Mexico has ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions; the OAS Inter-American Convention Against Corruption; the UN Convention against Transnational Organized Crime and its Protocols; and the UN Convention against Corruption.

In Mexico, there are two criminal jurisdictions: federal and local. The latter is comprised of 32 local jurisdictions which correspond to each one of the states in Mexico. Therefore, for corruption matters, the Federal Criminal Code (FCC) covers federal criminal offences and each state criminal code covers local criminal offences.

For the scope of the FCC and state criminal codes, please refer to 3.2 Geographical Reach of Applicable Legislation.

Acts of corruption are also considered administrative offences under the General Law of Administrative Liability (GLAL), which sets forth public officials’ principles and obligations for the correct and lawful fulfilment of their duties. Administrative offences apply to both public officials and private persons, including companies, that engage in any act of corruption.

Therefore, a corruption case can be investigated, prosecuted and sanctioned as both a criminal and administrative offence.

There are no guidelines in Mexico, since the interpretation and enforcement of national legislation is the remit of the Judicial Branch. In this regard, the Supreme Court of Justice has set precedents for corruption offences.

For instance, it has confirmed that the criminal offence of bribery provided by Article 222, subsection I FCC, is constitutional even though criminal law does not state which duties are related to the public official’s job, charge, or commission, since such duties are detailed in the regulations that assign the functions within the legislative, executive, or judicial offices.

There have not been any key amendments to the national legislation on corruption matters in 2024.

A bribe is any promise made – or benefit or money illicitly given – to a public official in order that the public official will execute or refrain from executing any act related to the duty inherent in their job, charge, or commission. In this regard, bribery is considered a criminal offence under Article 222 subsections I and II of the Federal Criminal Code (FCC) and in each one of the 32 Local Criminal Codes.

The bribery can be committed by public officials who, directly or indirectly, request or receive a benefit or accept a promise, and by private individuals who promise or provide a benefit to corrupt a public official even though the benefit is received by third parties linked to the latter, such as public officials’ relatives, partners or third parties with whom the public official has business, or a professional or work relationship, among others.

For the purposes of bribery, a benefit can be considered to be any goods, stocks, precious stones or metals, services, donations, or real estate, including when a property is sold very noticeably below market price.

Likewise, under Article 222 subsection III of the FCC, it is also considered bribery when, during the Federal Budget approval process, a federal legislator or someone on behalf of the federal legislator, negotiates or requests:

• the allocation of resources to a public entity by demanding or obtaining anything of value for their own or a third-party’s benefit; or
• the award of public work or service agreements to any individual or legal entity.

For both local and federal criminal jurisdiction, a public official is similarly defined in criminal law. Therefore, a public official is any individual who has a job, charge or commission of any nature in:

• the central Federal Public Administration or in the State’s Public Administration;
• decentralised agencies;
• majority state-owned companies;
• organisations or entities that have been assimilated to majority state-owned companies;
• public trusts;
• autonomous constitutional bodies;
• federal and local Congress;
• federal and local judiciary; or
• entities that manage federal or local financial resources.

Hospitality, Gifts and Promotional Expenditures and Facilitation Payments

In Mexico, there is no safe harbour for these kinds of expenditures or facilitation payments to a public official, since the law does not set forth any exceptions, and neither does the GLAL which governs public officials’ conduct. Moreover, the GLAL provides that public officials must not look for or accept rewards, benefits or gifts from any person or legal entity.

Bribery to Foreign Public Officials

When a bribe is offered to a foreign public official it is considered a federal criminal offence under Article 222 Bis FCC, which has extraterritorial reach, as explained in 3.2 Geographical Reach of Applicable Legislation. In this kind of bribery, the specific features are:

• the bribe is given with the purpose of obtaining or retaining an advantage during international business transactions; and
• unlike the domestic bribery previously explained, the bribe is also considered to be bribery crime when the foreign public official manages or processes the resolution of an issue not related with the duties inherent in their job, charge, or commission.

The Federal Criminal Code defines as “foreign public official” any individual who has the employment, charge, or commission in a foreign country in:

• an executive, judicial or legislative branch;
• autonomous constitutional bodies of any government level;
• state-owned companies; or
• public international agencies or organisations.

Bribery Between Private Parties

Even though Mexico is part of the UN Convention against Corruption, bribery in the private sector has not been established as a criminal offence.

