition of electronic slot machines

Game Design Player Rights

The decree reforms Reglamento arts. 12, 20 and 85 to expressly prohibit the operation, exhibition, distribution and import of máquinas tragamonedas in establishments authorised under the LFJS. The prohibition extends to electronic, electromechanical and software-based slot equivalents.

Requirements
  • Cease procurement of new slot machines from the decree's effective date
  • Plan inventory write-down and replacement product mix
  • Disclose the prohibition's impact in financial statements
Decreto 17-Nov-2023 art. 1 — RLFJS art. 12 reform

Broadened slot-machine definition (RLFJS art. 12 reform)

Game Design

The decree reforms Reglamento art. 12 to introduce a broadened definition of máquinas tragamonedas that captures electromechanical, electronic and software-based wagering machines regardless of physical form factor, including server-based gaming terminals. The definition closes interpretive workarounds that previously placed certain electronic devices outside the reach of the prohibition.

Requirements
  • Apply the broadened definition to every wagering device in the inventory
  • Re-classify server-based gaming terminals against the new definition
  • Document the definitional analysis for each device class in the compliance file
  • Avoid reliance on pre-decree industry guidance on the meaning of máquina tragamonedas
The breadth of the new definition is itself a substantive amparo argument — quejosos contend the definition is so wide it captures equipment never previously regulated as a slot.
Decreto 23-Nov-2023 art. 2

Five-year phase-out for installed inventory

Player Rights

Article 2 of the decree gives permit holders a transitional period of up to five years to remove all installed slot machines from authorised establishments, calibrated to the residual term of the underlying permit.

Requirements
  • Build a decommissioning plan for every installed machine
  • Track removal against the per-establishment deadline
  • Document removal evidence for DGJS inspection
The five-year ceiling has been the principal target of amparo arguments asserting acquired rights and disproportionate impact.
Decreto 17-Nov-2023 — 15-year permit cap (RLFJS art. 27 reform)

Reduction of permit term to 15 years non-extendable

Player Rights

The decree reforms Reglamento art. 27 to reduce the maximum term of new SEGOB permits from 25 years to 15 years and to make the new shorter term non-extendable, ending the renewability that had supported the long-cycle investment economics of the sector. Existing permits granted on 25-year terms remain in force only for their residual original term.

Requirements
  • Treat any new permit granted after the decree as having a 15-year non-extendable horizon
  • Re-model long-cycle investment cases against the shorter horizon
  • Diary residual original-term expiries for all pre-decree 25-year permits
  • Plan succession or new-permit strategies inside the 15-year boundary
The non-extendability is a structural break with the renewability principle that had been the bedrock of the Mexican permit economy since the 2004 Reglamento.
Decreto 17-Nov-2023 — DOF publication identity

DOF publication identity of the slot-ban decree

The slot-machine prohibition was enacted by the Decreto por el que se reforman, adicionan y derogan diversas disposiciones del Reglamento de la Ley Federal de Juegos y Sorteos, signed by President Andrés Manuel López Obrador and published in the Diario Oficial de la Federación on 17 November 2023, taking general effect from 23 November 2023. The instrument is the operative DOF citation for every downstream rule and every amparo proceeding.

Requirements
  • Cite the decree by its full DOF heading and 17 November 2023 publication date
  • Distinguish the 17 November publication date from the 23 November general effective date
  • Retain the official DOF text as the canonical source — not press releases or summaries
  • Track the consolidated Reglamento text as amended by the decree
Public commentary frequently mislabels the decree as the '23 November decree' — the strict DOF publication date is 17 November 2023.
Decreto 17-Nov-2023 — mandatory phase-out trajectory

Mandatory five-year phase-out trajectory for installed slots

Player Rights

Installed slot inventory under existing permits must be progressively removed across a phase-out trajectory capped at five years from the decree's effective date, calibrated per establishment to the residual term of the underlying permit. The trajectory is mandatory, not aspirational — DGJS is empowered to verify decommissioning against the per-establishment schedule.

Requirements
  • Submit a per-establishment decommissioning schedule to DGJS
  • Maintain rolling evidence of inventory removal, transfer or destruction
  • Coordinate with suppliers on equipment buy-back or international relocation
  • Reflect the phase-out in financial statements and asset-impairment testing
The five-year ceiling is the principal target of the substantive amparo arguments on acquired rights and disproportionate impact.
Decreto 17-Nov-2023 — prohibition on new slot operations

Prohibition on any new slot-machine operations

Game Design Player Rights

The decree prohibits SEGOB from authorising any new operations involving máquinas tragamonedas from the date of effect — including new permit grants, manual amendments adding slot product to existing permits, or expansion of slot inventory at existing authorised establishments. The bar is absolute and not subject to discretionary waiver.

Requirements
  • Cease all applications for new slot product to be added to the Manual Operativo
  • Reject any internal proposal to expand installed-base slot inventory
  • Confine all installed slot operations to the residual phase-out window
  • Document the prohibition's reach in updated internal compliance manuals
Pipeline products that had received DGJS technical certification but not yet operational authorisation are caught by the prohibition.
Decreto 17-Nov-2023 — transitional rules detail

Transitional rules — vacatio legis, grandfathering boundary and reporting

The decree's articulos transitorios fix a short vacatio legis between publication on 17 November 2023 and general effect on 23 November 2023, preserve the underlying permits as unaffected, and require permit holders to submit a baseline inventory of installed slot machines to DGJS within a defined initial window. The transitorios are themselves a discrete amparo target where they affect acquired rights.

Requirements
  • File the baseline inventory return within the transitorio-prescribed window
  • Treat the vacatio legis as the cut-off for newly authorised commissioning
  • Preserve evidence of pre-effective-date operational status of each machine
  • Treat the transitorios as separately amparable from the substantive articles
Several amparos challenge the substantive prohibition and the transitorios as separate but cumulative violations.
Decreto 23-Nov-2023 transitorios

Transitional articles and existing permits

The transitional articles preserve the validity of the underlying permits while annulling the slot-machine exception that the prior 2004 Reglamento had inferred. They condition any continuing slot operation on the residual phase-out period.

Requirements
  • Treat the underlying permit as unaffected by the slot ban
  • Document the residual phase-out window per establishment
  • Refresh internal compliance manuals to reflect the new prohibition
Amparo Codere 2024

Permit-holder amparo proceedings

Player Rights

Codere, Caliente, Logrand and other permit holders filed amparo indirecto proceedings during late 2023 and 2024 alleging violation of acquired rights, retroactivity, disproportionate impact and lack of regulatory-impact assessment (MIR/Conamer). Suspensions have been granted in several proceedings allowing continued operation pending resolution.

Requirements
  • Verify whether an amparo umbrella covers each operating establishment
  • Monitor the status of suspension orders before each operating day
  • Distinguish suspensions in your favour from suspensions granted to third parties
Suspensions are personal to the quejoso and do not automatically extend to other permit holders.
Amparo wave 2024-2026 — volume and posture

Amparo wave 2024-2026 — volume and procedural posture

Player Rights

Between late 2023 and 2026 approximately 37 amparo indirecto proceedings have been filed against the 2023 slot-ban decree by permit holders, slot-machine suppliers and associated operating entities. The filings are concentrated before federal district courts in Mexico City and Nuevo León, with proceedings at various stages between provisional suspension, definitive suspension and substantive resolution.

Requirements
  • Maintain a counter-party register of which permit holders are amparo plaintiffs and which are not
  • Distinguish provisional suspensions (resolved at admission) from definitive suspensions (resolved on incidente de suspensión)
  • Do not extrapolate amparo coverage from one quejoso to another
  • Monitor docket movement in the federal district courts of Mexico City and Nuevo León
The ~37 figure aggregates filings tracked by industry press into 2026; the true count is fluid as new amparos are filed and others are dismissed.
Amparo — Conamer MIR attack vector

Conamer MIR procedural-defect attack vector

Player Rights

The leading procedural argument in the slot-ban amparos is that SEGOB failed to submit the draft decree to the Comisión Nacional de Mejora Regulatoria for the mandatory Manifestación de Impacto Regulatorio prior to DOF publication, in breach of the Ley General de Mejora Regulatoria. If sustained at the SCJN, the procedural-defect ground would invalidate the decree without the Court having to reach the substantive acquired-rights questions.

Requirements
  • Preserve the documentary record of Conamer expediente status as of the decree's signing
  • Plead the LGMR MIR omission as a standalone amparo ground
  • Distinguish MIR exemption claims invoked by SEGOB from the strict statutory grounds
  • Coordinate with co-quejosos to maintain a consistent procedural-defect pleading
A finding for the quejosos on the procedural-defect ground would invalidate the slot-ban without resolving any substantive question on slot machines.
Amparo — Sheinbaum administration posture

Sheinbaum-administration posture on the slot-ban litigation

The Sheinbaum administration, which took office in October 2024, has maintained the slot-ban decree without repeal or substantial amendment, defending it in the amparo proceedings through SEGOB and the Consejería Jurídica del Ejecutivo. The political posture is continuity with the AMLO-era prohibition, narrowing the realistic universe of outcomes to judicial invalidation, judicial confirmation, or a future federal-statute reform.

Requirements
  • Treat the decree as politically entrenched for the duration of the Sheinbaum term
  • Plan amparo outcomes as the principal lever for sector relief
  • Track the Sheinbaum-era federal-gambling-law initiative as the secondary lever
  • Monitor DGJS leadership appointments as signals of any policy softening
An eventual Sheinbaum-era federal gambling statute could supersede the entire 1947/2004/2023 stack — but no published draft has yet been advanced to the floor of the Cámara de Diputados.
Amparo — Suprema Corte review pending

Suprema Corte review of the slot-ban amparos pending

Player Rights

As of 2026 several of the slot-ban amparos have reached the recurso de revisión stage and are working their way toward the Suprema Corte de Justicia de la Nación, which will resolve the substantive constitutional questions on a uniform basis. A SCJN ruling against the decree, in particular on the Conamer MIR procedural-defect ground, could collapse the prohibition for the entire sector; a ruling upholding the decree would terminate operating-day cover for all quejosos at once.

Requirements
  • Track each amparo's revision docket and the SCJN list of pending matters
  • Maintain scenario plans for full invalidation and full upholding of the decree
  • Coordinate with industry counsel on attracción requests to consolidate the cases
  • Reflect SCJN review timing in board-level slot-product exposure reporting
An eventual declaratoria general de inconstitucionalidad would be the most legally significant outcome — generalising the slot-ban repeal across all permit holders.
Amparo — acquired-rights and retroactivity arguments

Acquired-rights and retroactivity arguments

Player Rights

On the substantive side, quejosos argue that the slot-ban decree retroactively impairs derechos adquiridos under permits granted under the prior 2004 Reglamento regime — including the 25-year renewable term and the implicit slot-machine authorisation — in violation of art. 14 of the Constitution. The disproportionate-impact argument layers on top, contending that the five-year phase-out is insufficient to amortise legitimately acquired equipment and infrastructure.

Requirements
  • Document the original permit terms and the slot-product authorisation chain
  • Quantify the impairment of acquired rights for damages and amparo argumentation
  • Plead art. 14 retroactivity together with the proportionality argument
  • Preserve evidence of legitimate investment expectations at permit grant
Mexican courts have historically been receptive to art. 14 retroactivity arguments in the regulated-permit context, particularly where investment-backed expectations are well documented.
Amparo — personal-quejoso suspensions

Personal-quejoso nature of amparo suspensions

Player Rights

Under the relatividad de las sentencias principle codified in art. 73 of the Ley de Amparo, amparo suspensions and judgments protect only the named quejoso. A suspension granted to Codere does not extend to Caliente, PlayCity or any non-party permit holder, and cannot be invoked by a supplier whose customer is not the named quejoso.

Requirements
  • Verify the named quejoso in every suspension order relied upon
  • Refuse to operate slot product under a third-party amparo umbrella
  • Confirm supplier-side amparo coverage matches the customer-side coverage
  • Document the relatividad analysis in the compliance file
A future Suprema Corte unifying jurisprudence may issue a declaratoria general de inconstitucionalidad that would extend beyond named quejosos — but only on the conditions set in arts. 231-235 of the Ley de Amparo.
Amparo — provisional vs definitive suspensions

Provisional vs definitive suspension distinctions

Player Rights

Under the Ley de Amparo, a provisional suspension is granted with the auto admisorio and runs only until the incidente de suspensión is resolved; the definitive suspension, granted after contradictorio, runs until the substantive amparo is resolved. Operators relying on a slot-ban suspension must distinguish which class of suspension covers each operating day, as the legal basis for continuing operations differs.

Requirements
  • Record per-establishment which class of suspension is in force on each operating day
  • Refresh the suspension-status check before any change to slot-floor configuration
  • Reflect suspension class in management reporting to the board
  • Plan for collapse of provisional suspension into denial of definitive suspension
A denied definitive suspension forces immediate decommissioning of any slot inventory previously operated under the provisional cover.
Conamer MIR omisión

Regulatory-impact assessment challenge

A central amparo argument is that SEGOB failed to submit the decree to the Comisión Nacional de Mejora Regulatoria (Conamer) for the mandatory Manifestación de Impacto Regulatorio. The procedural defect, if confirmed, would invalidate the decree.

Requirements
  • Track judicial findings on the MIR procedural defect
  • Prepare for divergent outcomes across circuits
  • Plan for the possibility of a Suprema Corte unifying ruling
5
Theme 5

AML / LFPIORPI casino regime

The Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI) of 2012 designates casinos and gambling operators as actividades vulnerables. The Servicio de Administración Tributaria (SAT) administers the regime and the Unidad de Inteligencia Financiera (UIF) receives suspicious-activity reports.

75 standards 49 player-flagged
65%
player-flagged
Regulatory risks this theme addresses
  • Failing to register the activity with the SAT vulnerable-activity portal
  • Missing a threshold transaction or aggregated-transaction report
  • Operating without an appointed Oficial de Cumplimiento
LFPIORPI art. 17 frac. I

Casinos as covered vulnerable activity

Player Rights

Fraction I of article 17 designates the practice of games with wagers, contests and draws — including those operated under SEGOB permits — as a vulnerable activity under the law, regardless of the legal vehicle through which they are operated.

Requirements
  • Confirm coverage from the day operations begin
  • Register the activity with the SAT portal antes de la primera operación
  • Apply the LFPIORPI regime to every permit holder, branch and channel
The drafting of fraction I has been amended repeatedly; the current consolidated text covers electronic and remote channels.
LFPIORPI art. 18

Customer due diligence obligations

Player Rights

Article 18 requires identification of every client, beneficial owner and counterparty above the statutory threshold, retention of documentation for at least five years, and refusal to operate where identification is impossible.

Requirements
  • Identify every player above the identification threshold
  • Capture and preserve identification documents for five years
  • Refuse or suspend operations where CDD cannot be completed
LFPIORPI art. 17 — threshold

Identification and reporting thresholds in UMA

Player Rights

The casino-specific identification threshold is 325 UMA and the reporting threshold is 645 UMA per transaction or per series of related transactions in a six-month window. Cash transactions above 10,025 UMA trigger additional reporting and prohibition rules.

