ALN Mining Law Firm

ALN Mining Law Firm advised Vizsla Royalties Corp. (TSX-V: VROY) in connection with a definitive agreement with Elemental Royalty Corporation (TSX: ELE; NASDAQ: ELE), pursuant to which Elemental will acquire all issued and outstanding shares of Vizsla Royalties in a transaction valued at approximately US$240 million. The transaction marks a strategic milestone for both companies. For Elemental, it represents the largest single-asset acquisition in the company’s history and further strengthens its exposure to high-quality silver and gold assets through royalties tied to the Panuco Silver-Gold Project in Mexico, one of the world’s most significant advanced-stage silver projects.   For Vizsla Royalties, the transaction reflects the successful execution of the value creation strategy implemented since its 2024 spinout, while providing shareholders with immediate exposure to Elemental’s diversified royalty portfolio and continued participation in the long-term growth potential of the Panuco Project.   ALN acted as Mexican legal counsel to Vizsla Royalties, providing strategic advice on the legal aspects of the transaction. The deal further reinforces the firm’s experience in complex mining transactions and its ability to advise on high-value cross-border matters within the mining sector.

Canadian mining company Silverco Mining Ltd. announced the execution of a definitive share exchange agreement to acquire all issued and outstanding shares of Nuevo Silver Inc. in a transaction valued at approximately CAD$168 million, pursuant to which Nuevo Silver Inc. will become a wholly owned subsidiary of Silverco. As part of the transaction, Nuevo Silver shareholders will receive an aggregate of 16,802,316 common shares of Silverco. Nuevo Silver currently holds a 100% interest in the La Negra mine, located in Querétaro, Mexico, an operating silver-producing mine. As part of the transaction, Silverco will assume Nuevo Silver’s existing debt of approximately US$11 million related to the currently operating La Negra mine. In addition, Silverco will assume future obligations of up to US$12.5 million in milestone payments and up to US$5 million in contingent payments potentially owed to the former owner of the La Negra mine. Following completion of the transaction, former Nuevo Silver shareholders are expected to hold approximately 31% of Silverco’s outstanding shares, while existing Silverco shareholders will retain the remaining 69%. Closing of the transaction remains subject to customary regulatory and corporate conditions, including final approval from the TSX Venture Exchange (TSXV), which has already granted conditional acceptance of the transaction. This acquisition represents a significant strategic step for Silverco, adding a producing silver asset in Mexico to its portfolio and strengthening its presence within the regional mining sector. At ALN Mining Law Firm, we are proud to have advised Silverco Mining Ltd. on this important transaction, contributing our specialized legal expertise in the mining industry and supporting our clients in strategic cross-border transactions.

Mexico’s proposed replacement of the General Law of Ecological Balance and Environmental Protection (LGEEPA) should not be understood as a routine legislative update. Signed by the President on 26 August 2026, submitted to the Chamber of Deputies and published in the Parliamentary Gazette on 1 September, the initiative would repeal the statute enacted in 1988 and issue a new law under the same name, comprising 331 articles and 13 transitional provisions. While much of the existing regulatory structure would remain recognisable, the proposal could significantly alter the legal position of regulated projects through broader environmental principles, stronger enforcement powers and new mechanisms affecting previously granted authorisations. The direction of reform is understandable, as Mexico needs effective tools to prevent environmental damage, address cumulative impacts and secure restoration obligations long after productive activities have ended. Yet stronger regulation is not necessarily better regulation. For capital-intensive industries such as mining, the decisive question is whether the proposed powers would operate within sufficiently clear, technically grounded and predictable rules. From Policy Principles to Operative Legal RulesOne of the initiative’s most consequential changes is the stronger legal role assigned to environmental principles. Article 16 addresses prevention, precaution, responsibility for environmental harm, pro natura interpretation and the superior interest of the environment. Other provisions connect these principles to the granting of permits and the resolution of enforcement proceedings. Rather than merely informing public policy, they would increasingly shape the legal standards against which individual projects are assessed. This shift warrants careful attention. Under Article 16, pro natura would favour environmental protection in cases of doubt before authorities exercising jurisdictional functions; the same provision also restricts acts whose potential adverse environmental effects are disproportionate to their benefits. The latter rule could influence administrative decisions, although its precise scope remains open to interpretation. It may require developers to provide stronger justification for a project’s foreseeable effects, but the initiative does not establish a methodology for weighing environmental impacts against expected benefits. Principles should guide decision-making without displacing objective standards, reasoned assessments and consistent treatment of comparable projects. The Central Concern: The Stability of Existing PermitsArticle 252 presents perhaps the most significant challenge to regulatory predictability. It provides that subsequent environmental rules may prevail over regulatory provisions incorporated into existing permits, licences, resolutions, concession titles and authorisations when specified public-interest or