Under Article 221 of the FCC the following activities are specifically considered as influence-peddling crimes.

Influence-Peddling by Public Officials

• A public official who promotes or manages, directly or through third parties, the illicit processing or resolution of public businesses unconnected to the duties inherent in their job, charge, or commission.
• A public official who requests or encourages, directly or through third parties, any resolution or the execution of an act that corresponds to a public official’s job, charge, or commission, for their own economic benefit, a relative’s economic benefit, or the economic benefit of a third party with whom they are linked by friendship or business.

Influence-Peddling by Private Individuals

• A person who promotes the illicit conduct of the public official for managing or processing the resolution of public businesses unconnected to the duties inherent in the public official’s job, charge, or commission.
• A person who, without having authorisation for intervening in public businesses, affirms having influence before the public officials in charge of the decisions on such public businesses and intervenes before them to promote an illicit resolution in exchange for their own or for a third party’s benefit.

The influence-peddling established as criminal offence in the FCC does not cover foreign public officials but is only focused on domestic public officials.

The Federal Fiscal Code establishes as federal criminal offences the following activities connected with financial record-keeping:

• registering the accounting, fiscal and corporate transactions in two or more accounting books or systems with different content;
• hiding, altering, or destroying, totally or partially, the accounting books, records, or systems as well as the supporting documentation that are obliged to be kept pursuant to tax law; and
• registering false or inaccurate information of the accounting, tax or corporate operations or transactions or having false documentation related to such records.

Under the FCC, the following actions by a public official are considered criminal offences.

• Investing, selling, acquiring, or carrying out any act with economic benefit, directly or indirectly, using privileged information known due to their job, charge, or commission, when such information is not in the public domain, regardless of the connection that such information has to their respective duties as a public official (Article 220, subsection II).
• Granting a remunerated job, charge, or commission or service agreement or any other kind of agreement, while being aware that the duties or services are not going to be executed or the agreement will not be fulfilled (Article 215, subsection X).

• Illicitly granting:

1. concessions for providing public services or for exploitation, enjoyment, or use of public domain goods (Article 217, subsection I, paragraph A); and
2. permits, licences, awards, or authorisations of an economic nature (Article 217, subsection I, paragraph B).
• Using public funds for different purposes than those for which they are intended, or making an illicit payment (Article 217, subsection III).
• Increasing their wealth without proving the legitimate increase in value or origin of their goods and properties acquired when being a public official (Article 224).

As detailed in 2.1 Bribery and 2.2 Influence-Peddling, the criminal offence corresponds to the commission by the public official of the criminal act indirectly through third parties or to the benefit of third parties.

Lobbying activities are regulated by the internal regulations for Mexican Congress, which is comprised of the Senator and the Chamber of Deputies. However, there is no regulation for lobbying activities before the Executive and Judicial Branches.

Lobbying is defined as any activity carried out before both Chambers to obtain a resolution or positive decision according to their own or a third party’s interests.

Any individual must be registered before the Senator or Chamber of Deputies to be able to participate as a lobbyist.

In Mexico, the statute of limitations for the investigation of criminal offences is the arithmetic average determined by the sum of the minimum and the maximum imprisonment penalty of an offence, the result of which is then divided by half to determine the period in which a crime can be investigated.

Moreover, when the criminal offence is being investigated, in the first half of the arithmetical average period determined, the investigation suspends the statute of limitations, and the term can be extended by a half.

For instance, when the bribe is more than MXN54,285, the imprisonment penalty goes from two to 14 years, so the statute of limitations is eight years; and if the investigation starts the day after the criminal offence was committed, the public prosecutor will have up to 12 years to investigate and file charges against the defendant before a criminal judge, if the criminal investigation is launched from the first day after commission of the crime.

The statute of limitations runs once the crime is committed, and can only be halted when the defendant is brought before a criminal judge for filing the charges against them.

Therefore, the statute of limitations for investigating the criminal offences detailed in the above sections are the following, without considering the extensive term previously explained.

• 2.1 Bribery: 1.15 years when the bribe is less than MXN54,285 and eight years when it is more.
• 2.2 Influence-Peddling: four years.
• 2.3 Financial Record-Keeping: 1.75 years.
• 2.4 Public Officials: an average of six years.

The FCC is mainly applied when the act of corruption is connected to the Federal Government, the Federal Judicial Branch or the Mexican Congress; federal autonomous constitutional bodies; federal public trusts; Mexican embassies, and consulates, among others.