Requirements
  • Calibrate identification triggers to the current UMA value
  • Aggregate related transactions in a rolling six-month window
  • Apply the cash-transaction prohibitions above 10,025 UMA
UMA values are updated annually by INEGI and published in the DOF.
LFPIORPI art. 32

Cash-transaction prohibitions

Player Rights

Article 32 prohibits the receipt of cash for certain high-value transactions, including the payment of prizes, above thresholds set in MXN-denominated UMA equivalents. Payment must be channelled through the financial system.

Requirements
  • Pay high-value prizes via traceable bank channels
  • Refuse cash for transactions above the article 32 thresholds
  • Document electronic-payment evidence for SAT inspection
Reglas SAT LFPIORPI

Reglas de Carácter General SAT — reporting mechanics

The SAT Reglas de Carácter General set the technical mechanics for vulnerable-activity reporting: monthly periodicity, format, electronic signature (e.firma) requirements and the dedicated SAT portal at sppld.sat.gob.mx.

Requirements
  • File monthly reports through the SAT portal even where there is no activity
  • Maintain a valid e.firma for the reporting officer
  • Calendar negative reports as nil filings
UIF Oficial de Cumplimiento

Compliance officer and internal manual

Player Rights

Permit holders must appoint an Oficial de Cumplimiento, adopt a formal AML manual, conduct annual staff training and submit to independent audit. The appointed officer is the named counterparty for SAT and UIF.

Requirements
  • Appoint an Oficial de Cumplimiento and notify the SAT
  • Adopt and version-control a written AML manual
  • Conduct annual training and document attendance
  • Submit to independent external audit
UIF STR reporting

Suspicious-transaction reporting to UIF

Player Rights

Suspicious or unusual transactions must be reported to the UIF through the SAT relay, in addition to ordinary threshold reports. Tipping off the client is prohibited and personal to the compliance officer.

Requirements
  • Maintain a written STR triage and escalation procedure
  • File STRs without delay through the SAT relay
  • Prohibit any tipping-off of the reported client
LFPIORPI art. 17 frac. XII

Casino and gaming vulnerable-activity perimeter

Player Rights

Fraction XII of article 17 expressly enumerates the practice of games with wagers, contests and draws — operated under SEGOB permits or by any other legal vehicle, in physical premises or through electronic, computerised or telecommunications means — as a vulnerable activity. The fraction captures the operator, the brand and every cashier touchpoint, irrespective of corporate structure.

Requirements
  • Treat each permit holder, branch and remote channel as a single covered person
  • Capture white-label and B2B counterparties inside the AML programme perimeter
  • Re-baseline coverage after every corporate reorganisation or M&A event
Fraction XII is the perimeter clause the SAT cites first in every audit — confirm the registration record matches the current operating footprint.
LFPIORPI art. 18 frac. I

Client and user identification file

Player Rights

Fraction I of article 18 obliges every covered person to identify their clients and users and to integrate an identification file containing the official identification document, CURP, RFC where applicable, address proof and a recent photograph for sustained-relationship clients. The file must be kept in physical or electronic form for the entire life of the relationship plus the statutory retention period.

Requirements
  • Capture government-issued ID, CURP, RFC and address proof for every covered client
  • Maintain a verifiable selfie or in-person photograph for ongoing relationships
  • Refresh identification data on material change of circumstances
  • Use the SAT-approved formats for the identification file
INE, passport, cédula profesional and matrícula consular are the most commonly accepted government IDs.
LFPIORPI art. 18 frac. III

Beneficial-owner identification

Player Rights

Fraction III requires covered persons to request information from the client to determine whether the client is acting on its own behalf or on behalf of a beneficial owner (dueño beneficiario). Where a beneficial owner exists, the same identification standard applies to that person.

Requirements
  • Ask every client whether they act on behalf of a third party
  • Identify the beneficial owner to the same standard as the direct client
  • Document refusal to disclose and treat it as a CDD-impossible event
  • Update the beneficial-owner record whenever control or economic interest changes
The 2024 reform tightened the practical evidentiary standard — passive declarations alone are no longer sufficient.
LFPIORPI art. 18 frac. IV

Business-relationship purpose and nature

Player Rights

Fraction IV requires covered persons to ask the client the intended purpose and nature of the business relationship and to record the answer in the client file. For gaming, this includes expected wagering pattern, source of funds and intended channels of play.

Requirements
  • Capture purpose-of-relationship data at onboarding
  • Record stated source of funds and source of wealth
  • Match observed activity against the declared profile in transaction monitoring
  • Re-confirm the purpose at periodic CDD refresh
Mismatch between declared profile and observed wagering is the most common STR trigger in Mexican casino audits.
LFPIORPI art. 18 frac. V

Internal AML policies and criteria

Player Rights

Fraction V obliges every covered person to adopt internal criteria, measures and procedures to comply with the law and its secondary regulations. For gaming operators this crystallises into the documented AML manual covering customer acceptance, risk classification, monitoring, reporting and recordkeeping.

Requirements
  • Adopt a written AML manual covering acceptance, monitoring, reporting and retention
  • Operate a risk-classification model and document each client tier
  • Review and version-update the manual at least annually
  • Make the manual available to SAT and UIF inspectors on first request
LFPIORPI art. 18 frac. VI

Politically exposed persons and enhanced due diligence

RG Critical Player Rights

Fraction VI requires enhanced due diligence on persons considered politically exposed (personas políticamente expuestas, PEP), their close relatives and close associates. Senior management approval is required before opening or continuing the relationship.

Requirements
  • Screen every client and beneficial owner against domestic and foreign PEP lists
  • Apply enhanced source-of-funds and source-of-wealth checks for PEP relationships
  • Obtain documented senior-management approval to onboard or continue a PEP
  • Refresh PEP screening on a defined cycle for sustained relationships
The SAT publishes guidance treating PEP status as persistent for at least one year after the person ceases the public function.
LFPIORPI art. 19

Five-year recordkeeping obligation

Player Rights

Article 19 requires covered persons to retain identification files, supporting documents and transaction records for at least five years counted from the date of the act or operation. Retention must remain valid even if the relationship ends earlier.

Requirements
  • Retain identification, transaction and reporting records for a minimum of five years
  • Preserve electronic and physical records to a tamper-evident standard
  • Index records to allow retrieval on SAT request within the audit deadline
  • Continue retention after account closure for the full five-year clock
Where tax law or other regulation requires longer retention, the longer period prevails.
LFPIORPI art. 20

Aviso of vulnerable activities to the SAT

Player Rights

Article 20 requires covered persons to file an aviso (notice) of vulnerable activities to the SAT no later than the seventeenth day of the month immediately following that in which the act or operation took place. Filings are made through the SAT vulnerable-activity portal (SPPLD).

Requirements
  • Calendar the seventeenth-of-the-month deadline as a hard control
  • File the aviso through the SPPLD portal with valid e.firma
  • File a nil report where no notifiable operation occurred in the month
  • Retain the SPPLD acknowledgement (acuse) as evidence of compliance
Missing the seventeenth-day deadline triggers an administrative fine under art. 53 and can escalate to suspension of the SPPLD account.
LFPIORPI art. 21

Aviso content and required data points

Player Rights

Article 21 sets out the minimum content of every aviso: general data on the covered person, identification data on the client and beneficial owner, description of the act or operation, amount and means of payment, and the date. The SAT secondary rules specify the structured XML schema.

Requirements
  • Capture all article 21 data points at the time of the underlying operation
  • Use the SAT-published XML schema and validate before submission
  • Reconcile aviso content against the underlying transaction ledger
  • Correct an aviso through the supplementary-filing route within the deadline
Schema mismatches are the single most common rejection reason on the SPPLD portal — pre-validate every batch.
LFPIORPI art. 22

Prohibition on tipping off the client

RG Critical

Article 22 prohibits covered persons, their officers, directors and employees from disclosing to the client or to any third party that an aviso, an STR or an unusual-operation notice has been filed. The duty of confidentiality binds the compliance officer personally and survives termination of employment.

Requirements
  • Train all customer-facing staff on the tipping-off prohibition
  • Restrict aviso and STR knowledge to a documented need-to-know list
  • Route any client query about reporting through the compliance officer
  • Preserve confidentiality for the full statutory limitation period
Tipping off carries criminal exposure under arts. 400 and 400-bis of the Código Penal Federal in addition to LFPIORPI administrative sanctions.
Reglamento LFPIORPI art. 11

Customer acceptance and onboarding data

Player Rights

Article 11 of the Reglamento LFPIORPI specifies the data and supporting documentation that must be obtained at onboarding for every client subject to identification, including unique identifiers (CURP, RFC, foreign tax-ID equivalents), contact information, occupation and economic activity. The covered person must verify the information against an authoritative source where reasonably available.

Requirements
  • Collect CURP, RFC or foreign tax ID for every onboarded client
  • Verify occupation and economic activity against an authoritative source
  • Capture telephone, email and full address with proof of residency
  • Block account activation where mandatory onboarding data is incomplete
For non-residents, passport plus consular registration or FMM is the accepted substitute for CURP.
Reglamento LFPIORPI art. 12

Simplified and standard CDD tiers

Player Rights

Article 12 of the Reglamento, read with the RCG, establishes tiered CDD: simplified for occasional clients below the identification threshold, standard for clients above the identification threshold (325 UMA per operation) and ongoing relationships, and enhanced for higher-risk profiles. Each tier specifies the minimum identification data set.

Requirements
  • Apply simplified CDD only below the 325-UMA identification threshold
  • Trigger standard CDD on the first operation above 325 UMA or on the opening of a sustained relationship
  • Document the tier assigned to every client and the rationale
  • Re-tier the client when behaviour or risk indicators change
Aggregation across a six-month window can push a series of sub-threshold operations into the standard tier.
Reglamento LFPIORPI art. 14

Aviso electronic format and supplementary filings

Article 14 of the Reglamento confirms that avisos must be filed electronically using the formats and schemas published by the SAT, signed with e.firma. Supplementary or corrective filings are permitted within the time limits set in the RCG and must reference the original aviso.

Requirements
  • Maintain a current e.firma and renewal calendar for the compliance officer
  • Submit avisos only through the SPPLD portal — manual filings are not accepted
  • File supplementary avisos to correct errors within the RCG deadline
  • Cross-reference each supplementary filing to the original aviso identifier
Reglamento LFPIORPI art. 15

Risk-based approach and client classification

Player Rights

Article 15 instructs covered persons to design and apply a risk-based approach, classifying clients by ML/TF risk taking into account jurisdiction, product, channel, transaction profile and the presence of PEP or high-risk indicators. The model must be documented, tested and revised periodically.

Requirements
  • Adopt a documented client risk-classification model
  • Score every client at onboarding and at periodic refresh
  • Map high-risk classifications to enhanced due diligence and monitoring
  • Validate the model annually against observed STR conversion rates
FATF Recommendation 1 risk-based approach principles inform the SAT inspection methodology.
RCG LFPIORPI regla 12

CURP and RFC verification at onboarding

Player Rights

Rule 12 of the RCG requires covered persons in the gaming sector to verify CURP against the Renapo registry and RFC against the SAT registry where reasonably accessible. The verification result must be archived as part of the identification file.

Requirements
  • Verify CURP via Renapo at onboarding and archive the verification log
  • Verify RFC via the SAT validation service for resident clients
  • Document any verification failure and the residual decision to onboard
  • Re-run verification on material identity changes
RCG LFPIORPI regla 21

Oficial de Cumplimiento designation and SAT notification

Player Rights

Rule 21 requires covered persons that are legal entities to designate an Oficial de Cumplimiento and to notify the SAT through the SPPLD portal within fifteen business days of designation. The officer must have sufficient seniority, autonomy and resources to discharge the AML programme.

Requirements
  • Designate the Oficial de Cumplimiento by formal board or management act
  • Notify the SAT through SPPLD within fifteen business days of designation
  • Re-notify on every change of officer or contact data
  • Document the officer's seniority, independence and reporting line
Failure to register or to refresh the designation invalidates SPPLD filings made under the prior officer.
RCG LFPIORPI regla 22

Annual AML training programme

Player Rights

Rule 22 of the RCG requires covered persons to deliver annual AML training to all personnel involved in the vulnerable activity, with content tailored to the role. Records of attendance, materials and assessment results must be retained for the full five-year statutory window.

Requirements
  • Deliver role-tailored AML training at least annually
  • Maintain attendance logs and assessment scores per employee
  • Refresh content to reflect new typologies and rule changes
  • Include cashier, floor, surveillance and compliance roles in scope
RCG LFPIORPI regla 23

Independent AML audit

Player Rights

Rule 23 obliges covered persons to subject the AML programme to an annual independent audit covering the design and operating effectiveness of identification, monitoring, reporting and recordkeeping controls. Audit reports must be retained and made available to the SAT.

Requirements
  • Engage an independent auditor annually for the AML programme
  • Cover identification, monitoring, reporting and retention controls in scope
  • Track audit findings to remediation in a documented action plan
  • Make the audit report and remediation evidence available to SAT inspectors
RCG LFPIORPI regla 28

24-hour aviso for unusual operations

RG Critical Player Rights

Rule 28 of the RCG requires that operations identified as unusual or concerning (operaciones inusuales o preocupantes) be reported through a dedicated 24-hour aviso channel, separate from the periodic monthly aviso. The 24-hour clock starts when the compliance officer concludes the operation meets the unusual threshold.

Requirements
  • Operate a 24-hour STR pathway distinct from monthly avisos
  • Document the moment the unusual classification is reached
  • Escalate to the Oficial de Cumplimiento for filing within the 24-hour window
  • Preserve underlying evidence and reasoning for SAT and UIF review
The 24-hour clock is computed in business hours per the SAT operating calendar.
Reforma LFPIORPI 2024 — UBO

Expanded beneficial-ownership regime

Player Rights

The 2024 reform package tightened the beneficial-ownership regime by lowering the percentage threshold for control attribution, requiring active verification rather than passive declaration, and aligning the definition with the Código Fiscal de la Federación arts. 32-B Ter, Quáter and Quinquies. Gaming covered persons must hold and refresh the UBO record on demand from the SAT.

Requirements
  • Adopt the CFF arts. 32-B Ter–Quinquies UBO definition in onboarding policy
  • Lower the control-attribution threshold in line with the reform
  • Actively verify UBO data rather than rely on client declarations alone
  • Refresh the UBO record on any change of control or economic interest
SAT misceláneas fiscales 2024 carry sector-specific UBO guidance for vulnerable activities.
Reforma LFPIORPI 2024 — activos virtuales

Virtual-asset coverage and crypto-funded play

RG Critical Player Rights

The 2024 reform expanded coverage to include operations involving virtual assets (activos virtuales) and reaffirmed the LFPIORPI perimeter over crypto-funded gambling activity. Covered persons accepting crypto, stablecoin or token-denominated deposits must apply identification, monitoring and reporting on the on-ramp event.