environmental grounds are met. Importantly, this is not an express rule automatically invalidating previously granted permits; its direct target is the regulatory provisions contained within them. Even so, its potential effect on the conditions governing an authorised project is substantial. The grounds for applying this rule are broad, while the initiative does not expressly distinguish routine regulatory adjustments from changes affecting the fundamental assumptions on which a project was designed and financed. Nor does it provide a general mechanism for adaptation periods or technical reassessment. No authorisation should shield an operator from necessary measures addressing serious environmental risks. Equally, an authorisation must offer a meaningful degree of stability. This tension also has a constitutional dimension: Article 14 of the Mexican Constitution prohibits the retroactive application of laws to the detriment of any person, and the Supreme Court’s theory of the components of legal norms (jurisprudence P./J. 123/2001) provides a useful framework for distinguishing consequences already produced under a permit from those that may legitimately be governed by new rules. A more balanced approach would differentiate urgent protective measures from ordinary regulatory changes and establish proportionate transitions based on the risk involved and the stage of the project. Mining: Familiar Obligations, Greater Long-Term ExposureFor mining, the proposal largely retains core substantive requirements. Federal environmental-impact authorisation would remain necessary for relevant exploration, extraction and mineral-processing activities, and the existing prohibition on mining works in protected natural areas would continue. Article 168 would also substantially preserve the current framework for restoration, closure and post-closure programmes. The more significant changes arise from provisions governing how those obligations may evolve after a project has been authorised. Under Article 169, the Ministry of Environment and Natural Resources (SEMARNAT) could require closure-programme updates when works are not contemplated in the programme, site conditions change significantly, environmental rules are amended, or specified geotechnical or hydrogeological risks arise. It could also require updates for the broader purpose of improving or expanding environmental protection, and in any other case the regulations may establish. Such revisions can be environmentally necessary, particularly for tailings facilities. However, the proposal does not clearly establish how additional closure costs and financial guarantees would be calculated, how frequently reviews could occur or what compliance periods would apply. In combination with Article 252, these omissions could make long-term liabilities harder to forecast. Technically supported review criteria and defined adjustment procedures would protect the environment while preserving the financial predictability needed for mine development and closure planning. Environmental Authorisations Demand Greater PrecisionThe environmental-impact assessment procedure would retain its preventive character, but Article 57 would permit the authority to impose requirements whose non-compliance would deprive the authorisation of any legal effect. The authorisation could also be conditioned on works commencing within the period it specifies, which may not exceed five years, failing which a new environmental impact statement would have to be filed. These rules could have serious consequences for mining projects, where construction schedules depend on financing, engineering and multiple administrative approvals. The drafting of permit conditions would therefore become as important as their substantive content. Requirements carrying that consequence should be identified expressly and reserved for obligations whose breach warrants such a serious consequence, with a clear distinction between material violations and remediable deficiencies. Loss of legal effect should also be preceded by a procedure affording the permit holder a prior hearing, rather than operating automatically. Article 53 would also establish a procedure for seeking authorisation after works have begun or concluded, subject to an environmental-damage study, restorative or compensatory measures and financial security. That pathway should function as a controlled response to non-compliance, not as a substitute for obtaining prior approval. Corporate Liability Extends Beyond Direct OperationsArticle 306 would address liability of legal entities for certain infringements and damage involving representatives, managers, employees and persons exercising functional control when the statutory conditions concerning benefit or consent are satisfied. It also addresses the engagement of third parties to carry out infringing conduct. This does not mean that every contractor breach would automatically be attributable to the project owner; the applicable legal conditions would still matter. Nevertheless, the provision reinforces the need to examine environmental exposure across contractual and operational relationships. For mining companies, effective compliance would consequently require more than securing authorisations. Contractor due diligence, training, supervision, incident escalation and traceable records would become central to managing liability. The enforcement framework would also authorise greater reliance on documentary checks, technological monitoring and information supplied by citizens or other verifiable sources. Together, these tools call for compliance systems capable not only of preventing infringements, but also of demonstrating how the company monitored and responded to environmental risks. Sanctions and the Financeability of Mining ProjectsThe proposed maximum administrative fine would rise from 50,000 to 2 million Units of Measurement and Update (UMA), a fortyfold increase in the statutory ceiling. Other measures could include suspension or revocation of permits, cancellation