Internet operation
Articles 85 and 86 of the regulation contemplate taking bets by internet, telephone or electronic means. They require an internal control system that preserves integrity and records at least the account and identity of the bettor, date, time, transaction number, amount and selection. The betting mechanics must receive prior approval from the Ministry.
Article 86 links confirmation of electronic payment to a banking institution. That wording, written before today’s stablecoins and self-custody wallets, raises a material question: an on-chain transfer should not be assumed to satisfy the approved method. The real scope depends on the permit, the approved mechanics and the authority’s criteria.
Crypto assets: a gap is not an authorisation
Mexico has financial regulation on virtual assets, but that is not a gambling licence. An operator must meet gambling, payments, anti-money-laundering, consumer, tax and data rules at the same time. The label “crypto” can describe an asset or a technology without resolving any of those layers.
Our editorial recommendation is to demand a documentary answer to three questions: which permit covers the product; which condition authorises the payment method; and which entity answers for withdrawals and complaints. If the answer rests only on private terms or a foreign licence, it does not show Mexican authorisation.
Protection and practical checks
The DGJS publishes information on illegal gambling and reminds people to check that whoever organises the activity holds a permit. This check matters most with look-alike domains, apps downloaded outside official stores, or requests to deposit to constantly changing addresses.
Before transferring, a user can save the company name, permit number, domain, product rules, withdrawal policy and support channels. Crypto transactions can be irreversible; a hash proves a transfer, not the recipient’s legal obligation. In a dispute, keeping screenshots, receipts and communications improves the chance of reconstructing the facts.
Modernisation agenda
The Mexican framework recognises remote operation but retains concepts and banking dependencies from before Web3. A useful update should define neutrally what counts as payment, set custody, segregation and traceability requirements, and publish a register of domains and brands linked to each permit.
It should also distinguish low- and high-risk controls, fix withdrawal and complaint times, and require identifiable advertising. Until a specific rule exists, prudence means not presenting the absence of an express crypto prohibition as an authorisation.
Data needed to assess a reform
To assess a future reform we propose publishing data on channelling, processing times, complaints, withdrawals, sanctions and detected illegal activity. Without a baseline it is easy to attribute any change to the new framework. Transitional rules should explain the treatment of balances and contracts, and the DGJS should offer a domain checker linking permit, responsible entity and official support channels.
Technological neutrality does not mean no rules. It means defining enforceable outcomes — identification, segregation, traceability, security and redress — without mandating a single brand or architecture. On that approach an innovation can be judged by the risk it adds and not only by the word “crypto” in its advertising.
Primary sources
Links consulted to verify the regulatory facts. Editorial interpretation is the responsibility of this site.
Application depends on the permit, the product and the specific facts. Check current texts and take local advice.