Requirements
  • Identify the player on every crypto on-ramp into a gambling account
  • Capture wallet addresses and on-chain transaction identifiers in the operation record
  • Apply enhanced due diligence to mixers, privacy coins and high-risk chains
  • Report virtual-asset-funded operations through the aviso framework
Banxico circular 4/2019 continues to bar regulated financial institutions from operating in virtual assets — gaming acceptance therefore typically routes through third-party processors.
UIF SPPLD portal

SPPLD portal operational requirements

The Sistema del Portal en Internet para la Prevención de Lavado de Dinero (SPPLD) at sppld.sat.gob.mx is the sole electronic gateway for vulnerable-activity registration, monthly avisos, 24-hour STRs and supplementary filings. Access requires an active SAT e.firma issued to the Oficial de Cumplimiento.

Requirements
  • Hold a live e.firma for the registered Oficial de Cumplimiento at all times
  • Maintain a backup officer with portal access to ensure continuity
  • Archive every SPPLD acuse with timestamp and folio number
  • Monitor portal-downtime announcements and use the SAT contingency channel
UIF freezing list — bloqueo de cuentas

UIF blocked-persons list (Lista de Personas Bloqueadas)

RG Critical

The UIF maintains the Lista de Personas Bloqueadas under article 115 of the Ley de Instituciones de Crédito and parallel statutes. Although directly addressed at financial institutions, vulnerable-activity covered persons must screen clients and counterparties against the list as a matter of due-diligence prudence and to identify persons subject to international sanctions or domestic freezing orders.

Requirements
  • Screen clients and beneficial owners against the LPB on a continuous basis
  • Block onboarding or transactional flow on any positive match
  • Escalate matches to the Oficial de Cumplimiento for STR and UIF coordination
  • Document the screening engine, threshold and false-positive workflow
Inclusion on the LPB is administrative and may pre-empt judicial freezing action.
LFPIORPI art. 38

SAT as supervisory authority

Article 38 designates the Servicio de Administración Tributaria as the authority responsible for verifying compliance with the LFPIORPI by covered vulnerable activities. The SAT exercises desk-based and on-site inspection powers and may require production of identification files, transaction records and avisos.

Requirements
  • Treat the SAT as the principal AML supervisor, not the UIF, for casino activity
  • Maintain a documented inspection-readiness pack at every authorised site
  • Cooperate with desk requests within the SAT-specified deadline
  • Track inspection findings to remediation under documented governance
LFPIORPI art. 53

Administrative fines for AML breaches

RG Critical

Article 53 establishes the administrative-fine ladder for breaches of the LFPIORPI, scaled in UMA. Late filing of an aviso triggers a baseline fine; failure to identify, to report or to keep records can reach the highest band of up to 65,000 UMA per breach, and is computed per operation.

Requirements
  • Recognise that LFPIORPI fines are calculated per operation, not per filing
  • Quantify potential exposure in the AML risk register using current UMA values
  • Use the supplementary-aviso route to mitigate late-filing penalties
  • Document every breach analysis and remediation step contemporaneously
Article 54 adds a separate fine where the breach is committed by the Oficial de Cumplimiento personally.
CFF art. 9 — internación de divisas

Cross-border cash declaration above USD 10,000

Player Rights

Article 9 of the Código Fiscal de la Federación and the supporting customs rules require declaration to the SAT-Aduanas of cash, cheques, money orders or monetary instruments crossing the Mexican border in amounts exceeding USD 10,000 equivalent. Casino marketing programmes that arrange high-roller travel must brief players on the declaration obligation and document any incoming cash event into the player account.

Requirements
  • Inform high-roller and junket clients of the USD 10,000 declaration threshold
  • Document the source-of-cash narrative for any deposit funded by cross-border currency movement
  • Refuse to act as conduit for undeclared cross-border cash
  • Coordinate with the Oficial de Cumplimiento on any associated aviso obligation
Banxico FX-reporting rules and SAT-Aduanas declarations operate in parallel — the duty is on the traveller, but the casino's CDD must surface the event.
CNBV — intersección financiera

CNBV intersect for casino financial services

RG Critical

Where a casino offers services that constitute financial intermediation — stored-value cards, e-wallets, money-remittance functionality or extension of credit at scale — the Comisión Nacional Bancaria y de Valores' AML regime under art. 115 of the Ley de Instituciones de Crédito and the Disposiciones de Carácter General applicable to non-bank financial entities may apply in parallel to the LFPIORPI casino regime.

Requirements
  • Map each ancillary financial product against the CNBV non-bank regime
  • Channel money-remittance and e-wallet activity through a properly licensed entity
  • Cap credit extension within the boundaries of permitted casino lending
  • Maintain separate AML files where dual-regime coverage applies
Operating a de facto remittance product through a casino cage without CNBV authorisation has triggered enforcement against junket operators in past inspection cycles.
LFPIORPI art. 1

Object of the law

Article 1 fixes the purpose of the LFPIORPI: to protect the financial system and the national economy by establishing measures and procedures to prevent and detect acts or operations involving resources of illicit origin, through inter-institutional coordination aimed at gathering useful intelligence to investigate and prosecute the offences of operations with resources of illicit origin (lavado de dinero) and terrorism financing connected with these activities.

Requirements
  • Treat LFPIORPI compliance as a national-security duty, not a tax formality
  • Align internal AML programme objectives with the statutory purpose
  • Cooperate with inter-institutional information exchange between SAT, UIF, FGR and SEGOB
Article 1 is the interpretive anchor cited in every SAT and UIF enforcement resolution.
LFPIORPI art. 3

Statutory definitions

Article 3 supplies the controlling definitions used throughout the law: Actividades Vulnerables, Aviso, Beneficiario Controlador, Entidades Financieras, Fedatario Público, Persona Políticamente Expuesta, Reglas de Carácter General, SAT, Secretaría (SHCP) and Unidad (UIF). Each defined term has the meaning given in this article wherever it appears in subsequent provisions.

Requirements
  • Map each defined term to its operational counterpart in the AML manual
  • Adopt the article 3 definition of Beneficiario Controlador for the UBO register
  • Cite the article 3 definition when scoping PEP, vulnerable-activity and aviso obligations
Internal policy that uses different definitions from article 3 is a frequent SAT inspection finding.
LFPIORPI art. 6

Faculties of the Secretaría de Hacienda

Article 6 vests the Secretaría de Hacienda y Crédito Público (SHCP) with the lead policy and coordination faculty over the regime, including issuing the Reglamento and Reglas de Carácter General, receiving avisos through the SAT, requesting information from authorities and covered persons, and presenting denuncias to the Fiscalía General de la República where conduct may constitute the offence of operations with resources of illicit origin.

Requirements
  • Treat SHCP-issued RCG amendments as binding on the AML programme from the effective date
  • Track the SHCP-published official format catalogue (anexos) for aviso schemas
  • Anticipate that SHCP can refer findings directly to the FGR for criminal prosecution
Day-to-day supervision is delegated to the SAT under art. 38, but the rule-making power sits with the SHCP.
LFPIORPI art. 15

Unidad Especializada en Análisis Financiero (FGR)

RG Critical

Article 15 creates, within the Fiscalía General de la República, an Unidad Especializada en Análisis Financiero (UEAF) competent to investigate the offences contemplated in the law and connected offences, with access to the information held by the SHCP and the UIF. The UEAF is the operational counterparty for criminal-stage AML referrals affecting gaming operators.

Requirements
  • Recognise the UEAF as the criminal-investigation counterparty when an aviso escalates
  • Preserve evidence in a form admissible in a federal criminal proceeding
  • Route any UEAF subpoena or information request through the compliance officer and legal counsel
Where the UEAF is involved, the matter has already crossed from administrative supervision into criminal prosecution.
LFPIORPI art. 23

Supplementary requirements on aviso content

Player Rights

Article 23 directs the SHCP to issue, through Reglas de Carácter General, the specific characteristics, content and supporting documentation requirements for each aviso depending on the type of vulnerable activity. For casino and gaming operators, the active RCG set the XML schema, validation rules and the catálogo of operation types.

Requirements
  • Subscribe to the SHCP and SAT publication channels for RCG amendments
  • Re-validate aviso XML against the current schema before every monthly batch
  • Update the internal operation-type catalogue to match the published anexos
  • Run a parallel test environment before adopting any new schema version
Most rejection notices on SPPLD trace back to an outdated schema or operation-type code.
LFPIORPI art. 24

Aviso language and supporting records

Player Rights

Article 24 requires that the aviso and its supporting documents be in Spanish, and that foreign-language documents be accompanied by a translation by a perito traductor. Information must be presented in the format and through the means determined by the SHCP.

Requirements
  • Translate foreign-language onboarding documents through an authorised perito traductor
  • Retain both original and translation in the identification file
  • Submit avisos exclusively through SHCP/SAT-approved electronic channels
  • Reject documents that cannot be reliably translated within the onboarding window
Apostille or legalisation is a separate requirement under general civil-procedure rules and does not substitute for translation.
LFPIORPI art. 25

Confidentiality of aviso data

RG Critical Player Rights

Article 25 classifies the information contained in avisos and in supporting records as reserved and confidential under the federal transparency and personal-data regimes. The SHCP, the SAT and the UIF may use the information only for purposes set in this law and connected statutes.

Requirements
  • Treat aviso-related data as reserved-confidential within internal access controls
  • Limit access to aviso records to a documented need-to-know list
  • Refuse third-party disclosure requests other than via lawful authority channels
  • Log every access to aviso records for audit and SAT inspection
Unauthorised disclosure can constitute both an administrative breach under LFPIORPI and a criminal offence under the federal data-protection regime.
LFPIORPI art. 26

Use of third-party service providers for identification

Player Rights

Article 26 permits covered persons to rely on third parties to discharge identification obligations, but the covered person retains exclusive responsibility for compliance. Reliance is conditioned on a written agreement, on the third party meeting the identification standards in the law and on the covered person being able to obtain the underlying documentation on demand.

Requirements
  • Document third-party reliance through a written outsourcing agreement
  • Verify the third party's adherence to LFPIORPI identification standards
  • Retain on-demand access to the underlying identification documentation
  • Carry the residual compliance risk on the covered person's books, not the vendor's
KYC outsourcing to a B2B platform or affiliate does not transfer liability — the operator remains the obligated party.
LFPIORPI art. 27

Internal compliance unit for legal-entity operators

Player Rights

Article 27 obliges covered persons that are legal entities to maintain a compliance officer (encargado del cumplimiento) responsible for verifying that the LFPIORPI obligations are met. The encargado may be the legal representative or a dedicated officer, must be registered with the SAT and is the named point of contact for supervisory communications.

Requirements
  • Designate an encargado del cumplimiento and register the designation with the SAT
  • Provide the encargado with documented authority, autonomy and resources
  • Re-notify the SAT on every change of officer or contact details
  • Maintain a succession plan to avoid lapses in the registered designation
For multi-entity groups, a separate designation per legal entity is required — group-level officers are not recognised.
LFPIORPI art. 28

Fedatarios públicos and real-estate overlay

Article 28 addresses the duties of notaries and other public faith-givers acting in connection with vulnerable activities. For casino operators the article is relevant where corporate, real-estate or trust transactions linked to the gambling business are formalised before a notary — the fedatario has parallel identification and reporting duties.

Requirements
  • Coordinate with notaries on M&A, real-estate and trust transactions to align identification records
  • Provide the fedatario with the data required for the parallel aviso
  • Retain the notarial instrument alongside the LFPIORPI client file
  • Anticipate dual-track inspection (notary and operator) on the same transaction
Mismatch between notarial and operator records is a typical SAT cross-check finding.
LFPIORPI art. 29

Blacklisted-persons list and asset-freezing duty

RG Critical Player Rights

Article 29 obliges covered persons to suspend, in immediate terms, any act or operation with persons appearing on the lista de personas bloqueadas issued and updated by the SHCP. The list is communicated through the SAT and the UIF and covers persons subject to international sanctions, OFAC-type designations and domestic enforcement actions.

Requirements
  • Screen every client and beneficial owner against the SHCP lista de personas bloqueadas at onboarding and continuously
  • Suspend operations immediately on a positive match and notify the SHCP
  • Document the suspension and the underlying screening evidence
  • Re-screen on every list update without waiting for a transaction trigger
Operating with a listed person is treated as wilful breach and almost always escalates to the criminal track under arts. 62–65.
LFPIORPI art. 30

Information requests from the SHCP and SAT

Article 30 empowers the SHCP, acting through the SAT, to request from covered persons the information and documentation related to acts or operations carried out under the LFPIORPI. The request must be answered within the deadline set in the request, in the medium specified by the SAT.

Requirements
  • Acknowledge SAT information requests on receipt and calendar the response deadline
  • Route the request through the encargado del cumplimiento for a controlled response
  • Produce records in the requested electronic medium with chain-of-custody evidence
  • Document any extension request and the granting communication from the SAT
Failure to respond, or incomplete response, is sanctioned under art. 53 as a separate breach from the underlying conduct.
LFPIORPI art. 31

Coordination with other authorities

Article 31 instructs the SHCP, SAT and UIF to coordinate with other federal and state authorities to gather information necessary to fulfil their statutory functions. For gaming operators this underpins data exchanges between SAT (AML supervisor), SEGOB (permit authority) and state tax administrations.

Requirements
  • Anticipate cross-agency information exchange when responding to inspections
  • Maintain consistent records across SAT, SEGOB and state-level filings
  • Brief senior management on the inter-agency reach of any single inspection finding
Discrepancies between SAT and SEGOB records are a fast path to escalated supervisory attention.
LFPIORPI art. 33

Cash restriction enforcement against buyer and seller

RG Critical

Article 33 reinforces art. 32 by clarifying that the prohibition on cash settlement above the statutory thresholds binds both parties to the operation. Receiving cash above the threshold is itself a breach, irrespective of who tendered the cash.

Requirements
  • Refuse to accept cash above the article 32 thresholds at every cashier touchpoint
  • Train staff that the prohibition applies regardless of customer insistence
  • Document any rejected cash payment for SAT inspection
  • Route prize payouts above the threshold through bank channels even where the customer prefers cash
Liquidating chips for cash above the threshold is the most common breach pattern flagged by SAT inspection teams.
LFPIORPI art. 34

Information furnishing by financial entities

Article 34 requires entidades financieras to furnish information to the SHCP about their clients that conduct vulnerable activities, including casino operators. The provision is relevant to operators because it gives the SHCP a parallel data feed against which aviso content is cross-checked.

Requirements
  • Reconcile bank-channel records with submitted avisos before each monthly cycle
  • Anticipate that banking data on the operator's account will be cross-checked against avisos
  • Maintain consistent counterparty naming between bank records and aviso filings
Unexplained inflows on operator bank accounts that have no matching aviso are the highest-yield SAT desk-audit query.
LFPIORPI art. 35

Customs and cross-border cash overlay

RG Critical

Article 35 coordinates LFPIORPI with the customs cross-border cash-declaration regime. Cash imports or exports above the customs threshold (USD 10,000 equivalent) trigger separate declarations under aduanas law; LFPIORPI information may be cross-referenced with customs filings for inbound high-roller funds.