Additionally, the FCC has extraterritorial reach when the criminal offence is started, prepared, or committed abroad but has repercussions in Mexico; or is executed abroad and continues its commission in Mexico regardless of the perpetrator’s nationality.

When the criminal offence is committed abroad by a Mexican against another Mexican(s) or foreigner(s), or by the latter against a Mexican(s), it will be prosecuted in Mexico pursuant to the FCC if the defendant resides or is found in Mexico, and was not convicted or acquitted in the country where the criminal offence was committed, and the conduct is considered a criminal offence in both Mexico and the foreign country.

On the other hand, the local criminal codes apply when the act of corruption is connected to the local governmental bodies and each state applies their own criminal codes.

In the Federal Jurisdiction and in most of the local jurisdictions, companies can be held liable for the criminal offences detailed in section 2.1 Bribery and 2.2 Influence-Peddling. Additionally, in some local jurisdictions, companies can also be held liable for similar criminal offences to those detailed in section 2.4 Public Officials, depending on whether the crime comes under local jurisdiction, as explained in the above section.

In general terms, for a company to be held liable for a criminal offence it must be proven that it was committed in its name, on its behalf, for its benefit or through the means it provided, and it should be also determined that there was a failure to observe due control within the company.

This means that it is necessary to prove that there is no due organisational control, which translates into the absence of organisation and management models, which include surveillance and control measures, suitable for preventing the kind of crimes for which the company is being charged, or to significantly reduce the risk of their commission.

The criminal action brought against a company is independent from that which can be brought against the individuals involved in the criminal offence committed, and, for this reason, the criminal action is separate from the that related to the individuals, and is a liability not extinguished by the transformation, merger, absorption, or division of the company.

In this regard, the causes of exclusion of a crime that could benefit an individual do not affect proceedings against a company.

Defences available for any criminal offences are covered by the FCC and the local criminal codes. Since these both cover the same types of defences, each will be assessed on a case-by-case basis, particularly because any of the possible grounds for ruling crimes out must be proven. Examples might involve one of the elements making up the criminal offence not being met, or the action being carried out in error since the defendant was unaware that their conduct was illicit.

Causes of defence constitute exceptions in a criminal offence, so are not applicable when the offence cannot be proven. 

Mexican Criminal Law does not provide de minimis exceptions because, once the criminal offence is proved and the perpetrator is charged, the criminal proceedings need to be concluded unless an alternative solution is applied, as explained in 7.4 Discretion for Mitigation and Aggravation; an exclusion cause is upheld, or the criminal offence and its commission by the perpetrator is not duly proven beyond reasonable doubt for convicting the perpetrator.

The criminal law applies equally to all sectors and industries, so there are no exemptions.

The amnesty does not apply to these kinds of criminal offences. However, as explained in 8.1 Compliance Obligations, having a compliance programme can support an acquittal or lighten a penalty for companies if they are convicted.

The criminal offences detailed in 2. Bribery and Corruption Elements have different penalties. In summary, pursuant to the FCC for individuals, the penalties go from three months to 14 years of imprisonment, and from 100 to 150 “fine days”, in addition to the confiscation of money and/or properties connected to the illegal conduct and the dismissal of the public servants who committed the criminal offence.

A fine day is determined by the daily net income considering all kind of incomes.

Legal Entities Penalties

In connection with the legal entities, the FCC establishes the following penalties:

• suspension of activities from six months to six years;
• closing down of an establishment or premises from six months to six years;
• prohibition from carrying out activities where the crime took place for a period of six months to ten years;
• prohibition from participating or bidding in government tenders for a period of six months to ten years;
• judicial intervention for safekeeping employees or creditors’ interests for six months to six years;
• a fine; or
• dissolution of the legal entity.

The judicial authority has sole discretion and power to determine the severity of the penalty, and, in connection with the legal entities, can select the most suitable penalty from those listed above. However, the penalty selected for a legal entity must be proportional to the damage caused. Some of the aspects to be considered include the extent of the lack of control; the amount of money involved in the crime; the employment position of the perpetrators within the legal entity; the level of compliance compromise at the company; the damages caused and the social impact of the consequences.

Considering that dissolution is the most serious penalty, the judicial authority also assesses whether this is strictly necessary to warrant national and public security; prevent the national economy or public health from being jeopardised; or whether the commission of the criminal offence can only be ceased by dissolving the legal entity.