of certifications and property-registry annotations in the circumstances established by law. Articles 312–315 would introduce an Environmental Offenders Registry, administered by the Federal Environmental Justice Prosecutor’s Office (the new name proposed for PROFEPA), for specified infringements, with final registrations potentially lasting seven to ten years, subject to statutory reductions. Although the registry could be consulted only by federal environmental authorities, its consequences would extend well beyond the immediate penalty, as registration could affect future applications concerning the same works, including through guarantee requirements, and indirectly create issues for financing, acquisitions, insurance and environmental due diligence, through the disclosures and representations customarily required in those processes. Strong deterrence may be justified for serious infringements, but penalties and property-related effects should remain proportionate to the conduct involved and subject to effective procedural safeguards. The objective should be better compliance, not uncertainty detached from environmental risk. A Credible Transition Is IndispensableThe transitional provisions address pending procedures and applications, but do not establish a comprehensive adjustment regime for ongoing substantive obligations at already operating facilities. Questions therefore remain about new insurance arrangements, revised closure programmes and existing certifications. Several operational details would also depend on implementing regulations to be issued within 365 days, while the proposal anticipates no additional budgetary resources. That combination raises practical questions about the authorities’ capacity to administer more extensive investigative and decision-making responsibilities. Mexico has an opportunity to create a more effective environmental framework, provided that legislative ambition is matched by precise rules and capable institutions. Clarifying the reach of new principles, distinguishing changes to permit conditions from the validity of permits themselves, and defining review and transition mechanisms would strengthen enforceability rather than weaken protection. The measure of success will not be the number of new powers or the severity of sanctions, but whether environmental obligations are clear, proportionate and consistently applied. For the mining industry, legal certainty and environmental accountability must be mutually reinforcing conditions of responsible long-term investment. At ALN Mining Law Firm, we advise mining companies on the legal aspects of their projects, combining industry knowledge with an understanding of each business’s needs. Sincerely: Joel Antonio González Labrado Francisco Javier Andujo Tarango

The recent announcement of a critical minerals cooperation plan between Mexico and the United States is a particularly relevant development for the mining industry. Far from being a merely declarative instrument, this agreement reflects a structural change in the way mineral resources are conceived, not only as productive inputs, but as strategic assets linked to energy security, industrial competitiveness and the resilience of supply chains. The concept of critical minerals encompasses resources such as lithium, copper and nickel, the demand for which has intensified as a result of the energy transition, electromobility and technological progress. In this context, the United States has promoted the consolidation of more resilient and regionalized supply chains, reducing its dependence on external markets. Mexico, on its end, has significant geological potential and a privileged geographic position that positions it as a natural partner in this strategy. This plan, expressly aligned with the Treaty between Mexico, the United States and Canada (T-MEC), comes at a key moment, less than a year before its formal revision. Its content reveals a logic that transcends traditional trade. The possibility of implementing schemes such as minimum border prices, the coordination of trade policies and the identification of strategic minerals of common interest are evidence of a shift towards mechanisms aimed at stabilizing and strengthening regional supply chains in the face of an increasingly volatile and concentrated international market. Mexico is not a peripheral player in this framework. Its geological potential, geographic proximity and trade integration place it at the center of the U.S. strategy; however, its participation is not without its challenges. Recent mining policy has emphasized the strengthening of state control over natural resources, particularly in the case of lithium, as well as the introduction of greater restrictions on concessions. This approach, although it responds to a sovereignty logic, may generate tensions given the need to provide certainty to foreign investment and to align with increasingly demanding regional standards. For the mining industry, this scenario implies a profound transformation. It is no longer just a matter of producing and exporting minerals, but of integrating into strategic value chains ranging from exploration, processing, manufacturing and even exporting. At the same time, greater regulatory pressure is anticipated, both in terms of sustainability and compliance to international standards, as well as a possible reconfiguration of economic incentives derived from mechanisms such as minimum prices or preferential financing schemes for projects considered strategic. Therefore, the review of T-MEC in 2026 acquires a completely different dimension. Far from being a merely technical exercise, it is emerging as a space in which the rules of the game for key sectors such as mining could be redefined. Although the treaty does not expressly contemplate critical minerals, its institutional framework could be used to incorporate new instruments aimed at strengthening regional security of supply, facilitating investment in strategic projects or even establishing common regulatory parameters.