Requirements
  • Identify junket and high-roller fund flows that may have crossed the border in cash
  • Request customs declaration evidence for inbound cash that funds wagering
  • Document the cross-border source of funds in the enhanced-CDD file
VIP and junket programmes targeting US-resident players are the typical exposure point for this article.
LFPIORPI art. 36

Precious metals and high-value goods overlay

Article 36 extends cash restrictions to the acquisition of precious metals, jewellery, watches and other high-value goods, paralleling the casino regime. Where casino prize redemptions take the form of non-cash high-value goods, the parallel article 36 regime applies on the supplier side.

Requirements
  • Avoid prize redemptions in non-cash high-value goods unless the supplier is fully LFPIORPI compliant
  • Document the supplier's compliance status where in-kind prizes are offered
  • Route in-kind prize values into the operator's aviso even where the supplier files its own
Watch and luxury-good prizes appearing in promotional campaigns are the typical exposure.
LFPIORPI art. 37

UMA denomination and annual update

Article 37 confirms that the monetary thresholds in the law are denominated in Unidades de Medida y Actualización (UMA). UMA values are updated annually by INEGI and published in the DOF, with the new value taking effect on 1 February each year.

Requirements
  • Recalculate identification, reporting and cash thresholds on 1 February each year
  • Refresh AML monitoring rules and cashier prompts with the new UMA values
  • Document the threshold-update step as a controlled change in the AML manual
Out-of-date UMA values in the monitoring engine are a common cause of under-reporting findings.
LFPIORPI art. 39

SAT inspection powers (visitas de verificación)

Article 39 grants the SAT the power to conduct visitas de verificación on covered persons to confirm compliance with LFPIORPI obligations. Inspections may be carried out at any of the operator's establishments during business hours and follow the procedure set out in the law and supplementary federal-administrative-procedure rules.

Requirements
  • Maintain an inspection-readiness pack at every authorised site
  • Brief site management on the SAT inspection procedure and the encargado escalation path
  • Record the inspector's credentials and the orden de visita in the inspection log
  • Preserve a contemporaneous note of every interaction during the visit
Refusing entry to an inspector with a valid orden de visita is an independent ground for sanction under art. 53.
LFPIORPI art. 40

Conduct of visitas de verificación

Article 40 sets the procedural rules for the inspection: the visit must be carried out with the person in charge of the establishment, two witnesses must be designated, and an acta circunstanciada must be drawn up recording the inspection findings. The covered person has the right to formulate observations and to attach documents to the acta.

Requirements
  • Designate the encargado del cumplimiento (or delegate) as the named person for the visit
  • Have two witnesses available on-site at all times during business hours
  • Review the draft acta circunstanciada before signing and lodge observations
  • Preserve a signed copy of the acta and all attachments in the inspection file
Signing an acta without observations forfeits the operator's right to contest factual statements in any subsequent procedure.
LFPIORPI art. 41

Document production during visit

Article 41 obliges the covered person to make available, during the visit, the books, registers, identification files, avisos and supporting documentation relating to the vulnerable activity. The inspectors may take copies and require explanations from the personnel present.

Requirements
  • Maintain a current index of identification files, avisos and supporting records
  • Provide working copies during the visit and a controlled retrieval process
  • Avoid expurgated or redacted production — the inspector is entitled to complete records
  • Document every record extracted by the inspector in the acta
Records held off-site or with a third-party processor must be retrievable within the inspection window.
LFPIORPI art. 42

Supplementary application of CFF and LFPA

Article 42 makes the Código Fiscal de la Federación and the Ley Federal de Procedimiento Administrativo supplementary to the LFPIORPI procedural rules. Inspection, notification and challenge timelines borrow from the CFF where the LFPIORPI is silent.

Requirements
  • Apply CFF notification rules to compute response deadlines
  • Use LFPA mechanisms for procedural challenges where LFPIORPI is silent
  • Brief legal counsel familiar with both regimes on every active inspection
  • Anticipate that the deadline computation rules differ from general civil procedure
Notification by buzón tributario applies to LFPIORPI communications under the CFF cross-reference.
LFPIORPI art. 43

Information exchange with foreign authorities

Article 43 enables the SHCP and the UIF to exchange information with foreign authorities under bilateral or multilateral instruments, including FATF/GAFILAT and Egmont Group channels. Casino-sector aviso data may be transmitted abroad under these frameworks.

Requirements
  • Recognise that aviso data may be transmitted to foreign FIUs under Egmont Group protocols
  • Brief affected business lines (especially cross-border VIP) on this exposure
  • Avoid privacy notices that contradict the statutory information-exchange faculty
Information exchange under art. 43 is independent of any MLAT — operators cannot resist by reference to data-protection law alone.
LFPIORPI art. 44

Duty of secrecy of public servants

Article 44 imposes a duty of secrecy on public servants who handle LFPIORPI information. Breach by an SAT, UIF or SHCP officer is sanctioned under the federal regime for public-servant responsibilities and may also constitute a criminal offence.

Requirements
  • Where unauthorised disclosure by a public servant is suspected, document evidence and consider denuncia
  • Do not rely on informal verbal commitments by inspecting officers — require written record
  • Brief senior management on the operator's right to confidentiality of submitted aviso data
This article is the statutory mirror to the operator-side tipping-off prohibition in art. 22.
LFPIORPI art. 45

Administrative procedure for sanctions

RG Critical

Article 45 sets the structure of the administrative procedure leading to a sanction: detection of facts during a visita or desk audit, formal notification to the covered person, fifteen business days for the operator to formulate allegations and offer evidence, and a resolution from the SAT within the statutory deadline.

Requirements
  • Treat any SAT formal notification as the start of the fifteen-business-day response clock
  • File written allegations and evidence within the deadline — silence is treated as acceptance
  • Engage external counsel familiar with the LFPIORPI administrative procedure on receipt of notification
  • Preserve the full acta, notification and response file for any later challenge
Failure to answer the notification is the single most damaging procedural mistake — it converts contestable findings into final ones.
LFPIORPI art. 46

Evidence and burden in the sanction procedure

Article 46 governs the evidentiary regime: the operator may offer all evidence admissible under the federal procedural rules except the confesional from authorities. The SAT must weigh the evidence and issue a reasoned resolution.

Requirements
  • Prepare a documentary evidence pack to support every disputed factual element
  • Avoid relying on confesional from SAT inspectors — it is not admissible
  • Request expert evidence where technical AML controls are in dispute
  • Track every evidentiary submission against the inspector's acta findings
Reasoned-resolution requirement gives strong grounds for nullity if the SAT fails to address timely-offered evidence.
LFPIORPI art. 47

Sanction resolution and notification

Article 47 requires the SAT resolution to be reasoned, to identify the breaching conduct, to state the legal basis for the sanction and to specify the quantum in UMA. The resolution must be notified to the covered person under the CFF notification rules.

Requirements
  • Verify that every element required by article 47 appears in the resolution
  • Calendar the challenge deadline from the date of formal notification, not actual receipt
  • Preserve the resolution and notification evidence in the legal hold file
Resolutions that fail to quantify the sanction in UMA or to identify the breach element are vulnerable to nullity on judicial review.
LFPIORPI art. 48

Administrative challenge and juicio de nulidad

Article 48 confirms that the resolution may be challenged through the recurso de revisión under the LFPA or directly through the juicio de nulidad before the Tribunal Federal de Justicia Administrativa (TFJA). Election of remedy is one-way and conditions subsequent procedural avenues.

Requirements
  • Make a deliberate, counsel-led election between recurso de revisión and juicio de nulidad
  • File within the statutory deadline (fifteen or thirty business days depending on remedy)
  • Preserve evidence of every procedural step in the underlying administrative file
Going straight to the TFJA is the more common route for material sanctions in the casino sector.
LFPIORPI art. 49

Criteria for sanction quantum

RG Critical

Article 49 directs the SAT to fix the quantum of the sanction taking into account the seriousness of the conduct, the economic capacity of the covered person, recidivism, the volume of the operation, the benefit obtained and any cooperation provided. Mitigating and aggravating factors must be expressed in the resolution.

Requirements
  • Document mitigating factors (self-disclosure, prompt remediation, cooperation) for use in the response
  • Quantify any benefit obtained and any harm avoided as part of the evidence pack
  • Track recidivism risk across affiliated entities under the same operator
  • Use the article 49 framework to argue for reduction in the formal response
Self-disclosure before an inspection is one of the strongest documented mitigating factors in TFJA precedent.
LFPIORPI art. 50

Warning (amonestación) as lightest sanction

Article 50 contemplates a written warning as the lightest sanction available to the SAT, reserved for first-time, low-impact breaches with full and prompt remediation. The warning is recorded in the operator's compliance history and weighs as aggravating factor in any subsequent procedure.

Requirements
  • Treat a warning as a record-making event — not a costless outcome
  • Document the remediation that supports a warning rather than a fine
  • Update internal controls to evidence that the underlying root cause was addressed
Repeat warnings effectively guarantee escalation to a quantified fine on the next breach.
LFPIORPI art. 51

Revocation of vulnerable-activity registration

RG Critical

Article 51 empowers the SAT, in addition to monetary sanctions, to revoke the registration of the covered person in the vulnerable-activity registry where the breach is of the highest severity or where there is reiterated non-compliance. Revocation does not extinguish other liabilities.

Requirements
  • Treat revocation risk as an existential threat to the operating permit framework
  • Escalate any pattern of repeated breaches to board-level governance immediately
  • Document the remediation plan addressing every cited breach element
  • Coordinate the LFPIORPI defence with the SEGOB permit-defence track
SAT revocation of SPPLD registration does not formally cancel the SEGOB permit but practically disables continued operation.
LFPIORPI art. 52

Publication of sanctions

RG Critical

Article 52 authorises the SAT to publish firm sanctions on its institutional portal, identifying the sanctioned person and the breach. Publication has material reputational and counterparty-risk implications for casino operators dependent on banking relationships.

Requirements
  • Anticipate publication once an LFPIORPI resolution becomes firm
  • Brief banking, B2B and audit counterparties before publication takes effect
  • Prepare a stakeholder-communication pack for the publication event
  • Track the SAT portal feed for own-name and group-name appearances
Bank de-risking following SAT publication is the most material indirect consequence for the casino sector.
LFPIORPI art. 54

Statute of limitations on sanctions

Article 54 sets the five-year limitation period for the SAT's faculty to impose sanctions, computed from the date the breach was committed or from the date the conduct ceased in the case of continuing breaches. The period is interrupted by any formal act of inspection.

Requirements
  • Calendar the five-year limitation clock per breach element
  • Distinguish between point-in-time and continuing breaches when assessing exposure
  • Track any formal inspection act that interrupts the limitation period
  • Use limitation arguments in the article 45 response where applicable
Continuing breaches (e.g., persistent failure to file avisos) keep the clock open indefinitely until the conduct ceases.
LFPIORPI art. 55

Collection of fines as tax claims

RG Critical

Article 55 treats unpaid LFPIORPI fines as créditos fiscales, recoverable through the SAT's procedimiento administrativo de ejecución (PAE). Collection mechanisms include freezing of bank accounts, embargo on movable and immovable assets and the buzón tributario notification path.

Requirements
  • Treat any firm LFPIORPI fine as a tax debt for cash-management purposes
  • Anticipate PAE actions including account freezes if the fine is unpaid
  • Use the suspension-of-execution mechanism where the resolution is under challenge
  • Coordinate with tax counsel on bonding (garantía del interés fiscal) options
Posting a garantía del interés fiscal suspends PAE collection while the juicio de nulidad is litigated.
LFPIORPI art. 56

Joint liability of directors and administrators

RG Critical

Article 56 establishes personal liability of the directors, administrators and legal representatives of a covered legal entity for breaches they authorised or in which they participated. Personal liability is in addition to entity-level sanctions.

Requirements
  • Brief directors and senior officers on personal LFPIORPI exposure at appointment
  • Maintain board minutes evidencing AML oversight and challenge
  • Avoid directors signing off on AML matters without documented information packs
  • Consider D&O policy alignment with LFPIORPI personal-liability exposure
Documented board challenge is the most effective evidence of due diligence at director level.
LFPIORPI art. 57

Relationship with other administrative regimes

Article 57 preserves the parallel application of other administrative regimes (tax, gaming, customs) — an LFPIORPI sanction does not exhaust or displace SEGOB, SAT-tax or customs sanctions for the same underlying conduct. Non-bis-in-idem applies only within the same regime.

Requirements
  • Map every breach event to its potential exposure under each parallel regime
  • Coordinate the LFPIORPI, SEGOB and tax-defence tracks under a single privileged file
  • Avoid admissions in one regime that prejudice defence in another
A single typology breach can simultaneously generate LFPIORPI, IEPS and SEGOB sanctions — coordinated defence is essential.
LFPIORPI art. 62

Criminal offence — providing false aviso information

RG Critical

Article 62 criminalises the provision of false information in an aviso or in records that should support an aviso, with imprisonment from two to eight years and a fine of five hundred to two thousand days. The offence may be charged against the encargado del cumplimiento and other staff who knowingly participated.

Requirements
  • Maintain documented data-quality controls on aviso production
  • Avoid signing off on avisos where source-data integrity is in doubt
  • Escalate concerns about data accuracy to senior management before submission
  • Train cashier and surveillance staff on the criminal exposure for falsified records
Falsification by intent is the threshold — negligent error attracts administrative sanction under art. 53 rather than the criminal track.
LFPIORPI art. 63

Criminal offence — improper use of aviso information

RG Critical

Article 63 criminalises the use, for personal benefit or third-party benefit, of the information obtained through avisos. Conviction carries imprisonment of six to twelve years and a fine of five hundred to two thousand days. The provision applies equally to public servants and to private-sector personnel with access.

Requirements
  • Restrict aviso-data access to a documented need-to-know list
  • Maintain technical access logging on all systems holding aviso records
  • Include misuse of aviso data in the code of conduct and disciplinary policy
  • Prepare an internal investigation protocol for suspected art. 63 conduct
Six-to-twelve-year sentencing range puts art. 63 in serious-offence territory under the CNPP — pre-trial detention is the rule.
LFPIORPI art. 64

Criminal offence — tipping off

RG Critical

Article 64 criminalises the disclosure to the client, the beneficial owner or a third party of the fact that an aviso has been or is about to be filed. Conviction carries imprisonment of two to eight years. The criminal track sits on top of the administrative tipping-off prohibition in art. 22.