There are no guidelines in Mexico, since the penalties and the criteria for their applications must be provided by law.

When determining the extent of the penalty, the criminal judge must take into consideration, pursuant to Article 410 of the National Code of Criminal Procedure (NCCP):

• the interests protected by the criminal offence;
• whether the conduct was wilfully committed or not;
• the means used for the commission of the criminal offence;
• the circumstances in which the criminal offence was committed;
• the contribution of the perpetrator to the commission of the criminal offence; and
• whether it was possible for the perpetrator to avoid commission of the criminal offence.

Moreover, in the case of public officials involved in criminal offences connected to acts of corruption, the FCC provides that judges must take the following into consideration:

• the hierarchical level of the public official;
• their level of responsibility pursuant to the job, charge, or commission;
• their seniority;
• the backgrounds of the public service performed, incomes, and degree of education; and
• any other special circumstances connected to the illicit conduct of the public official.

For criteria for determining the penalty against legal entities, see 5.1 Penalties on Conviction.

Pursuant to Article 222 of the NCCP, any individual who is aware of the commission of a criminal offence is obliged to expose it before the relevant authority. In instances of acts of corruption, a criminal offence must be expose it before the authority as set forth in 7.2 Enforcement Body.

There are no incentives provided by law for voluntary self-disclosure; however, if a company or individual is under investigation, they may seek that the Public Prosecutor agrees “Proceeding Suspension” or to an “Abbreviated Procedure”, as explained in 7.4 Discretion for Mitigation and Aggravation.

Also, in some cases provided for in Article 256 of the NCCP, the Public Prosecutor has discretional power to not prosecute a case by applying the criterio de oportunidad. The guidelines for doing this are issued by the Attorney General’s Office and each of the 32 State Attorney General’s Offices. When a company or individual is under investigation, they may request the application of the criterio de oportunidadfrom the Public Prosecutor if there are merits in doing so.

Since there are no self-disclosure procedures, if a company or individual decides to cooperate in a criminal case by disclosing information, the information must be submitted directly to the Public Prosecutor in charge of the criminal investigation.

If a person denounces a criminal offence, such as an act of corruption, or testifies in connection with such, the Federal Law for the Protection of Persons that Intervene in Criminal Proceedings applies. Each State has a similar law applicable for protection of persons and witnesses in connection with local criminal proceedings.

This federal law is enforced by Mexico’s Attorney General’s Office, and applies for any person that could be in danger for intervening in criminal proceedings, as well as to witnesses that voluntarily accept to provide assistance in the prosecution of the federal criminal offence.

The protective measures for such individuals are focused on protecting physical, psychological, patrimonial, and family aspects. Among such measures are (i) constant surveillance by the relevant authority; (ii) anonymity for the individual (zero disclosure of identity); (iii) safe removal to another location if needed; and (iv) granting of a new identity if absolutely necessary due to potential risk.

On the other hand, the Federal Government has issued Guidelines for establishing a whistle-blower system for corruption acts connected to administrative offences and for determining the protective measures to be granted. This system and protective measures are covered by the Ministry of Public Service.

In Mexico there is no law governing the development of content for a whistle-blowing system for companies and protective measures regarding the investigation of criminal and administrative offences.

There are no incentives for whistle-blowers granted by the guidelines or law.

In all cases of a criminal investigation, a perpetrator can decide to effectively co-operate with the public prosecutor whether it is for the prosecution of a worse criminal offence than the one for which they are being prosecuted or is in connection with the same crime.

If the co-operation concerns the same crime, the perpetrator’s contribution must be lower than that of one of the other perpetrators, and, in both cases referred to above, the perpetrator must agree to appear in the trial as a witness.

In this regard, the public prosecutor can decide to dismiss the case against the perpetrator who decides to co-operate by applying the criterio de oportunidad, as explained in 6.2 Voluntary Disclosure Incentives.

The anti-bribery and anti-corruption regulations are applicable in both the criminal local and federal jurisdictions for criminal offences in accordance with the State Criminal Codes and the FCC.

Regarding bribery and corruption as administrative offences, the GLAL is applied in both local and federal jurisdictions.

The civil jurisdiction is not applicable in Mexico.