By: Daniela Vargas Mendoza The recent announcement of a critical minerals cooperation plan between Mexico and the United States is a particularly relevant development for the mining industry. Far from being a merely declarative instrument, this agreement reflects a structural change in the way mineral resources are conceived, not only as productive inputs, but as strategic assets linked to energy security, industrial competitiveness and the resilience of supply chains. The concept of critical minerals encompasses resources such as lithium, copper and nickel, the demand for which has intensified as a result of the energy transition, electromobility and technological progress. In this context, the United States has promoted the consolidation of more resilient and regionalized supply chains, reducing its dependence on external markets. Mexico, on its end, has significant geological potential and a privileged geographic position that positions it as a natural partner in this strategy. This plan, expressly aligned with the Treaty between Mexico, the United States and Canada (T-MEC), comes at a key moment, less than a year before its formal revision. Its content reveals a logic that transcends traditional trade. The possibility of implementing schemes such as minimum border prices, the coordination of trade policies and the identification of strategic minerals of common interest are evidence of a shift towards mechanisms aimed at stabilizing and strengthening regional supply chains in the face of an increasingly volatile and concentrated international market. Mexico is not a peripheral player in this framework. Its geological potential, geographic proximity and trade integration place it at the center of the U.S. strategy; however, its participation is not without its challenges. Recent mining policy has emphasized the strengthening of state control over natural resources, particularly in the case of lithium, as well as the introduction of greater restrictions on concessions. This approach, although it responds to a sovereignty logic, may generate tensions given the need to provide certainty to foreign investment and to align with increasingly demanding regional standards. For the mining industry, this scenario implies a profound transformation. It is no longer just a matter of producing and exporting minerals, but of integrating into strategic value chains ranging from exploration, processing, manufacturing and even exporting. At the same time, greater regulatory pressure is anticipated, both in terms of sustainability and compliance to international standards, as well as a possible reconfiguration of economic incentives derived from mechanisms such as minimum prices or preferential financing schemes for projects considered strategic. Therefore, the review of T-MEC in 2026 acquires a completely different dimension. Far from being a merely technical exercise, it is emerging as a space in which the rules of the game for key sectors such as mining could be redefined. Although the treaty does not expressly contemplate critical minerals, its institutional framework could be used to incorporate new instruments aimed at strengthening regional security of supply, facilitating investment in strategic projects or even establishing common regulatory parameters.

The Mexican mining sector is entering a new regulatory and policy cycle under the federal administration of President Claudia Sheinbaum Pardo. This cycle is structured around Plan México 2030, a long‑term industrial and economic development strategy grounded in the doctrine of Mexican Humanism, which prioritizes social welfare, environmental sustainability, and national sovereignty. Mining has been formally positioned as a strategic industry for the country’s energy transition, industrial self‑sufficiency, and technological development. As a result, federal authorities have articulated five regulatory and policy pillars that will shape mining operations, permitting, financing, and compliance in the coming years:   Water regulation and corporate water responsibility; 2. Forest sustainability and land‑use management; 3. Mining education, innovation, and technological sovereignty; 4. Adoption of international sustainability standards (TSM) 5. Institutional financing through the Mining Development Trust (FIFOMI);   For mining companies, these pillars represent not only regulatory compliance obligations, but also a framework for securing legal certainty, access to public incentives, institutional financing, and long‑term operational continuity in Mexico.  I. Plan México 2030 and the New Industrial Policy Framework.   Plan México was formally presented on January 13, 2025, as the federal government’s roadmap to position Mexico among the world’s ten largest economies by 2030. The strategy seeks to rebalance industrial development through:   a) Increasing productive investment to more than 25% of GDP, with an initial portfolio estimated at approximately USD 277 billion across nearly 2,000 projects. b) Ensuring that at least 50% of domestic supply and consumption in strategic sectors is sourced from national production, reducing structural dependence on Asian imports. c) Developing 100 industrial parks and 12 “Welfare Hubs” designed to promote regional specialization, nearshoring, and territorial economic integration.   Mining is explicitly identified as the foundation of industrial sovereignty, given its essential role in supplying critical minerals for energy infrastructure, manufacturing, telecommunications, and advanced technologies.   Federal authorities, including the Ministry of Economy, have emphasized the need to prevent strategic vulnerabilities in mineral supply chains and to align extractive activity with environmental protection, social development, and technological autonomy.   From a regulatory perspective, adherence to these policy pillars enables mining companies to benefit from incentives established under the federal Relocation Decree, including accelerated depreciation of new investments and enhanced tax deductions for workforce training conducted in partnership with academic and research institutions. II. Water as a Human Right: Regulatory Reform and Corporate Water Responsibility.   The first pillar is anchored in the National Water Plan 2024–2030 and the National Agreement for the Human Right to Water and Sustainability, which redefine water as a public, strategic national asset rather than a purely economic resource.   Recent reforms to the National Water Law and the enactment of the new General Water Law introduce the concept of corporate water responsibility, which prioritizes human and domestic consumption, imposing stricter obligations on concession holders, including mining companies, to:   Measure and digitally report extracted volumes; Monitor usage efficiency and reuse processes; Comply strictly with authorized parameters and technical conditions; and Implement mitigation and compensation mechanisms where applicable.   