Requirements
  • Reinforce the article 22 tipping-off prohibition with explicit reference to criminal exposure
  • Document every internal communication about aviso preparation in a controlled-access system
  • Train senior managers on the personal criminal exposure of pressuring cashier or compliance staff for information
  • Operate a confidential reporting channel for staff who experience pressure to disclose
Article 64 is the criminal-stage counterpart to article 22 — both apply concurrently to the same disclosure event.
LFPIORPI art. 65

Aggravators and public-servant uplift

Article 65 uplifts the criminal penalties under arts. 62-64 by one-half where the conduct is committed by a public servant in the exercise of their function. The provision interfaces with the public-servant secrecy duty in art. 44 and the FGR UEAF investigation under art. 15.

Requirements
  • Where a SAT, UIF or SHCP officer is implicated in a breach against the operator, escalate to the FGR UEAF
  • Preserve evidence to the standard required for a criminal denuncia
  • Coordinate criminal and administrative defence under privileged-counsel oversight
Article 65 supplies a credible threat against rogue inspectors and is the statutory counter-leverage in misconduct scenarios.
6
Theme 6

Tax stack (IEPS + state)

Federal gambling tax sits in the Ley del Impuesto Especial sobre Producción y Servicios (IEPS) at a headline rate of 30 percent, layered with state-level entidad federativa taxes that range from 2 to 12 percent and the ordinary ISR (corporate income tax). The SAT administers the federal stack; state secretariats administer their own gambling taxes.

22 standards 9 player-flagged
41%
player-flagged
Regulatory risks this theme addresses
  • Treating the IEPS as the only gambling tax owed in Mexico
  • Missing a state-level levy on apuestas, sorteos or premios
  • Failing to withhold ISR on player prizes above the statutory threshold
LIEPS art. 2 frac. II inciso B

30 percent IEPS on games with wagers and draws

Article 2 fraction II inciso B of the Ley del IEPS imposes a 30 percent tax on the realización de juegos con apuestas y sorteos, including those held through electronic, computerised, telecommunications or satellite means. The tax base is the amount received from the player less amounts paid as prizes.

Requirements
  • Apply IEPS at 30 percent on the net wager base
  • Reduce the base by prizes actually paid
  • Account for IEPS monthly via the SAT electronic declaration
LIEPS art. 5 — IEPS base

Base calculation and prize deduction

Article 5 details the periodic calculation: the base is the total amount received from players in the month, less prizes paid in the same month. Negative balances may be carried forward against future positive balances.

Requirements
  • Reconcile player ledger to monthly IEPS base
  • Carry forward negative balances per the SAT mechanics
  • Preserve audit-grade documentation of every deduction
LIEPS art. 19 — record-keeping

IEPS record-keeping obligations

Article 19 obliges taxpayers to keep electronic records of every operation subject to IEPS and to produce them to the SAT. For gambling, this requires a per-transaction ledger reconciled to the wagering platform.

Requirements
  • Maintain a transaction-level ledger reconcilable to the platform
  • Preserve records for the statutory five-year period
  • Produce ledgers on SAT inspection request
Estado de México — Código Financiero art. 70

Estado de México wagering and draw tax

The Código Financiero del Estado de México imposes a state-level tax on games with wagers, sorteos and prizes at rates between 2 and 12 percent. Each entidad federativa with significant gambling activity has equivalent provisions.

Requirements
  • Map each operating site to the applicable entidad federativa tax
  • Register with each state secretariat as required
  • File state declarations in parallel with federal IEPS
Provisional citation — verify the current article and rate against the consolidated text published by the Estado de México Gaceta Oficial before relying on it for a filing.
LISR art. 137

ISR withholding on player prizes

Player Rights

Article 137 of the Ley del ISR requires withholding at a federal rate on prizes paid to natural persons, with state-level surcharges in entidades that have established additional levies. The total combined withholding can reach 21 percent.

Requirements
  • Withhold ISR on prizes at the federal rate
  • Add state surcharges where applicable
  • Issue CFDI to the winner reflecting the withholding
CDMX — Código Fiscal

Ciudad de México gambling levy

The Código Fiscal de la Ciudad de México imposes its own levy on permitted gambling activities conducted within CDMX. Rate calibration and reporting periodicity are set in the annual Código de Hacienda.

Requirements
  • Confirm the current CDMX rate annually
  • Register with the Secretaría de Administración y Finanzas
  • File the corresponding monthly declarations
Provisional citation pending publication of the consolidated annual Código de Hacienda.
LIEPS art. 2 frac. II inciso B (2026)

Extension of IEPS to foreign-resident operators without PE in Mexico

Player Rights

The 2026 reform extends the IEPS to foreign residents that offer games with wagers or draws to persons located in Mexico, even where the operator has no permanent establishment in the country. The foreign operator must register before the SAT, designate a Mexican legal representative and a domicilio fiscal for notifications, and collect and remit the 50% IEPS on Mexican-sourced wagering income.

Requirements
  • Register the foreign entity with the SAT registro de contribuyentes de actividades vulnerables aplicable
  • Appoint a Mexican legal representative jointly liable for tax obligations
  • Designate a domicilio fiscal for SAT notifications
  • Calculate, withhold and remit IEPS at 50% on every Mexican-resident wager
The extension mirrors the SAT digital-services regime under LIVA and is the principal anti-offshore lever of the 2026 reform.
LIEPS art. 20 — bloqueo

Access-blocking sanction for IEPS non-compliance

Player Rights

The reformed LIEPS empowers the SAT to instruct concesionarios de telecomunicaciones to block access to digital services of foreign-resident gambling operators that fail to register, fail to designate a Mexican representative, or fall behind on IEPS remittances. Blocking is administrative and may be lifted on regularisation.

Requirements
  • Treat SAT registration as the precondition for continued .mx accessibility
  • Cure any late payment immediately to avoid bloqueo proceedings
  • Maintain a contact channel for SAT pre-blocking notifications
  • Document any blocking event in shareholder disclosures
The bloqueo lever extends the model already used by the SAT under LIVA art. 18-H BIS for foreign digital-service providers.
Decreto DOF 7-Nov-2025 art. Único

IEPS rate increase from 30% to 50% effective 1 Jan 2026

Player Rights

The decree published in the Diario Oficial de la Federación on 7 November 2025, as part of the Paquete Económico 2026, reforms LIEPS art. 2 fracción II inciso B to raise the special tax on games with wagers and draws from 30 percent to 50 percent of the taxable base. The new rate applies to all permit holders and to foreign-resident operators in scope, with effect from 1 January 2026.

Requirements
  • Reprice the IEPS line in pricing models from 1 January 2026
  • Update player-facing terms and tax-disclosure language
  • Refresh forecasting and capital plans for the 20-point increase
  • Reconcile any prior-period IEPS declarations under the legacy 30% rate
The reform was approved by the Cámara de Diputados in late October 2025 and published in the DOF on 7 November 2025; the 50% rate is the highest gambling-tax headline rate in the OECD.
Reglas SAT IEPS 2026 — reporting

SAT real-time reporting obligations for digital intermediation platforms

Player Rights

The Reglas de Carácter General accompanying the 2026 IEPS reform require digital intermediation platforms that facilitate games with wagers — including app stores, payment aggregators and white-label technology providers — to share transaction-level data with the SAT in near real time, identifying counterparties, amounts wagered and prizes paid.

Requirements
  • Build a SAT data-sharing pipeline before the first reporting cut-off
  • Capture counterparty CURP/RFC where available
  • Reconcile platform-side records with operator-side ledgers monthly
  • Retain raw-event logs for the SAT statutory period
The reporting model draws on the SAT CFDI digital-invoice infrastructure; the exact technical schema is published through SAT Anexos.
LISR art. 9 — ISR corporativo

30% federal corporate income tax on operator profits

Under article 9 of the Ley del Impuesto sobre la Renta, Mexican-resident legal persons pay a flat 30 percent corporate income tax on net taxable profit, computed annually with monthly provisional payments. The ISR stacks on top of the IEPS levied on wagering income.

Requirements
  • File monthly provisional ISR payments
  • Compute net taxable profit after IEPS, depreciation and authorised deductions
  • File annual ISR return within three months of fiscal year-end
  • Preserve electronic accounting (contabilidad electrónica) for SAT lookups
There is no reduced corporate ISR rate for gambling operators; the 30% rate has been stable since the 2013 ISR reform.
LIVA art. 15 frac. VII

VAT exemption for gambling and draw supplies

Fraction VII of article 15 of the Ley del Impuesto al Valor Agregado exempts services consisting of the practice of games with wagers and draws — when subject to the IEPS — from the general 16 percent IVA. Ancillary services (food and beverage, hotel, advertising) remain subject to IVA at the standard rate.

Requirements
  • Issue IEPS-bearing wagering invoices without IVA
  • Charge IVA at 16% on ancillary supplies
  • Maintain separate accounting blocks for exempt and taxed revenues
  • Refresh the exempt-supply mapping after any LIVA reform
The exemption avoids double taxation given the IEPS already targets gambling activity; it is anchored in the LIVA's exclusive-tax doctrine.
LISR art. 138

1% federal withholding on player winnings — stepped to 21% by state add-on

Player Rights

Article 138 of the LISR establishes a 1 percent federal withholding by the operator on the value of each prize paid. Where the state prize tax exceeds 6 percent, the federal withholding rises to 21 percent so that the combined federal-plus-state burden on a winning ticket remains aligned to the LISR design.

Requirements
  • Withhold 1% federal ISR on every prize as a default rule
  • Apply the 21% stepped rate where state prize tax exceeds 6%
  • Issue a CFDI de retenciones to each beneficiary
  • Remit withholdings monthly through the SAT portal
The mechanism prevents combined federal-plus-state prize taxation from breaching the LISR constitutional proportionality test.
Código Fiscal CDMX art. 156

Ciudad de México 6% tax on prizes

Player Rights

Article 156 of the Código Fiscal de la Ciudad de México imposes a 6 percent local tax on the value of prizes paid to winners of authorised games with wagers, draws and contests, withheld at source by the operator and remitted monthly to the Secretaría de Administración y Finanzas.

Requirements
  • Withhold 6% on each prize paid to a CDMX-resident winner
  • Remit monthly through the CDMX portal
  • File the corresponding declaración informativa
  • Issue the CDMX-format prize receipt
CDMX sets the 6% benchmark that triggers the LISR stepped 21% federal withholding when surpassed elsewhere.
Ley General de Hacienda Yucatán — sorteos

Yucatán small-operator gambling tax

The Ley General de Hacienda del Estado de Yucatán imposes a state tax on the organisation of raffles, sorteos and small-scale wagering activity, scaled by prize value and operator class. The regime captures sub-permit and promotional activity that escapes the federal IEPS net.

Requirements
  • Map every Yucatán-based promotional draw to the state-tax schedule
  • Compute the prize-band rate per event
  • File state declarations through the Agencia de Administración Fiscal de Yucatán
  • Coordinate with federal sorteo permits to avoid double taxation
Yucatán's regime is representative of similar small-operator state taxes in Tabasco, Campeche and Chiapas.
Ley de Hacienda Jalisco — apuestas

Jalisco ~7% tax on gambling gross revenue

The Ley de Hacienda del Estado de Jalisco levies a tax of approximately 7 percent on the gross revenue of authorised gambling operators within the state, accruing alongside the prize-side levies and federal IEPS.

Requirements
  • Compute the Jalisco GGR base monthly per establishment
  • Remit through the SEPAF Jalisco portal
  • Maintain per-municipality revenue allocation working papers
  • Reconcile state GGR to federal IEPS GGR each period
Jalisco's rate has been progressively raised through annual Ley de Ingresos amendments; verify the current percentage in the year-applicable Ley de Ingresos del Estado de Jalisco.
Ley de Hacienda NL — apuestas

Nuevo León 10-15% tax on stakes (pioneer of stakes-base taxation)

Player Rights

The Ley de Hacienda del Estado de Nuevo León established a 10-15 percent state tax computed on the value of stakes (importe apostado), not on prizes or GGR. The model is the pioneer Mexican stakes-base levy and the principal candidate for harmonisation in the post-2026 reform pipeline.

Requirements
  • Compute the stakes-base tax per wager, not per prize
  • Apply the correct band within the 10-15% range per product class
  • Remit through the Secretaría de Finanzas y Tesorería General NL
  • Track any harmonisation proposal that would migrate other states to a stakes base
The stakes base produces a materially higher effective tax than a GGR or prize base for high-churn products; operators have litigated proportionality of the levy in local amparos.
Ley de Ingresos Quintana Roo — zonas turísticas

Quintana Roo state-tax waivers for integrated-resort tourism zones

Annual Leyes de Ingresos of Quintana Roo grant time-limited state-tax waivers or reduced rates for gambling activity carried out inside designated integrated-resort tourism zones (Cancún, Riviera Maya), conditional on documented tourism-investment thresholds and resort licensing.

Requirements
  • Confirm the establishment is inside a designated zona turística
  • Meet the tourism-investment threshold for the relevant fiscal year
  • Refresh the waiver request annually via the state Ley de Ingresos process
  • Maintain ring-fenced accounting for waived-rate revenue
Waivers are politically sensitive and frequently scrutinised in Congreso del Estado audits.
Banxico — Disposiciones cambiarias

Banco de México foreign-exchange rules for operator remittances

Player Rights

Banco de México disposiciones generales applicable to financial entities require that operator remittances to foreign accounts in excess of statutory thresholds be channelled through institutions supervised under the Ley de Instituciones de Crédito, with traceable counterparty data and consistent FX-rate evidence.

Requirements
  • Use Banxico-supervised institutions for material outbound remittances
  • Document the underlying commercial cause of every transfer
  • Capture the FIX exchange rate published by Banxico for accounting consistency
  • Coordinate with LFPIORPI threshold notifications
FX controls are layered on top of LFPIORPI AML reporting; both regimes share the SAT/UIF supervisory perimeter.
Convenio México-España (CDI)

Mexico–Spain double-taxation treaty — gambling income

The Mexico–Spain Convenio para Evitar la Doble Imposición allocates taxing rights over business profits to the residence state where there is no permanent establishment in Mexico. Spanish-resident gambling groups (Codere, R Franco) typically structure Mexican operations through Mexican subsidiaries to manage PE risk and dividend withholding.

Requirements
  • Confirm there is no inadvertent PE in Mexico for upstream Spanish entities
  • Apply the treaty reduced withholding rates on dividends, interest and royalties
  • File the CDI residence certificate with the SAT for each treaty benefit claimed
  • Refresh the analysis after the 2026 IEPS extension to foreign residents
The IEPS extension to foreign residents is an indirect tax and is not relieved by the income-tax treaty.
Convenio México-Malta (CDI)

Mexico–Malta double-taxation treaty — gambling technology licensing

The Mexico–Malta CDI in force from 2014 caps withholding on royalties and technical-service fees, the predominant fee streams paid by Mexican operators to Malta-licensed B2B gambling technology suppliers (RNG, platform, sports-data feeds).

