Primary artisanal mercury (Hg) mining in Mexico continues to proliferate unabated, while official Hg exports have declined in recent years amid speculation of a rising black market trade. In this paper, an assessment of primary Hg mining in Mexico was conducted, with a focus on four sites in Querétaro State. Atmospheric Hg concentrations were measured at two of those sites. In addition, trade data was examined, including Hg exports from Mexico and imports by countries that have a large artisanal gold mining (AGM) sector. Results showed that while annual Hg production in Mexico has ramped up in recent years, official Hg exports reduced from 307 tonnes in 2015 to 63 tonnes in 2019. Since 2010, mercury exports to Colombia, Peru and Bolivia have represented 77% of Mexico’s total Hg trade. As the large majority of Hg trade with these countries is apparently destined for the AGM sector, which is contrary to Article 3 of the Minamata Convention, there is evidence that increased international scrutiny has led to an increase in unregulated international transfers. Atmospheric Hg concentrations at the mines show dangerously high levels, raising concern over the risk of significant health impacts to miners and other community members.