Compliance under Mexico’s New Anti-Corruption Legal Framework
Mexico’s anti-corruption system has undergone a period of transformation since the entry into force of the General Law of Administrative Responsibilities (the “LGRA”) in 2017. This law establishes the control mechanisms for the fight against corruption in Mexico by: (i) setting the standards that public servants must abide by in their public service, requiring them to file their “3 de 3” statements of assets, conflicts of interest and annual tax returns; (ii) providing a list of conducts deemed as corrupt practices and that can be carried out by public servants and/or private parties (individuals and legal entities); and (iii) establishing the penalties which may be imposed by the authorities for the failure to comply with the law.
The LGRA provides for liability of private parties, including both individuals and legal entities that engage in acts of corruption. Among the “serious administrative offenses” are: (i) bribery; (ii) illegal participation in administrative proceedings; (iii) influence-peddling; (iv) falsification of information; (v) collusion; (vi) misappropriation of public funds; and (vii) wrongful hiring of former public servants.
Sanctions may vary depending on whether they apply to legal entities or individuals. For legal entities, sanctions include fines, disqualification from contracting with the public sector, suspension of activities, and even dissolution in serious cases. For individuals, on the other hand, sanctions may include fines (up to twice the benefit obtained), temporary disqualification, and the obligation to compensate for damages. In both cases, the authority will determine the amount and duration of the sanctions in accordance with the degree of participation and the economic benefit obtained.
Like the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), the UK Bribery Act 2010 and other similar frameworks around the globe, the LGRA sets forth that companies can mitigate their liabilities if they have in place an “integrity policy”, which is essentially a compliance program that includes policies, procedures, training, audits and reporting mechanisms to prevent and detect misconduct.
- The LGRA establishes seven key elements that a company or organization must have to maintain an acceptable compliance program:
- Organization and procedures manual that is clear and complete, and outlines responsibilities of every area and the chain of command of the company and leadership structure;
- Code of conduct duly published within the company and/or organization;
- Adequate and effective supervision, audit, and control systems that periodically examine compliance throughout the organization;
- Internal whistleblower and reporting systems, along with corrective procedures for individuals who violate the company’s policies or the law;
- Training programs and systems for compliance with the policies;
- Nondiscriminatory human resources policies, which may prevent the hiring of individuals who could compromise the company’s integrity; and
- Mechanisms to ensure transparency and publicity.
Having an integrity policy based on these seven elements is the best starting point for proper compliance with Mexico’s anti-corruption system, as a proactive strategy not only reduces legal risks but also strengthens the confidence of investors and strategic partners.
It is widely recommended that companies implement real-time risk monitoring and analysis systems, integrate ESG (environmental, social, and governance) criteria into their anti-corruption policies, and continuously review their operations and international business relationships to comply with global standards.
At JATA, we are prepared to guide companies in the implementation and updating of anti-corruption compliance programs, offering personalized legal advice tailored to each corporate need in Mexico and internationally.
February 2026.
This article was originally written in 2017 by Carlos A. Chávez, and updated and supplemented in February 2026 by Carla A. Ríos. Please send any questions or comments to info@jata.mx. The original author was a Senior Associate at JATA - J.A. Treviño Abogados, and the co-author who updated and supplemented this article is an Associate at JATA and can be reached at crios@jata.mx. JATA is a Mexican law firm with offices in Monterrey, N.L., Mexico, and Houston, Texas.
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