Requirements
  • Document substance of the Maltese counterparty
  • Apply the treaty cap on royalty and FTS withholding
  • Obtain a Malta tax-residence certificate annually
  • Refresh the BEPS-LOB analysis where the supplier is part of a wider group
Substance review is sharpened by the OECD MLI's principal-purpose test, now applicable to the Mexico–Malta treaty.
Curaçao — ausencia de CDI

Mexico–Curaçao — absence of double-taxation treaty

Mexico has no double-taxation treaty in force with Curaçao. Payments to Curaçao-licensed gambling counterparties are subject to default LISR withholding rates without treaty relief, and Curaçao remains on Mexican lists requiring enhanced transfer-pricing documentation.

Requirements
  • Apply default LISR withholding to Curaçao-counterparty payments
  • Apply enhanced transfer-pricing documentation for low-tax-jurisdiction transactions
  • Treat any Curaçao licence as offering no Mexican tax benefit
  • Track any future bilateral or TIEA negotiations
The absence of treaty relief, combined with the IEPS extension to foreign residents, materially reduces the viability of Curaçao-only structures targeting Mexican players.
7
Theme 7

Responsible gambling & player protection

Mexico's responsible-gambling framework is thinner than that of Brazil, Spain or the United Kingdom. The Reglamento sets a minimum age of 18, mandates self-exclusion and obliges signage, but the absence of a dedicated online statute leaves deposit-limit defaults and reality-check mechanics to operator discretion under the SEGOB-approved Manual Operativo.

19 standards 18 player-flagged
95%
player-flagged
Regulatory risks this theme addresses
  • Treating the absence of statutory deposit-limit defaults as an absence of duty
  • Failing to honour an autoexclusión request across all permit-holder channels
  • Inadequate display of helpline information at the point of wagering
RLFJS art. 30

Minimum age and supervised access

RG Critical Player Rights

Article 30 sets the minimum age at 18 and prohibits the entry of minors to any wagering establishment. Permit holders must verify age at the door and at remote-channel registration.

Requirements
  • Block under-18 access at every channel
  • Verify age at remote registration with an official document
  • Train staff on age-verification escalation
RLFJS art. 30 — sportsbook variant

Minimum-age controls under sportsbook permits

RG Critical Player Rights

Cross-betting (apuestas remotas) permit holders must verify age at every retail kiosk and at remote-channel registration. The Reglamento bars under-18s from any wagering area including OTB lounges adjacent to permitted establishments, even where the wagering area is segregated from a non-gambling food and beverage zone.

Requirements
  • Block under-18 access at every retail kiosk and OTB lounge
  • Verify age at remote-channel registration with INE plus liveness check
  • Segregate any adjacent non-gambling zone with controlled access
  • Sanction staff who admit minors regardless of the customer's representations
RLFJS art. 30 — sorteos variant

Minimum-age controls for sorteos and number-draw permits

RG Critical Player Rights

Sorteo de números and number-draw centre permit holders are equally bound by the 18-year floor and must refuse ticket sales and prize redemption to minors, including through commercial-propaganda sorteos distributed by mass media.

Requirements
  • Refuse ticket sales to anyone under 18 at point of sale and online
  • Refuse prize redemption to a minor regardless of the channel of purchase
  • Require age confirmation at registration for any participation requiring an account
  • Print the 18-only restriction on every physical ticket and bono
RLFJS art. 30 bis

Mandatory self-exclusion (autoexclusión)

RG Critical Player Rights

Article 30 bis obliges permit holders to operate a self-exclusion register, accept self-exclusion requests from players, deny access for the requested period and refrain from sending marketing communications to self-excluded individuals.

Requirements
  • Operate a register of self-excluded players
  • Apply self-exclusion across all sites, channels and apps of the permit holder
  • Suppress all marketing to self-excluded players
  • Document each self-exclusion request and its scope
RLFJS art. 30 bis — procedure

Autoexclusión application procedure

RG Critical Player Rights

The Reglamento requires permit holders to receive autoexclusión requests in writing, in person at any authorised establishment or via the remote channel, capture the applicant's official identification, and acknowledge receipt with a written constancia that fixes the effective date and scope of the exclusion.

Requirements
  • Accept written autoexclusión requests at every authorised site and through the remote interface
  • Capture the applicant's INE or passport and biometric photograph for the register
  • Issue a written constancia confirming start date, term and channels covered
  • Activate the block within 24 hours of receipt across all branded properties of the permit holder
Operators commonly mirror the Codere, Caliente and PlayCity autoexclusión forms; SEGOB has not published a single federal template.
RLFJS art. 30 bis — term

Autoexclusión minimum term and renewal

RG Critical

The autoexclusión runs for the term elected by the applicant, with a typical operator floor of six months and the option of one-year, three-year or indefinite exclusion. The term may not be shortened on the applicant's request before expiry; renewal is automatic only where the applicant has elected the indefinite form.

Requirements
  • Offer at least six-month, one-year, three-year and indefinite options at intake
  • Refuse any in-term reduction request even where the applicant changes their mind
  • Treat indefinite autoexclusión as enduring until a reinstatement procedure is completed
  • Log every term election against the player record for audit
The SEGOB-approved Manual Operativo of each permit holder fixes the exact term ladder; six months is the most common floor.
RLFJS art. 30 bis — reinstatement

Reinstatement after autoexclusión

RG Critical Player Rights

After the elected term expires, reinstatement is not automatic: the applicant must present a written request, undergo a renewed identification check, and observe a cooling-off period before the permit holder may reopen the account. Indefinite exclusions require a documented attestation of treatment progress before reinstatement may be considered.

Requirements
  • Require a written reinstatement request after expiry of the elected term
  • Re-run KYC and screen against the active autoexclusión register before reopening
  • Apply a cooling-off window between request and account reactivation
  • For indefinite exclusions, request a treatment attestation or CONADIC referral letter
RLFJS art. 30 bis 1

Helpline signage and RG messaging

RG Critical Player Rights

Permit holders must display responsible-gambling messaging and helpline information at visible points in each authorised establishment and on each remote channel.

Requirements
  • Display RG messaging at the point of wagering
  • Publish a national helpline reference on every page of the remote channel
  • Refresh messaging on each Manual Operativo update
CONADIC Lineamientos

CONADIC lineamientos on pathological gambling

RG Critical

CONADIC's lineamientos on adicciones include juego patológico as a behavioural addiction and direct treatment integration through the Centros de Atención Primaria en Adicciones (CAPA / UNEME-CAPA) network. Permit holders are expected to reference the CAPA network in their player-protection materials.

Requirements
  • Reference the CAPA / UNEME-CAPA network in RG help materials
  • Make CONADIC educational content available within the remote help section
  • Train RG team on the CONADIC treatment pathway for referrals
CONADIC overlap

CONADIC and gambling-disorder overlap

RG Critical

The Comisión Nacional contra las Adicciones (CONADIC) recognises gambling disorder (juego patológico) within its public-health remit and publishes treatment guidance, although it has no direct regulatory authority over permit holders.

Requirements
  • Reference CONADIC materials in the RG manual
  • Link players to CONADIC resources from the help section
  • Track any CONADIC guidance with operational impact
CONADIC — helpline disclosure

Mandatory CONADIC helpline disclosure

RG Critical Player Rights

The Comisión Nacional contra las Adicciones operates the national addictions hotline that has been adopted by the gambling sector as the de facto helpline. Permit holders must surface the CONADIC reference at the point of wagering, in the help section of every remote channel, and inside the autoexclusión constancia.

Requirements
  • Surface the CONADIC helpline reference at the point of wagering and in remote help sections
  • Include the helpline in the autoexclusión constancia issued to the player
  • Mirror the helpline in every RG email and behavioural-marker interaction
  • Update the published number whenever CONADIC reissues the service
CONADIC has no direct sanction power over permit holders; failure surfaces through DGJS inspection findings against the Manual Operativo.
Customer-interaction triggers

Behavioural-marker customer interactions

RG Critical Player Rights

The Manual Operativo for each permit holder must set out customer-interaction triggers based on behavioural markers such as session length, deposit velocity and chasing-losses patterns. Interactions and outcomes must be logged.

Requirements
  • Define behavioural markers in the Manual Operativo
  • Log every triggered interaction and its outcome
  • Review markers against incident data at least annually
There is no published federal default marker set; SEGOB approves each operator's framework on a case-by-case basis.
Customer-interaction — loss trigger

Loss-threshold customer-interaction trigger

RG Critical

Permit holders' Manual Operativo must include a loss-velocity trigger that initiates a documented RG outreach when a player's cumulative net losses over a rolling window exceed an operator-defined threshold. The outreach must offer deposit-limit, time-out and autoexclusión options.

Requirements
  • Define a rolling-window cumulative-loss threshold in the Manual Operativo
  • Initiate a documented RG outreach on threshold breach
  • Offer deposit limit, time-out and autoexclusión as outreach outcomes
  • Escalate repeated breaches to senior RG review
SEGOB does not publish a federal loss threshold; the operator-defined value is approved as part of the Manual Operativo review.
Customer-interaction — session-length trigger

Session-length and frequency interaction trigger

RG Critical Game Design

Operator RG frameworks must include a session-length trigger (typically continuous play exceeding two to four hours) and a frequency trigger (daily logins across consecutive days) that prompts a reality-check overlay and an RG team review of the player.

Requirements
  • Surface a reality-check overlay at the configured session-length threshold
  • Track consecutive-day login frequency as a separate marker
  • Refer flagged players to RG team review for outreach
  • Log overlay impressions, dismissals and downstream actions
PRODECON / PROFECO complaints

Formal player-complaint routes (PROFECO, PRODECON, DGJS)

Player Rights

Mexican players have three concurrent complaint avenues: DGJS (regulatory breach), PROFECO (consumer commercial dispute) and PRODECON for tax-withholding disputes against the operator's IEPS or ISR withholding. Permit holders must publish the three routes in their terms.

Requirements
  • Publish the DGJS, PROFECO and PRODECON escalation routes in the terms
  • Acknowledge complaints in writing within 5 business days
  • Maintain a single complaints register cross-tagged by route
  • Reconcile complaint patterns against RG and KYC controls quarterly
PROFECO — consumer protection

PROFECO consumer-protection escalation

Player Rights

The Procuraduría Federal del Consumidor exercises consumer-protection jurisdiction over the gambling commercial relationship, including bonus-term disputes, withdrawal delays and advertising claims. Players may escalate complaints to PROFECO independently of any DGJS process.

Requirements
  • Disclose the PROFECO escalation route in the terms and conditions
  • Respond to PROFECO complaints within statutory deadlines
  • Maintain a complaints log accessible to PROFECO and DGJS
  • Track PROFECO conciliation outcomes for systemic findings
PROFECO has issued sanction proceedings against gambling operators for misleading bonus communications and withdrawal delays.
Player limits — no federal default

No federal default deposit, loss or time limits

RG Critical Player Rights

Unlike Spain, Brazil and the United Kingdom, Mexico's RLFJS does not impose statutory default deposit, loss or time limits on player accounts. Limit-setting infrastructure is required by the Manual Operativo but the floor values, mandatory prompts and override controls are entirely operator-set.

Requirements
  • Offer deposit, loss and time-limit controls in the remote interface
  • Document the available limit set, granularity and minima in the Manual Operativo
  • Apply a minimum 24-hour cool-off before any limit increase takes effect
  • Track regulatory developments — federal defaults are a recurring reform-pipeline proposal
The absence of federal defaults is a key point of operator differentiation; SEGOB reviews each operator's limit framework during Manual Operativo approval.
RLFJS — in-venue RG signage

Mandatory in-venue responsible-gambling signage

RG Critical

Permit holders must display permanent responsible-gambling signage at the main entrance of every authorised establishment, at each bank of gaming positions, at cash desks and at restroom exits. Signage must include the 18-plus warning, autoexclusión access and the national addictions helpline.

Requirements
  • Display permanent RG signage at entrance, gaming banks, cash desks and restroom exits
  • Use lettering legible from at least three metres
  • Include the 18-plus warning, autoexclusión access and CONADIC / 800 helpline
  • Refresh signage on each Manual Operativo update or material RG policy change
DGJS inspectors check signage placement and legibility as part of every routine inspection.
RLFJS art. 13

Private domestic non-profit games excluded from the Reglamento

Article 13 excludes from the Reglamento occasional, non-habitual betting games held in a private home with no profit motive, played only by family members or close social contacts of the residents.

Requirements
  • Do not rely on art. 13 for any commercial activity — it covers genuinely private games only
  • Treat any habitual or fee-bearing private game as falling within the Reglamento
  • Document the non-commercial character of any borderline event
This is the narrow private-home carve-out; commercial relevance is essentially nil.
8
Theme 8

Advertising & marketing restrictions

Reglamento art. 87 governs gambling advertising and requires SEGOB authorisation for major campaigns. Cofepris claims overlapping jurisdiction over broadcast advertising on health-protection grounds, the Ley Federal de Telecomunicaciones y Radiodifusión sets media-channel rules, and the Ley General de Responsabilidades Administrativas prohibits inducement of public officials.

19 standards 18 player-flagged
95%
player-flagged
Regulatory risks this theme addresses
  • Running a major campaign without prior SEGOB authorisation
  • Broadcast advertising before the Cofepris dispute over jurisdiction is resolved in your favour
  • Affiliate or influencer content targeting minors or self-excluded players
RLFJS art. 84

Permitted scope of gambling advertising

Bonus & Ads

Article 84 of the Reglamento defines the permitted scope of advertising for permitted gambling activities: it must accurately describe the authorised game, identify the permit holder by corporate name and permit number, and be limited to activities and sites covered by the permit. Cross-promotion of unauthorised products through the permit-holder brand is prohibited.

Requirements
  • Identify the permit holder's corporate name and permit number in every advertisement
  • Limit content to activities and sites included in the permit
  • Avoid cross-promotion of unauthorised products under the permit-holder brand
  • Archive an audit-quality copy of every published advertisement
RLFJS art. 85 — ad standards

Prohibited advertising content

Bonus & Ads RG Critical

Article 85 prohibits gambling advertising that is deceptive, that misrepresents the probability of winning, that depicts or glamorises addictive behaviour, that targets or features minors, or that suggests gambling is a route to economic success or social validation.

Requirements
  • Reject creative that misrepresents the probability of winning
  • Exclude under-18s from casting, voice-over and audience targeting
  • Avoid scenarios depicting gambling as a solution to financial or social need
  • Reject taglines that glamorise chasing losses or extended play sessions
Although the article number for advertising in the RLFJS is contested in some scholarship, the operative content rules sit within the arts. 84-87 cluster.
RLFJS art. 86

Broadcast watershed for gambling advertising

Bonus & Ads

Article 86 restricts the broadcast of gambling advertising on open-signal television and radio to the post-22:00 watershed window, with carve-outs for sports-event sponsorship integrations that remain subject to the article 85 content standards.

Requirements
  • Schedule open-signal broadcast spots after the 22:00 watershed
  • Treat live-sports integrations as in-scope of article 85 even when running pre-watershed
  • Maintain broadcast-as-aired logs for IFT and DGJS inspection
  • Apply equivalent timing discipline to streaming and OTT placements
Industry practice has extended the 22:00 watershed treatment to high-reach streaming inventory even where statutory coverage is contested.
RLFJS art. 87

Advertising authorisation and content limits

Bonus & Ads Player Rights

Article 87 obliges permit holders to seek SEGOB authorisation for the advertising of permitted activities, prohibits the inclusion of minors, and requires accurate representation of the games and odds. Misleading or unauthorised advertising is a basis for sanction.

