Why your Mexican broker checks the SAT 69-B list, and what happens if a supplier is on it

Your broker emails you a question that wasn't in last year's onboarding: "Can you confirm none of your suppliers or related parties appear on the SAT's 69-B list?" If that term lands somewhere between unfamiliar and alarming, you're not alone, and the answer matters more in 2026 than it ever has. This guide explains what the 69-B list is, why your broker is now obligated to screen against it, and what actually happens if a counterparty shows up on it.

A note before we start: this is an operational explainer, not legal advice. The 69-B procedure has specific legal consequences that depend on your exact situation, and for those you should consult your tax attorney. What we can do is explain how the list affects your clearance and what to watch for operationally.

What the 69-B list actually is

Article 69-B of the Código Fiscal de la Federación targets companies the SAT presumes are issuing invoices for operations that didn't really happen, the so-called empresas que facturan operaciones simuladas (EFOS). In plain terms, it's the mechanism the tax authority uses to flag invoices it believes are fictitious, and the businesses behind them.

The list works in two stages, and the distinction is everything.

First, the SAT publishes a company as a presunto: presumed to be issuing simulated invoices. This is a presumption, not a final determination, and the company has a window to rebut it. Second, if the presumption isn't successfully challenged, the company moves to definitivo: a final determination that its operations are simulated. The two-stage structure is set out in Article 69-B itself.

There are related lists worth knowing by name, because your broker screens against all of them: Articles 69, 69-B, 69-B Bis, and 49 Bis of the CFF, which the verification duty under Regla 1.4.14 references explicitly. For the purposes of this guide, 69-B is the one most people mean when they say "the SAT blacklist."

Why your broker now has to check it

Until 2026, screening your counterparties against the 69-B list was good practice. Now it's a documented obligation that sits inside the file your broker keeps on you.

Under Regla 1.4.14 of the RGCE 2026, the broker must hold a declaration under oath that they verified you are not on the watchlists, and that you're not linked, in the terms of Article 68 of the Ley Aduanera, to taxpayers on the 69-B list. And because the 2026 reform made the broker a responsable solidario for the operations they promote, that verification is no longer a courtesy. It's how they protect their patente while clearing your cargo.

There's a timing nuance that catches operations off guard: this isn't a one-time check at onboarding. A supplier can be perfectly clean when your file is built and land on a list months later. In our work across the corridor, the screening that actually protects you happens before each operation, or at minimum on a regular cadence, because the list is a moving target.

What happens if a counterparty shows up on it

This is where the presunto-versus-definitivo distinction does the work.

If a counterparty appears as a presunto, our operational guidance is that you can keep operating, but with caution. Request additional documentation that substantiates the materiality of your dealings with that party, and monitor their status closely. The presumption can be rebutted, and a presunto listing is not an automatic stop.

If a counterparty moves to definitivo, the posture changes sharply: suspend operations with that party immediately. A final determination of simulated operations is the kind of exposure that can stall your clearance and create tax risk that reaches well beyond customs.

Common mistake: Assuming the list only matters if you are on it. The verification reaches your suppliers and related parties too. A clean importer with a flagged supplier can still find their clearance under scrutiny, which is why the screening is about your whole counterparty network, not just your own RFC.

The deeper point: your materiality file and your 69-B exposure are connected. If you can document genuine operations with a flagged-but-presunto counterparty, you're in a far stronger position than an operation that can't prove its dealings were real. This is one more reason the materiality evidence in your broker file isn't busywork. It's the support that holds up if a counterparty's status changes.

Q: A supplier we use just appeared on the 69-B presunto list. Do we have to stop everything?

A (Santiago Obeso, Head of Legal & Compliance, Joffroy): Not automatically. A presunto listing is a presumption, not a final ruling, and the supplier has the right to contest it. Operationally, the move is to tighten: gather documentation proving your transactions with them were real, monitor their status, and be ready to pause if they go definitivo. What you should not do is ignore it or assume it resolves itself. And for the tax implications specific to your situation, bring in your fiscal counsel. That's their terrain, not ours.

Common misconceptions

"This is just a tax issue, not a customs issue." It's both now. The verification lives inside the customs file your broker must maintain, and an exposure can directly affect clearance.

"If my supplier is on the list, that's their problem." Their listing becomes your operational problem the moment it touches a transaction in your file. You don't control their status, but you do control how well you've documented your dealings with them.

"A presunto listing means we have to cut the supplier immediately." Not necessarily. Presunto is a presumption that can be rebutted. The disciplined response is heightened documentation and monitoring, not a reflexive stop. (A definitivo determination is the one that warrants immediate suspension.)

"We checked at onboarding, so we're covered." The list updates continuously. A point-in-time check at onboarding doesn't protect you against a counterparty that gets listed later.

When to bring in expert help

Bring in your tax attorney whenever a counterparty's listing creates a question about your own fiscal position. The legal consequences of 69-B are specific and situation-dependent, and that's counsel's domain, not a customs broker's. Bring in your customs partner when the question is operational: how to screen efficiently across a large supplier base, how to document materiality so it holds up, and how to keep your broker file current as counterparties move on and off the lists.

The 69-B list sounds frightening because the word "blacklist" is frightening. But operationally, it rewards the same discipline everything else in the 2026 reform rewards: know your counterparties, document your dealings, and keep your file current. The companies that screen continuously and document thoroughly treat a counterparty's listing as a manageable event. The ones who don't are left treating it as a crisis, because for them, it is one.

Don't wait for a held shipment to find out whether your counterparty screening would survive scrutiny. Ask us to review how your broker file handles 69-B exposure across your supplier base. Talk to a Joffroy expert.

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