In criminal matters, the body in charge of investigating criminal offences committed by federal public servants, private individuals and/or legal entities is the Attorney General’s Office. For prosecution, the Federal Criminal Courts are the designated authority.

For local jurisdiction criminal offences, the respective bodies are the Attorney General’s Offices of the States of the Mexican Republic, and the State Criminal Courts.

It is important to point out that, in Mexico, both the Federal and the Local Attorney General’s Offices have an autonomous Prosecutor Agency for the Prosecution of Corruption Crimes in charge of an alternative prosecutor to the Attorney General. This was implemented as part of the National Anti-Corruption System as a consequence of the constitutional amendment.

Regarding administrative offences committed by local public servants, private individuals and/or connected legal entities, in accordance with Article 12 of the GLAL, internal control bodies have jurisdiction over the investigation and prosecution of the administrative offences.

Alternatively, the Local Administrative Courts of Justice have jurisdiction to issue a final ruling regarding administrative offences of local jurisdiction and the Federal Court of Administrative Justice for federal jurisdiction administrative offences.

In accordance with Article 14 of the GLAL, in the event that the administrative offence investigated also constitutes a criminal offence, the corresponding complaint will be filed so that criminal and administrative proceedings can be carried out in parallel.

Please refer to 7.2 Enforcement Bodies and 3.2 Geographical Reach of Applicable Legislation.

The NCCP provides the possibility to suspend proceedings or resort to an abbreviated procedure, explained as follows.

Proceeding Suspension

When the arithmetic mean of the criminal offence does not exceed five years and the defendant pays the related damages, they become subject to several conditions for suspending proceedings (eg, are ordered not to leave the country, and may be expected to appear before the authority several times) which must be fulfilled within a period of six months to three years. Once such conditions are met, the criminal proceedings are concluded with an acquittal.

The arithmetic averages for the criminal offences detailed in this guide are shown in 3.1 Limitation Period.

Abbreviated Procedure

The NCCP provides the abbreviated procedure, where the imprisonment penalty of the defendant could be reduced between two-thirds and one-third of the minimum imprisonment time penalty.

The abbreviated procedure can be requested by the Public Prosecutor before the criminal judge, but the damages caused must be repaired or indemnified, and there must not be opposition from the victim. Finally, the defendant must acknowledge having committed the criminal offence and renounces the oral hearing.

With this procedure, the defendant will be condemned without the need for an oral trial and without the need for other procedural stages to be completed, with the advantage of shortening the penalty of imprisonment.

Aggravation

The penalty for the crimes may be aggravated in the cases provided by law. For instance, Article 213-Bis of the FCC provides that the penalty of the crimes set forth in Articles 215, 219 and 222 of the FCC will be increased by up to half when the public official is a member of the police or customs or migratory bodies.

SEGALMEX

“Seguridad Alimentaria Mexicana” (known by its Spanish acronym SEGALMEX) is a state-owned enterprise operating under the Ministry of Agriculture and Rural Development. Its purpose is to achieve food self-sufficiency in Mexico by increasing the production of staple grains and milk.

The SEGALMEX case involves a significant misappropriation of funds amounting to MXN15.3 billion, in the company’s early years of operation, identified by the Ministry of Finance and Public Credit. The funds are alleged to have been diverted through fictitious purchases linked to shell companies.

In 2022, the federal government dismissed three senior officials and denounced them before the Prosecutor’s Office. However, to date, none of them have been convicted, and details regarding the case have been classified for a period of five years.

Odebrecht

Being one of the most emblematic cases of corruption in Latin America, the group of Brazilian engineering and construction companies formerly known as Odebrecht were the protagonists in the delivery of bribes in exchange for the award of contracts and tenders for PEMEX.

The former Director of PEMEX is also involved in this case. So far, there is no conviction in criminal matters related to it.

Unfortunately, to date, no convictions or substantial criminal sanctions have been imposed on the individuals or companies involved in the cases previously mentioned.

In connection with the NCCP, the FCC provides that companies must have in place, from the outset, an effective compliance programme which covers due control for not being held criminally liable for criminal offences or that assists in reducing any sanctions that could be imposed.

Therefore, a company can be held criminally liable for the lack of prevention of a bribery offence if no due control was implemented within the organisation.

Unfortunately, the FCC does not provide the content of a compliance programme nor the NCCP; however, a useful guide is the Policy of Integrity, which is designed for the purpose of excluding or attenuating administrative offences related to corruption. The LGRA defines the elements of a Policy of Integrity as follows.