Requirements
  • Seek SEGOB authorisation before any major campaign
  • Exclude minors from advertising imagery and casting
  • Avoid claims that are misleading as to odds or expected return
  • Include responsible-gambling messaging in every campaign asset
RLFJS art. 87 — RG disclosure

Mandatory RG disclosures in advertising

Bonus & Ads RG Critical

Article 87 requires every gambling advertisement to carry a mandatory responsible-gambling message, the 18-plus age warning and a clearly legible reference to the CONADIC helpline. Disclosure must be present on both visual and audio creative.

Requirements
  • Carry the 18-plus warning on every visual asset and audio spot
  • Surface the CONADIC helpline reference in legible type or audible read-out
  • Include a responsible-gambling message at the close of every asset
  • Maintain a creative library evidencing disclosure on every flight
LFTR art. 246 — watershed enforcement

LFTR watershed enforcement by IFT

Bonus & Ads

Article 246 of the Ley Federal de Telecomunicaciones y Radiodifusión empowers the Instituto Federal de Telecomunicaciones to classify programming and enforce the protection of child audiences, providing the enforcement spine for the gambling-advertising watershed restriction.

Requirements
  • Reconcile every broadcast flight against the IFT classification matrix
  • Avoid placement adjacent to AA / A-classified programming
  • Honour any IFT enforcement actions affecting the schedule of competing brands
  • Document IFT classification evidence for each placement
Cofepris broadcast claim

Cofepris claim over broadcast advertising

Bonus & Ads

The Comisión Federal para la Protección contra Riesgos Sanitarios has historically asserted authority over the broadcast advertising of gambling on health-risk grounds and has issued sanction proceedings. The competence has been judicially contested.

Requirements
  • Submit broadcast scripts for Cofepris review where the regulator claims jurisdiction
  • Preserve evidence of the Cofepris filing for litigation defence
  • Track judicial outcomes that affect the competence claim
Cofepris — broadcast pre-approval

Cofepris broadcast pre-approval claim

Bonus & Ads

Cofepris claims jurisdiction to require prior approval of broadcast creative that includes references to recreational consumption or any addiction-adjacent imagery, on the basis of its health-risk mandate under the Ley General de Salud. The claim is contested by permit holders who treat SEGOB as the exclusive advertising authority.

Requirements
  • Map every creative against the Cofepris addiction-adjacency criteria
  • Where ambiguity exists, file the Cofepris pre-approval as a defensive measure
  • Preserve the Cofepris filing and any reply for litigation defence
  • Monitor amparo outcomes that delimit the Cofepris competence
Industry practice splits between defensive Cofepris filing and reliance on the SEGOB-exclusivity argument.
LFTR — broadcast standards

Telecommunications and broadcasting rules

Bonus & Ads

The Ley Federal de Telecomunicaciones y Radiodifusión and the Ley General de Salud constrain the schedule, content and intensity of broadcast gambling advertising, restricting placement during child-audience programming.

Requirements
  • Avoid placement in child-audience time bands
  • Honour any per-channel intensity ceilings in the IFT rules
  • Document compliance for each campaign flight
LGRA art. 52 — official endorsement

Public-official endorsement prohibition

Bonus & Ads

Article 52 of the Ley General de Responsabilidades Administrativas captures the giving of any benefit to a public servant, prohibiting the appearance of serving federal, state or municipal officials in gambling advertising whether paid or complimentary.

Requirements
  • Exclude serving public officials from casting in any campaign
  • Refuse complimentary or discounted play for public servants
  • Run an official-status screen for every featured talent
  • Document the screen result in the campaign compliance file
Affiliate registration

Affiliate engagement and registration

Affiliate Rules Bonus & Ads

Permit holders remain liable for the content distributed by their affiliates and influencers. Affiliate engagements must be documented in the Manual Operativo and SEGOB may require disclosure of marketing-partner contracts.

Requirements
  • Document every affiliate and influencer engagement
  • Audit affiliate content against the SEGOB content limits
  • Suspend affiliates that breach RG, age or honesty standards
Bonus-offer disclosure

Bonus and welcome-offer disclosure

Bonus & Ads

Welcome bonuses, free bets and other promotions must be disclosed with full terms in proximity to the headline claim, including wagering requirements, expiry and excluded games. The Manual Operativo must list every active promotion.

Requirements
  • Disclose full bonus terms next to headline claims
  • Avoid ambiguous wagering-requirement language
  • Include the active promotion list in the Manual Operativo
CONAR — voluntary code

CONAR voluntary advertising self-regulation

Bonus & Ads

The Consejo de Autorregulación y Ética Publicitaria (CONAR) operates a voluntary code that signatory advertisers and agencies apply across categories including gambling. The code overlays the Reglamento with industry norms on truthfulness, taste, and protection of vulnerable audiences, and CONAR may issue non-binding rulings on complaints.

Requirements
  • Sign the CONAR code and apply it as the secondary compliance layer
  • Submit campaigns for CONAR pre-clearance where the agency is a signatory
  • Respond to CONAR complaint rulings even where non-binding
  • Treat CONAR adverse rulings as Manual Operativo escalation triggers
CONAR rulings are non-binding but are commonly cited in DGJS and PROFECO proceedings as evidence of industry standards.
LGRA — public-official inducement

Anti-corruption inducement prohibition

The Ley General de Responsabilidades Administrativas prohibits the offering, promising or giving of any benefit to a public servant, capturing public-official endorsements and complimentary play arrangements.

Requirements
  • Prohibit complimentary play for public servants
  • Decline endorsements or appearances by serving officials
  • Maintain a written gifts-and-entertainment policy
Sheinbaum proposal — ad restrictions

Sheinbaum-era proposed advertising restrictions (proposed)

Bonus & Ads

Initiatives circulated in the Cámara de Diputados under the Sheinbaum administration propose to extend the 22:00 watershed to a full 06:00-22:00 prohibition, ban gambling advertising during sports broadcasts and on transport infrastructure, prohibit influencer marketing, and forbid the use of footballers and baseball players in gambling creative. None of the proposals has yet been promulgated in the DOF.

Requirements
  • Track the parliamentary status of each reform initiative
  • Model commercial impact of a sports-broadcast advertising ban
  • Audit influencer pipelines for divestment readiness
  • Avoid operational dependencies on the current ad regime persisting beyond 2026
Sheinbaum-era proposals echo Spain's Real Decreto 958/2020 and Italy's Dignità decree; the direction of travel is consolidative even where individual texts fail.
Sports endorsement restrictions

Sports figure endorsement restrictions

Bonus & Ads Affiliate Rules

Existing CONAR norms discourage and Sheinbaum-era proposals would prohibit the use of active footballers, baseball players and other sports figures in gambling advertising on the basis of their disproportionate influence on under-18 audiences. The Reglamento art. 85 prohibition on advertising that targets minors is the operative current back-stop.

Requirements
  • Apply enhanced due diligence to any active footballer or baseball-player endorsement
  • Avoid casting that the audience would recognise as adjacent to a national-team or LMB roster
  • Document the audience-modelling underpinning every athlete endorsement
  • Prepare divestment paths if a statutory ban is promulgated
The Liga MX sponsorship ecosystem already operates under voluntary restrictions on shirt-front gambling logos in youth-team contexts.
Student-audience restriction

Restrictions on advertising in student environments

Bonus & Ads RG Critical

SEP and CONACYT (now CONAHCYT) guidance prohibits the placement of gambling advertising in or adjacent to educational establishments, on official student platforms or in association with student-targeted scholarships and contests. The Reglamento art. 85 minors prohibition is the operative back-stop where the SEP guidance is not directly enforceable on the operator.

Requirements
  • Avoid OOH placements within a defined exclusion zone around schools and universities
  • Decline sponsorship of student-targeted scholarships or academic contests
  • Suppress audience targeting that resolves to under-18 student segments
  • Audit programmatic placements against an education-exclusion list quarterly
RLFJS art. 9

Advertising and propaganda rules for permitted games and venues

Bonus & Ads RG Critical Player Rights

Article 9 requires advertising of authorised games and venues to comply with the applicable rules. Advertising may only be deployed once SEGOB has granted the permit. Permitted establishments may not explicitly promote the bets they take; ads must be clear and non-misleading, carry the permit number, state that betting is prohibited to minors and include a responsible-gambling message.

Requirements
  • Display the SEGOB permit number on every ad
  • Carry a minors-prohibited notice on every ad
  • Carry a responsible-gambling invitation on every ad
  • Do not explicitly promote the specific bets offered at the venue
Reformed in 2012 and 2013; the responsible-gambling message and permit-number obligations have been in force since the 2013 reform.
RLFJS art. 117

Sorteos transmitted by mass media — RTC oversight

Bonus & Ads

Article 117 brings commercial contest, Q&A and similar programmes offering prizes (where chance intervenes at any stage and they are broadcast or promoted via mass media) within SEGOB authorisation and supervision via the Dirección General de Radio, Televisión y Cinematografía, alongside applicable rules and the Reglamento. The Unidad de Gobierno's favourable opinion is required. Concessionaires and broadcasters must verify that third-party promoters of such contests hold prior authorisation.

Requirements
  • Route mass-media draw and contest formats through SEGOB-RTC for authorisation
  • Obtain the Unidad de Gobierno favourable opinion
  • Verify third-party promoter authorisations before airing
9
Theme 9

Sheinbaum-era reform pipeline

Reform of the 1947 framework has been a perennial pending file in the Cámara de Diputados since 2014. Initiatives under the Sheinbaum administration concentrate on creating a dedicated gambling commission, codifying the online channel and reinforcing the slot-machine ban beyond the disputed 2023 decree. None of the leading initiatives has yet been promulgated.

7 standards 1 player-flagged
14%
player-flagged
Regulatory risks this theme addresses
  • Building operational dependencies on a pending statute before publication in the DOF
  • Ignoring the cumulative direction of travel evident across successive initiatives
  • Failing to engage with the parliamentary consultation process
Iniciativa Ley Federal de Juegos 2024

Proposed Ley Federal de Juegos with Apuestas y Sorteos

Initiatives presented in the LXVI legislatura propose to replace the 1947 LFJS with a new framework statute codifying the online channel, introducing class-based licensing and creating a dedicated regulatory commission. The proposal would also lift the slot-machine ban into primary legislation.

Requirements
  • Track the dictamen of the Comisiones Unidas
  • Engage with the parliamentary consultation
  • Plan permit-equivalence scenarios for transition
Provisional citation — verify the current expediente number on the Sistema de Información Legislativa before relying on it.
Proposed Comisión Federal de Juegos

Proposed Federal Gambling Commission

Most leading initiatives propose to detach the regulatory function from SEGOB and establish a Comisión Federal de Juegos with technical autonomy, modelled on Spain's DGOJ and Colombia's Coljuegos.

Requirements
  • Plan for a transitional handover from SEGOB to the new commission
  • Track the budgetary appropriation that would accompany creation
  • Identify changes to the inspection-and-sanction process
Reform politics — Morena/PRI/PAN

Parliamentary positioning across blocs

Morena and allied parties have framed the reform as a tightening of consumer-protection and anti-money-laundering rules, while opposition blocs have prioritised regulatory-certainty arguments raised by permit holders. The composition of the LXVI Cámara de Diputados conditions the chance of approval.

Requirements
  • Map bloc positions against each contested article
  • Plan for divergent committee outcomes
  • Maintain a government-relations register
Borrador SEGOB Ley Federal de Juegos con Apuesta y Sorteos

(draft) Ley Federal de Juegos con Apuesta y Sorteos — SEGOB working text

SEGOB has circulated an internal working draft of a new Ley Federal de Juegos con Apuesta y Sorteos to replace the 1947 LFJS, restructuring permit classes, codifying the online channel, recognising e-sports wagering and creating a dedicated administrative authority. The draft is not yet public and no version has been formally introduced in the Cámara de Diputados.

Requirements
  • Track every leaked or officially released draft version
  • Avoid public commentary or compliance plans grounded in unverified draft language
  • Build internal scenarios for both reform and status-quo outcomes
  • Engage industry chambers for coordinated technical input once a draft is published
Status as of 2026-05-30: internal SEGOB working text only — no DOF publication and no formal turno to commission.
Propuesta — Comisión Nacional de Juegos

(proposed) New federal gambling commission — institutional design

The SEGOB working draft proposes the creation of a Comisión Nacional de Juegos as a decentralised technical body absorbing the current DGJS functions, with operational, technical-certification and sanctioning powers, financed by permit fees and a portion of IEPS revenue.

Requirements
  • Assume continuity of the DGJS until any commission is formally constituted
  • Identify which current SEGOB powers would migrate under each draft version
  • Map fee-financed cost recovery against current free-of-charge supervision
  • Monitor parallel reform of LOAPF art. 27 required for the migration
No commission exists in force; the LFJS still vests powers in SEGOB and any commission requires both LFJS and LOAPF amendments.
Propuesta — bloqueo estatutario

(proposed) Statutory ISP blocking of unlicensed offshore operators

The draft reform anticipates a statutory power for the future commission to instruct telecommunications concesionarios to block access to unlicensed offshore gambling sites — the Mexican analogue of Spain's DGOJ and Colombia's Coljuegos blocking regimes. The power does not yet exist in force.

Requirements
  • Treat current enforcement as ad hoc and payment-channel-led until statutory blocking is enacted
  • Plan for an enforcement step-up if the power is enacted
  • Coordinate technical compliance roadmap with the IFT (Instituto Federal de Telecomunicaciones)
  • Distinguish proposed statutory blocking from the SAT IEPS-driven blocking already enacted in 2026
The current 2026 SAT bloqueo lever is tax-driven, not gambling-conduct-driven; the proposed statutory power would target the underlying gambling activity directly.
FIFA World Cup 2026 — presión calendaria

World Cup 2026 timeline pressure on Mexican gambling reform

RG Critical

Mexico co-hosts the FIFA World Cup in June and July 2026, with matches in CDMX, Guadalajara and Monterrey. The tournament concentrates demand for sports-betting capacity, intensifies pressure on SEGOB enforcement of unlicensed offshore operators and accelerates the political timetable for the reform pipeline.

Requirements
  • Build capacity plans for the June-July 2026 spike
  • Coordinate enforcement contingencies with SEGOB for illegal-operator surges
  • Track any expedited DOF publication tied to the World Cup window
  • Plan responsible-gambling messaging spikes around the tournament
Industry chambers have repeatedly cited the World Cup as the catalyst for resolving the reform pipeline in 2026.
10
Theme 10

Enforcement & criminal sanctions

Sanctions sit on three rails: SEGOB administrative sanctions under the Reglamento (fines, closure, suspension and revocation), SAT closures and tax enforcement, and the criminal prohibition of unauthorised games in arts. 257-264 of the Código Penal Federal. The Fiscalía General de la República prosecutes the criminal track.