Voluntary corrective measures, such as the formal return of unused concession volumes, may mitigate regulatory exposure and significantly reduce the risk of sanctions, including the revocation of water concessions, suspension of operations, or administrative closure.   In parallel, the federal “Water for Well‑being” digital platform will centralize reporting and permitting procedures, granting preferential administrative treatment to companies that demonstrate sustained compliance and best operational practices.   Legal and transactional impact: Water compliance will become a core component of regulatory due diligence, asset valuation, project finance structuring, and M&A risk allocation in the Mexican mining sector.   III. Forest Sustainability: Toward Net‑Zero Deforestation by 2030.   Under the Institutional Program of the National Forestry Commission (PIC) 2025–2030, Mexico has formally committed to halting ecosystem degradation and achieving net‑zero deforestation.   Mining projects are now expected to adopt an integrated land‑use and environmental management approach, supported by:   166 federal lines of action for ecosystem restoration; Strengthened inspection and sanction mechanisms; and Increased scrutiny of unauthorized land‑use changes.   This regulatory evolution is particularly relevant given that more than 50% of Mexico’s forest territory is socially owned (ejidos and agrarian communities), which directly links environmental compliance to land tenure security and community relations. Legal and operational impact: Environmental permits, land access agreements, and social license to operate will be evaluated holistically. Reforestation and restoration programs are becoming not only environmental obligations but practical tools to mitigate operational risk, community disputes, and climate‑related contingencies. IV. Mining Education, Innovation, and Technological Sovereignty.   The Ministry of Economy has established the Mexico 2025 Mining Education Committee, a multi‑sector body aimed at transforming mining from a predominantly extractive activity into a knowledge‑based industry.   The committee’s objectives include: Establishing partnerships with more than 26 academic institutions; Expanding dual education models and professional internship programs; Promoting domestic research and the registration of Mexican patents; and Reducing structural dependence on foreign mining technologies.   Legal and strategic impact: Companies that participate in these initiatives may benefit from preferential treatment under industrial integration programs, improved labor stability, reduced turnover, and enhanced positioning in public procurement and development projects. V. International Sustainability Standards: Adoption of TSM.   The formal adoption of the Towards Sustainable Mining (TSM) standard from the Mining Association of Canada (MAC) by the Federal Mexican Government´s Ministry of Economy, the Mexican Mining Chamber (CAMIMEX) and the Canadian Chamber of Commerce in Mexico (CANCHAM) introduces objective, measurable, and auditable indicators for environmental, social, and governance performance.   TSM Protocols require: Periodic external audits (every three years); Public disclosure of performance metrics; and Continuous improvement benchmarks across environmental protection, community relations, safety, and governance.   Compliance aligns Mexican mining operations with the Mexico–Canada Action Plan 2025–2026 and significantly strengthens credibility with regulators, development banks, institutional investors, and international partners subject to ESG investment criteria.   Legal and financial impact: TSM compliance is increasingly relevant in project finance, cross‑border transactions, public listings, and regulatory negotiations, functioning as a reputational safeguard and a facilitator of access to international capital markets. VI. FIFOMI: Strategic Financing for the Mining Sector.   The Mining Development Trust (FIFOMI) is a public development finance institution whose trustor is the Ministry of Finance and Public Credit, whose trustee is Nacional Financiera, and which is regulated by the National Banking and Securities Commission.   Since December 2024, FIFOMI has undergone significant institutional restructuring, resulting in:   An upgrade of its credit rating to A+ (stable) by Fitch Ratings; A reduction of its delinquency rate from 37% to 24.9%; Reactivation of first‑tier lending; Evaluation of more than 40 mining projects nationwide; and Expansion of technical assistance and training programs benefiting more than 4,000 individuals annually.   FIFOMI currently operates in direct alignment with:   Objective 3.10 of the National Development Plan 2025–2030 (increase national content in production chains); and Plan México’s objective to increase small and medium size companies (PYMES) access to credit in strategic sectors to at least 30% by 2030. Its financial instruments include:   Direct loans (simple credit, refurbishment, working capital, refinancing); Factoring under the FIFOMI‑NAFIN Production Chains program; Technical advisory services in exploration, operation, processing, commercialization, environmental compliance, and industrial safety; and Specialized training programs offered both virtual and in person.   Looking forward, FIFOMI is expected to consolidate as a central institutional partner for mining project development, particularly for junior and mid‑tier operators, and to play an active role in the administration of strategic mining allocations and national processing infrastructure.   VII. Conclusion: Regulatory Compliance as a Strategic Business Asset.   While these five pillars undeniably increase regulatory density and compliance obligations, they also provide a comprehensive framework for legal certainty, institutional financing, operational continuity, and reputational strengthening.   Mining companies that proactively align their governance structures, operational practices, and investment strategies with this new policy architecture will be better positioned to:   Secure permits and concessions; Access public and private financing; Navigate ESG‑driven investor scrutiny; Strengthen relationships with authorities and communities; and Maintain their social license to operate.   In the context of Plan México 2030, regulatory compliance is no longer merely defensive. It has become a strategic asset for sustainable growth in the Mexican mining industry.     ALN Mining Law Firm Joel Gonzalez Javier Andujo Marco Perea Legal Alert – For informational purposes only. This publication does not constitute legal advice.

