, IFPEs)—participation in virtual asset transactions is strictly limited. In accordance with Circular 4/2019 issued by the Mexican Central Bank, these institutions may only use virtual assets for internal operations, and solely with prior written authorisation from Banxico. To the best of our knowledge, as of July 2025, no financial institution has received such authorisation.
In contrast, VASPs that are not regulated financial institutions may offer services involving the exchange, custody, or transfer of cryptocurrencies and other digital assets to the public. However, when operating within Mexican territory, these entities are considered subject to AML oversight under the AML Law. Specifically, they must register with the Tax Administration Service (SAT), implement robust KYC procedures, submit transaction reports to the Financial Intelligence Unit (UIF), and maintain internal controls to mitigate AML/CFT risks. Non-compliance may result in administrative sanctions, financial penalties, and suspension of activities.
Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area
A particular aspect where the current legal framework has been mute is the use of virtual assets as securities. Initially, securities in Mexico are regulated by the Securities Market Law which defines a security as 'the shares, obligations, bonds, optional titles, certificates, promissory notes, letters of exchange and other named or unnamed negotiable instruments, whether recorded or not in a registry, susceptible to circulation in securities markets, issued in series or in mass and that represent the stock of a company, a part of an asset or the participation in a collective credit or any individual right, in terms of applicable local or foreign laws'. While this would give the impression that virtual assets could, in some cases, serve as securities, the Central Bank holds the (non-binding) opinion that any virtual asset representative of an underlying asset (be it shares, bonds etc.) is not really a virtual asset (without clarifying what such digital value representation would be). While such definition is different to the one provided by the FinTech Law, it sheds light on the opinion Mexican regulators hold on the use of virtual assets as tradeable securities.
Economic conditions
Market size for financial services using crypto currencies and biggest companies in this business area
The local market leader is Bitso.
Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area
Future changes to the current regulation could vastly impact the reach and scope of the current market, expanding transactions and adoption of said sector. Changes to applicable legislation is expected in the near future.