28 standards 6 player-flagged
21%
player-flagged
Regulatory risks this theme addresses
  • Treating administrative sanctions as the only enforcement track
  • Underestimating SAT closure as a recovery lever for unpaid IEPS
  • Personal criminal exposure for directors and operators of unlicensed sites
RLFJS art. 151

Administrative sanction ladder

Article 151 sets out the principal SEGOB sanctions: fines, temporary closure, suspension of the permit and definitive revocation. Sanctions are imposed in proportion to gravity, recidivism and economic capacity.

Requirements
  • Maintain a sanctions register and lessons-learned process
  • Engage in the procedural defence at the acta stage
  • Provision for fines in line with article 152
Reglamento Interior SEGOB art. 155

Grounds for permit revocation

Article 155 lists the grounds for definitive permit revocation, including persistent breach of the operating manual, false statements in the application file, illegal acceptance of wagers and conviction of controllers for serious offences.

Requirements
  • Treat material breaches as revocation triggers
  • Investigate and remediate any false-statement allegation
  • Monitor controller-conduct risk across the group
Citation corrected: previously labelled "RLFJS art. 155" — RLFJS only runs to art. 153; this article is from Reglamento Interior SEGOB.
Reglamento Interior SEGOB art. 158

Procedural rights in sanction proceedings

Player Rights

Article 158 guarantees the right to be heard, to produce evidence and to be notified of every procedural step in a sanction proceeding. Procedural defects are a routine basis for amparo challenges to SEGOB decisions.

Requirements
  • Diary every notification and response deadline
  • Produce evidence in the format SEGOB requests
  • Preserve procedural defects for amparo defence
Citation corrected: previously labelled "RLFJS art. 158" — RLFJS only runs to art. 153; this article is from Reglamento Interior SEGOB.
CPF art. 257

Operating prohibited games — base offence

Article 257 of the Código Penal Federal criminalises the establishment or operation of prohibited games of chance, with imprisonment and fines. The offence captures unlicensed operation and operation outside the scope of a SEGOB permit.

Requirements
  • Avoid any operation outside the SEGOB permit perimeter
  • Assess the risk of personal criminal exposure for directors
  • Coordinate with criminal-defence counsel in any FGR proceeding
CPF art. 258

Hosting and intermediation offences

Article 258 extends criminal liability to those who host, provide premises or intermediate prohibited games, including digital intermediaries that knowingly facilitate operation.

Requirements
  • Assess hosting and intermediation exposure across the value chain
  • Refuse to host unlicensed gambling content on shared infrastructure
  • Maintain takedown procedures on notice of illegality
CPF arts. 259-264

Penalties, aggravations and corporate liability

Player Rights

Articles 259 to 264 set the penalty structure, aggravating circumstances and the rules on corporate liability for the offences of arts. 257 and 258. Penalties may be increased where minors participate.

Requirements
  • Map the aggravation triggers against the activity
  • Apply heightened controls where minors might access the activity
  • Plan for corporate liability alongside individual exposure
SAT closure — IEPS

SAT operative closure for unpaid IEPS

The SAT may order operational closure of a permitted establishment for unpaid IEPS under the Código Fiscal de la Federación, in coordination with SEGOB. Closure is a frequently used recovery lever and can precede formal sanction.

Requirements
  • Maintain current IEPS filings to avoid closure exposure
  • Coordinate SAT and SEGOB communications in any dispute
  • Plan continuity arrangements for short-term closure
FGR/UIF — lavado en redes ilegales

Money-laundering prosecutions against illegal-operator networks

Player Rights

The Unidad de Inteligencia Financiera and Fiscalía General de la República have pursued high-profile money-laundering investigations against clandestine gambling networks under the Código Penal Federal Title XXIII (operaciones con recursos de procedencia ilícita), with parallel asset-freezing under the LFED (Ley Federal de Extinción de Dominio).

Requirements
  • Maintain ring-fenced banking and avoid commingling with third-party cash flows
  • Refresh LFPIORPI screening against the UIF lista de personas bloqueadas
  • Document the source of funds for any high-value transfer
  • Prepare for extinción de dominio risk where any asset is touched by an investigated counterparty
Asset-freezing under the LFED is precautionary and proceeds independently of the criminal case.
Operativos — salas clandestinas 2024-2026

Federal raids against clandestine gambling halls — 2024-2026

Player Rights

The Fiscalía General de la República, supported by the Guardia Nacional and SEGOB, executed multiple operativos against clandestine gambling halls in CDMX, Estado de México, Tamaulipas and Quintana Roo during 2024-2026, charging operators under CPF arts. 257-264 and seizing equipment.

Requirements
  • Maintain documentary evidence distinguishing the permit-holder estate from any third-party premises
  • Refuse any informal sub-letting of permit-authorised sites
  • Coordinate immediately with counsel if equipment is misidentified in a raid
  • Track the FGR public communications for sector priorities
Clandestine-hall raids have been used by the Sheinbaum administration as a public signal of resolve while the broader reform pipeline advances.
SAT — operativos IEPS 2024-2026

SAT operative closures for IEPS evasion — 2024-2026 wave

Player Rights

Between 2024 and 2026 the SAT executed a documented wave of clausuras temporales against gambling establishments for unpaid or under-declared IEPS, accompanied by seizure of gaming equipment and accounting records. The wave intensified in the run-up to the Paquete Económico 2026 reform.

Requirements
  • Pre-empt a SAT clausura by maintaining current IEPS declarations
  • Document inventory and accounting integrity to limit seizure scope
  • Prepare a precautionary amparo where a clausura appears imminent
  • Track the SAT enforcement bulletin for sector-level priorities
Clausura risk rose materially after the 2025 rate increase debate and SAT data-sharing improvements with SEGOB.
SEGOB — suspensiones de permiso 2024-2026

SEGOB permit suspensions — 2024-2026 enforcement record

The DGJS published a record of suspensiones and revocaciones during 2024-2026 targeting permit holders for operation outside authorised sites, unauthorised slot operation outside an amparo umbrella, and failures of fit-and-proper compliance after changes of control. Suspended permits typically remain on the public registry pending administrative appeal.

Requirements
  • Audit operating sites against the permit-resolution annex monthly
  • Refresh fit-and-proper evidence on every change of control
  • Pre-prepare administrative-appeal documentation
  • Avoid relying on third-party amparos for slot operations
Several 2024-2026 suspensions were lifted on appeal where the underlying inspection acta administrativa contained procedural defects.
Bloqueo estatutario — no en vigor

Statutory online-blocking power — not yet in force

Unlike Spain (DGOJ), Colombia (Coljuegos), the Philippines (DICT/NTC) or Argentina (LOTBA), Mexico has no dedicated statutory power for a gambling regulator to instruct ISPs to block unlicensed online gambling sites. Current enforcement relies on payment-channel disruption, criminal referrals under CPF arts. 257-264 and — from 2026 — the SAT IEPS-driven bloqueo for foreign-resident operators.

Requirements
  • Do not assume an IFT or SEGOB takedown can be obtained on demand
  • Treat payment-channel cooperation as the primary lever against offshore exposure
  • Distinguish the 2026 SAT bloqueo (tax-led) from a future gambling-led statutory blocking power
  • Track the SEGOB draft reform for any consolidated blocking provision
The absence of statutory blocking is a primary reason the unlicensed offshore channel has historically dominated Mexican online play.
Amparos vs Decreto 23-Nov-2023 — estado

Status of amparos against the 23 Nov 2023 slot decree

Player Rights

As of mid-2026 the vast majority of amparos filed against the 23 November 2023 slot-machine ban remain at the provisional-suspension stage, allowing continued operation pending resolution. Several definitive suspensions have been granted, but no SCJN merits ruling has yet been issued and no unifying jurisprudencia has been published.

Requirements
  • Distinguish provisional from definitive suspension orders before relying on any umbrella
  • Verify the named quejoso matches the operating permit holder
  • Refresh the suspension status before each operating day
  • Track any contradicción de tesis that would trigger a SCJN unifying ruling
Status as of 2026-05-30: predominantly provisional, several definitive, no SCJN merits decision yet. The political pressure of the 2026 reform pipeline may overtake the judicial track.
SCJN — federalización del juego

SCJN jurisprudence — federal exclusivity over gambling

The Suprema Corte de Justicia de la Nación has repeatedly upheld the constitutional doctrine that regulation of games with wagers is reserved to the federation under art. 73 fracción X of the Constitución, invalidating state or municipal attempts to issue parallel gambling permits and reinforcing SEGOB's exclusive perimeter.

Requirements
  • Defend any preemption challenge by citing the SCJN federalisation line
  • Treat any purported state or municipal gambling permit as constitutionally void
  • Litigate state-tax design defensively where it crosses into regulatory territory
  • Monitor SCJN tesis aisladas for any narrowing of the doctrine
The federalisation doctrine has been stable across multiple SCJN compositions and survives the 2024 judicial reform.
RLFJS art. 139

SEGOB designates inspectors by oficio

Article 139 lets SEGOB designate the necessary inspectors by written oficio specifying appointment and the commission to perform.

Requirements
  • Verify the inspector's oficio de comisión on arrival
  • Hold a current oficio on file alongside the inspection record
RLFJS art. 140

Inspector eligibility — five conditions

Article 140 requires inspectors to be Mexican citizens of legal age in full enjoyment of civil rights, not under criminal process or convicted of property, tax or organised-crime offences, with the necessary experience and knowledge, having attended and passed the SEGOB course and having passed performance examinations. Inspectors must also attend ongoing technical-update training.

Requirements
  • Verify that inspectors visiting the venue carry valid SEGOB credentialling
The compliance burden here is SEGOB-internal; operator obligation is limited to verifying credentials.
RLFJS art. 141

Inspector identification on duty

Article 141 requires inspectors on duty to identify themselves with a current SEGOB credential and the corresponding oficio de comisión.

Requirements
  • Demand the credential and oficio at the start of every inspection
  • Log the inspector's identification details
RLFJS art. 142

Inspector powers and duties — 34 fractions

Article 142 sets out the 34 powers and duties of SEGOB inspectors, including identification, enforcement, citation, prize-seeding oversight, document verification, weapons-presence enforcement, conduct of events with transparency, on-the-fly correction, full-event presence, immediate suspension where anomalies arise, signature of supporting evidence, scheduling of large-prize delivery (above 1,500 daily UMAs), bar on prize delivery to minors, witnessing prize delivery, recording details for commercialisation-system draws, certifying events, preventing manipulation, reporting anomalies, executing venue closures, filing criminal denunciations, drawing up the formal acta, recording cancellations, executing instructions without excess, calling on public force, reporting bribery attempts, transmitting the file to SEGOB within 72 hours, preparing prize-and-ticket schedules, and informing SEGOB of unauthorised gambling.

Requirements
  • Cooperate with the inspector's full art. 142 remit
  • Be prepared for immediate suspension or closure if anomalies arise
  • Provide records on demand within the inspection window
This is the operational backbone of SEGOB on-site enforcement; non-cooperation typically escalates to a grave infraction.
RLFJS art. 143

Inspector disqualification cases

Article 143 disqualifies inspectors from intervening where they have a family, friendship or subordination relationship with the permit holder, participate themselves or via third parties in the commissioned event, know that family or friends will participate, hold a personal interest in the event, or where other laws so require.

Requirements
  • Raise any apparent inspector conflict of interest with SEGOB
  • Maintain records sufficient to support a recusal request
RLFJS art. 144

Inspector prohibitions

Article 144 prohibits inspectors from exploiting their position, favouring participants, demanding compensation, overstaying, attending under the influence, representing contestants, leaking information, behaving abusively, using physical or moral violence, acting immorally, suggesting unauthorised events, attending winners' homes, and falsifying records.

Requirements
  • Report any breach of art. 144 to SEGOB
  • Document any solicitation or undue conduct in writing
RLFJS art. 145

Inspections governed by LFPA

Article 145 subjects inspector functions to the Ley Federal de Procedimiento Administrativo, with the oficio de comisión naming the inspected person, the place, period, scope and purpose of inspection.

Requirements
  • Check the oficio for required LFPA content
  • Limit the inspection to the stated scope and period
RLFJS art. 146

Paraestatal-sponsored events — SEGOB supervision (Lotería Nacional excepted)

Article 146 (reformed 16 November 2023) requires SEGOB to supervise events run by paraestatal welfare entities by designating the necessary inspectors, with the Lotería Nacional excepted.

Requirements
  • Coordinate with SEGOB on inspector designation for paraestatal welfare events
Operator-side relevance is limited; main consequence is the Lotería Nacional exception.
RLFJS art. 147

Sanction types — fines, arrest, suspension, revocation and closure

Article 147 sets the four sanction types for violations of the LFJS, Reglamento and permit terms: fine, arrest, suspension of functions and permit revocation with closure. Sanctions may be combined; SEGOB individualises them under the LFPA considering the nature, gravity and frequency of the infraction.

Requirements
  • Track sanction exposure across the four categories
  • Plan defence strategy in line with LFPA individualisation criteria
RLFJS art. 148

Minor infractions — fine up to 10,000 pesos and arrest

Article 148 sanctions infractions of the LFJS, Reglamento and permit terms that are not grave or frequent with a fine of up to 10,000 pesos and, where applicable, arrest.

Requirements
  • Note the 10,000-peso ceiling for minor sanctions
  • Distinguish minor from grave infractions in defence pleadings
The 10,000-peso ceiling is widely seen as inadequately deterrent; reform proposals routinely target it.
RLFJS art. 149

Grave or frequent infractions — revocation and closure

Article 149 sanctions grave or frequent infractions of the LFJS, Reglamento and permit terms with permit revocation and, where applicable, venue closure. Infractions are 'frequent' when committed twice or more within one year.

Requirements
  • Track recurrence of every notified infraction within a 12-month window
  • Treat any second similar notification within a year as crossing the frequency threshold
RLFJS art. 150

Suspension of individuals — up to one year

Article 150 sanctions players, referees, brokers and any other persons performing functions in the show, game, venue or sorteo with suspension from that activity for up to one year, where they breach the LFJS or Reglamento.

Requirements
  • Track suspensions imposed on staff for the duration of the suspension
  • Replace suspended staff in line with art. 44 eligibility
RLFJS art. 152

Prior notification of administrative process

Article 152 requires SEGOB to notify the alleged infractor of the start of the administrative procedure so that evidence and arguments can be presented under the applicable rules.

Requirements
  • Demand timely notification of any sanction procedure
  • Lodge evidence and arguments within the notified window
RLFJS art. 153

Five-year statute of limitations on administrative sanctions

Article 153 caps SEGOB's power to impose administrative sanctions at five years, running continuously from the date of the infraction if completed or from when a continuing infraction ceased.

Requirements
  • Diary the five-year limitation window for each notified infraction
  • Raise limitation defences where applicable