On May 13, 2026, the Institutional Program of the Mining Development Trust (FIFOMI) was published in the Federal Official Gazette, a significant update that redefines the operational and programmatic focus of this institution. This program is aimed at strengthening financing, training, and technical assistance for the national mining sector and its value chain. The new FIFOMI program focuses primarily on institutional strengthening and defining its operational guidelines. However, it also sends a clear message regarding the Federal Government’s current vision and priorities for the mining industry: to reposition FIFOMI as a key mechanism for promoting economic growth, social development, and sustainability in the sector. Among the most relevant aspects of the program for mining companies are the following: The program recognizes the need to attract foreign investment in order to harness the country’s geological potential, so that its implementation stimulates regional and social development. The Federal Government identifies mining as a strategic industry and emphasizes the need to develop mining projects aligned with environmental, social, and human rights standards, promoting public policies oriented toward sustainability and social well-being. FIFOMI will expand financing schemes aimed primarily at mining MSMEs and related companies through working capital loans, start-up or equipment financing, financial leasing, factoring, and revolving lines of credit. The program emphasizes regional integration and the development of “Well-being Hubs” and local production chains, prioritizing projects that generate employment, domestic content, industrial linkages, and community development. It favors projects with demonstrable regional impact and mining models with a greater social component and reliance on local suppliers. FIFOMI will expand its focus beyond traditional mining extraction to include supply chain activities, processing, specialized services, maintenance, transportation, and mining-related manufacturing. This means that not only companies holding mining projects but also companies integrated into the mining supply chain will be eligible for the program. From a strategic perspective, FIFOMI’s new institutional program outlines a series of action plans aimed at strengthening the competitiveness and sustainability of the national mining sector, aligning primarily with three government objectives: (i) improving access to financing mechanisms; (ii) strengthening value chains, procurement, and supply chains; and (iii) promoting social development through economic and productive growth in the sector. Given this, it is undeniable that FIFOMI positions itself as a relevant and highly beneficial tool for the mining sector, not only as a means of financing but also as a vehicle for technical support, institutional strengthening, and engagement with the Federal Government. At ALN Mining Law Firm, we are at your call to provide advice on how to take advantage of the programs offered by FIFOMI, as well as strategic planning to ensure maximum benefit for your projects in the mining sector.

On September 2nd, 2026, an initiative to enact the Environmental Liability Law of the State of Guerrero was published before the Parliamentary Gazette of the Congress of the State of Guerrero presented by Congresswoman Obdulia Naranjo Cabrera of the Ecologist Green Party of Mexico (PVEM). The bill seeks to give the state a specialized legal and procedural framework for the remediation of, and compensation for, environmental damage. The bill rests on a core premise: environmental damage must be remediated even where no direct financial loss to a specific person can be shown. Broadly, it brings the model of the 2013 Federal Environmental Liability Law (LFRA) to the state level. Guerrero would thus join states such as Michoacán, Sonora, Coahuila and Quintana Roo, which already have their own environmental liability statutes. If approved, the law would increase exposure to environmental claims for companies operating in Guerrero. The impact would be greatest for mining and extractive companies and, more generally, for any business whose activities carry potential environmental impacts. Key ProvisionsThe proposed framework prioritizes effective ecosystem restoration over purely financial or punitive responses. It even provides that monetary penalties be allocated entirely to restoration and biodiversity conservation. Its main provisions are: Comprehensive remediation: responsible parties would have to carry out technical measures to restore, recover, remediate or rehabilitate affected ecosystems. Where restoration is materially or technically impossible, environmental compensation would apply. Broader standing: state residents, qualifying environmental organizations and certain state and municipal authorities could bring claims. Strict and fault-based liability: both regimes would coexist. For certain activities, such as those requiring state environmental impact authorization, liability could arise without proof of fault or negligence. Precautionary measures: courts could order measures during proceedings, including the suspension of business operations. Monetary penalties: legal entities could face fines of up to 600,000 UMA (Unit of Measure and Update), approximately MXN 70.4 million at the 2026 UMA value, for certain intentional unlawful acts. These fines would apply in addition to remediation obligations. Corporate Liability