• A clear and complete organisational and procedures manual that defines the functions and responsibilities of each department of the company, and specifies the chains of command and leadership for each corporate structure.
• A code of conduct that is duly published and made known to every person in the organisation and that has systems and mechanisms for effective implementation.
• Adequate and effective control, monitoring and audit systems that ensure compliance on a continuous and periodic basis throughout the organisation.
• Satisfactory whistle-blowing systems both for internal reports and for reporting to authorities, as well as disciplinary processes with clear and specific consequences for those who act contrary to internal standards or to Mexican legislation.
• Adequate systems and processes for training on ethics standards.
• Human resources policies to avoid hiring people who could be a risk to the integrity of the company. These policies cannot enable discrimination based on ethnicity, nationality, gender, age, disabilities, social status, health status, religion, political opinion, sexual orientation, marital status or any other that compromises human dignity or curtails human rights and liberties.
• Mechanisms to ensure transparency and publication of interests (always avoiding conflicts of interest).

Additionally, it is important that the compliance programme be adapted to the requirements and culture of the company.

There are no guidelines issued by and/or best practices suggested by the enforcement bodies.

Similar to a compliance monitorship, one of the penalties for legal entities is judicial intervention, whereby a controller is imposed by the judicial authority within the timeframe detailed in 5.1 Penalties for Conviction. The controller will oversee the acts carried out by the administration body of the legal entity.

In Mexico, the evaluation of corruption and anti-bribery is primarily carried out by civil society and international organisations.

Transparency International

In the 2023 edition of the Corruption Perception Index (CPI), the organisation Transparency International presented the ratings of 180 countries evaluated from 0 to 100 for level of corruption, taking into account the experiences revealed by the surveys of various experts.

This year, Mexico ranks 126th on the board with 31 points, for the fourth consecutive year since 2020, sharing the position with Kenya, Togo, and El Salvador. According to Transparency International, Mexico’s stagnant position is primarily due to a lack of judicial independence, which undermines the judiciary’s ability to act impartially and effectively, compounded by widespread corruption and impunity that prevent accountability and leave many high-profile cases unresolved.

World Justice Project Mexico

The World Justice Project (WJP) is a non-profit civil organisation that conducts research, compilation, and analysis of data on the Rule of Law in 140 countries. In the Index, which uses a scale from 0 to 1, 1 indicates the maximum adherence to the Rule of Law.

One of the factors that WJP considers for Rule of Law is the “absence of corruption”, which is considered as the use of public power to obtain a private benefit in executive, legislative, and local judicial branches, and in the security and justice system. WJP considers three forms of corruption: bribery, undue influence, and misappropriation of public resources. In the 2023 report, Mexico was ranked 118 out of 140 countries in the Rule of Law, dropping three places versus the previous year, with an index score of 0.41, along with Guinea. For absence of corruption, Mexico was positioned 135 out of 140, with an index score of 0.27, just above Venezuela, Cameroon, Gabon, Haiti, Cambodia, Bolivia and the Democratic Republic of Congo.

Mexican Institute for Competitiveness

The Mexican Institute for Competitiveness (IMCO) developed the Corruption Risk Index (IRC) to assess more than 260 federal institutions in Mexico. This index employs three sub-indices – transparency, competition, and legal compliance – to evaluate corruption risk. Institutions are scored on a scale from 0 to 100, with higher scores indicating a greater risk of corruption in public procurement.

In analysing the risk of institutions in 2022 compared to the previous year, IMCO found that 184 institutions had higher scores. This indicates that, between 2020 and 2022, 71% of federal institutions increased their corruption risk scores in public procurement. It was noted that federal institutions failed to comply with procurement laws by contracting MXN3.584 billion with high-risk companies, including sanctioned firms, shell companies, and newly established entities.

Regarding transparency in public procurement, the IRC results indicated that, in 2022, institutions exhibited a continued lack of transparency, with 16% of direct awards and 30% of tenders being incomplete due to non-compliance with the publication of one or more requisite documents.

In Mexico, law amendment initiatives are constantly proposed and, since the creation in 2015 of the National Anti-Corruption System, an increasing number have been presented to combat and prevent acts of corruption and bribery.

Currently there are no relevant law amendment initiatives on the horizon that could be proposed to the CPF or the LGRA on anti-corruption and bribery issues.