and Environmental ComplianceOne of the bill’s most significant features is that companies would be liable for acts or omissions of their representatives, directors, employees, or third parties acting on their behalf or for their benefit. Parties that engage or induce a third party to carry out the conduct causing the damage would also be jointly and severally liable. The bill provides an exception to joint and several liability. It applies where a company can show that, for at least three years before the harmful conduct, it had internal control mechanisms, an environmental management system, ongoing training and financial guarantees in place. This timeframe matters: a compliance program put in place after the damage would not qualify as a defense. Environmental compliance therefore becomes more than a preventive tool. It is a line of defense that must be built and documented in advance. Implications for the Mining IndustryThe law’s actual reach will depend on how it interacts with the LFRA and with the allocation of authority under the General Law of Ecological Balance and Environmental Protection (LGEEPA). Mineral exploration, extraction and processing generally fall under federal jurisdiction. As a result, the most direct impact of a state law would likely be on activities under state authority, such as aggregate quarries, roads, and works and facilities subject to state environmental review. Contractors and suppliers would also be directly affected. Even so, mining companies’ exposure would be significant: Remediation obligations could include technical assessments, restoration plans, soil and water remediation, and monitoring programs. Joint and several liability for third parties is especially relevant in an industry that relies heavily on contractors. The possibility of precautionary measures against operations is a factor that should be weighed in project continuity planning. In any dispute, historical environmental information would carry decisive evidentiary weight. This includes baseline studies, environmental impact assessments, monitoring and operational records, and evidence of compliance. How Should Companies Prepare?We recommend adopting a preventive strategy now, covering: Regulatory review: confirm the validity and scope of federal and state environmental authorizations and the obligations they impose. Compliance programs: strengthen environmental management systems, prevention programs and response protocols, and document how they operate. Technical records: keep monitoring records, sampling results, environmental studies and compliance evidence up to date and securely preserved. Contractors and third parties: assess risks arising from work performed by third parties and review contractual provisions on environmental compliance, indemnification and insurance. Financial assurance: evaluate whether insurance and guarantees are adequate to cover potential remediation obligations. Legislative monitoring: follow committee review, potential amendments and eventual approval of the bill. Monitoring the Legislative ProcessThe bill is at an early stage and remains subject to the Committee’s and the Congress review, debate, potential amendments and a floor vote. It is not the first bill of its kind in Guerrero: bills with similar contents were introduced in 2019 and 2022. Its final scope will depend on the text ultimately enacted, if any, and on how it interacts with existing federal and state environmental frameworks. At ALN Mining Law Firm, we help mining companies identify regulatory risks, assess their environmental obligations and design preventive strategies that strengthen legal certainty and support the continuity of their operations. ALN Mining Law Firm Francisco Javier Andujo Tarango Partner Juan Carlos Luévano López Associate

1) Cancellation of 1,126 Mining Concessions in Mexico 2) U.S. - Mexico Critical Minerals Action Plan 3) Mexico - Canada Strategic Action Plan (February 2026 Trade Mission) By: Joel Antonio González Labrado February 2026 marked a significant inflection point for Mexico’s mining policy environment within the broader North American geopolitical and trade architecture. Three concurrent developments: (i) the recent cancellation of 1,126 mining concessions, (ii) the announcement of a U.S. - Mexico Critical Minerals Action Plan, and (iii) the launch of a Mexico - Canada strategic economic minerals focused action plan; collectively signal a structural reordering of regulatory enforcement, supply chain policy, and continental investment alignment. This article provides a detailed legal, economic, and strategic analysis of these developments, evaluating implications for operators, investors, financiers, and cross-border stakeholders. The convergence of stricter domestic enforcement and heightened continental supply - chain diplomacy creates both heightened compliance risk and strategic opportunity for well-positioned projects. Chapter 1:  Cancellation of 1,126 Mining Concessions in Mexico 1.1 Regulatory Context On February 12, 2026, Mexican President Claudia Sheinbaum announced the cancellation (“recovery”) of 1,126 mining concessions covering approximately 889,000 hectares. The measure was publicly framed as an enforcement action targeting non-payment of mining duties, failure to comply with reporting obligations, and overlaps with Protected Natural Areas (ANPs). This development must be interpreted within the broader reform trajectory of Mexico’s mining legislation since 2023 - 2024, including strengthened environmental oversight, enhanced state discretion in concession administration, and political emphasis on territorial sovereignty. 1.2 Legal Grounds and Administrative Mechanisms Under Mexican mining law, concessions may be cancelled for failure to pay duties, failure to submit annual expenditure work and statistical reports, or other material non-compliance. The February 2026 announcement demonstrates an assertive application of these statutory tools at scale. Notably, the public communication highlighted that 713 concessions overlapped with Protected Natural Areas, underscoring the integration of environmental policy with title administration. While overlap does not automatically invalidate title rights, it increases regulatory scrutiny and operational uncertainty. Each cancellation procedure should be analyzed independently considering the specifics of each particular case, in order to determine the best action or legal defense to secure or recover the concessions from the cancellation procedure, and if possible, remedy the non-compliance that motivated such disciplinary proceedings. 1.3 M&A and Financing Implications The cancellation wave materially shifts due diligence standards in mining transactions. Investors and lenders should now treat compliance documentation (payment receipts, report filings, and regulatory acknowledgments) as closing-critical deliverables. Enhanced representations and warranties related to concession standing, duty payments, and reporting compliance are expected to become standard in financing agreements and acquisition documentation. 1.4 Strategic Risk Assessment Increased enforcement unpredictability. Elevated political sensitivity for projects near protected areas. Greater administrative discretion in title validation. Potential chilling effect on speculative land banking. Chapter 2: U.S.–Mexico Critical Minerals Action Plan 2.1 Strategic Objectives Announced February 4, 2026, by U.S. Trade Representative Ambassador and Mexico´s Secretary of Economy, the U.S. - Mexico Critical Minerals Action Plan seeks to strengthen continental supply chains by identifying priority minerals, aligning geological cooperation, and evaluating trade-policy tools such as border-adjusted price floors. The plan must be understood within the context of geopolitical competition over rare earths, lithium, graphite, copper, silver and other inputs essential to clean energy, defense, semiconductors, and advanced manufacturing. 2.2 Trade Policy Dimensions The potential exploration of price floors represents a notable shift toward active trade intervention to stabilize domestic and allied mineral supply chains. If implemented, such measures could materially influence offtake contracts, project valuation models, and cross-border pricing mechanisms. 2.3 Industry Perspective - CAMIMEX CAMIMEX characterizes the Action Plan as a strategic opportunity for Mexico to consolidate its industrial role in North America. The association highlights Mexico’s production of at least a dozen strategic minerals critical to electromobility, digitalization, and renewable energy. However, CAMIMEX emphasizes that realizing this opportunity requires enabling conditions that strengthen competitiveness and regulatory certainty. The industry estimates potential investments exceeding USD 43 billion over six years if such conditions are satisfied. CAMIMEX: Enabling Conditions Condition Strategic Implication Responsible investment incentives Enhance capital attraction while preserving ESG compliance Counter unfair foreign competition Strengthen continental competitiveness Improved regional security Reduce operational disruption risks Expanded exploration investment Ensure long-term resource sustainability Clear and predictable permitting Increase investor confidence Modernized legal framework Provide durable legal certainty 2.4 Strategic Assessment The success of the Action Plan depends not only on bilateral diplomacy but on Mexico’s internal regulatory coherence. Without permitting predictability and security stabilization, supply chain integration goals may remain aspirational. Chapter 3: Mexico - Canada Strategic Action Plan (February 2026 Trade Mission) 3.1 Diplomatic Context The Team Canada Trade Mission in mid-February 2026 coincided with announcements of a forthcoming bilateral action plan aimed at expanding trade, reducing regulatory obstacles, and facilitating investment in minerals and infrastructure. 3.2 Economic and Investment Dimensions Given Canada’s significant footprint in Mexico’s mining sector, the proposed action plan may streamline investment corridors and reduce administrative bottlenecks affecting Canadian issuers. 3.3 Forward-Looking Outlook Potential structured government facilitation mechanisms. Alignment of ESG standards across jurisdictions. Integration of port and logistics infrastructure into mineral strategy. Enhanced continental positioning ahead of USMCA review. Convergence of Enforcement and Geopolitics Mexico’s cancellation of concessions, combined with enhanced continental critical mineral diplomacy, reflects a dual-track evolution: stricter domestic regulatory enforcement alongside intensified North American strategic coordination. For sophisticated operators and investors, this environment presents heightened compliance demands but also significant strategic upside for projects aligned with critical mineral priorities and continental supply chain integration.