Anti-Corruption 2024 Comparisons

Mexico has ratified The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions; 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 by 32 local jurisdictions which corresponds to each one of the states in Mexico. Therefore, for corruption matters the Federal Criminal Code (FCC) provides the federal criminal offences and each state criminal code provides the local criminal offences. 

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

The corruption acts are also considered as administrative offences under the General Law of Administrative Liability (GLAL), which set forth the public officials’ principles and obligations for a correct and lawful fulfilment of their duties. The administrative offences are applicable to both public officials and private individuals, including companies, that engage in any act of corruption.

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

In Mexico there are no guidelines since the interpretation and enforcement of the national legislation corresponds to 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 in Article 222, subsection I of the FCC is constitutional even though the criminal law does not provide 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 2023. 

A bribe is any promise made, or benefit or money illicitly given, to a public official in order that the public official executes or refrains from executing any act related with the duty inherent to his or her public official’s job, charge, or commission. In this regard, bribery is considered as 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 give the benefit to corrupt a public official even though the benefit is received by third parties linked to the latter, such as public official’s relatives, partners or third parties with whom the public official has business, professional or labour relationship, among others. 

For the purpose of bribery, a benefit can be considered as any goods, stocks, precious stones or metals, services, donations, or real-estate, including when a property is sold notoriously below the market price.

Likewise, under Article 222 subsection III of the FCC is also considered when, in the meantime of the Federal Budget process for approval, 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 his or her own or third-party benefit;
• awarding 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;
• state-owned enterprises;
• 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 kind of expenditures or facilitation payments to a public official, since the criminal law does not set forth any exception, neither does the GLAL which governs the public officials conduct. Moreover, the GLAL provides that the 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 given to a foreign public official it is considered a federal criminal offence under Article 222 Bis FCC, which has extraterritorial reach as explained in section 3.2 Geographical Reach of Applicable Legislation. In this kind of bribery, the particularities are:

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

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

• 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 to his or her job, charge, or commission.
• A public official who requests or encourages, directly or through third parties, any resolution or execution of any act that corresponds to a public official’s job, charge, or commission, for his or her own or for relatives' or a third party’s economic benefit with whom they are linked by friendship or businesses.

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 to 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 of their own or for a third party’s benefit.

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

The Federal Fiscal Code establishes as federal criminal offences the following activities connected to 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;
• 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 his or her job, charge, or commission, when such information is not in the public domain regardless of the connection that such information has to his or her 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);
2. permits, licences, awards, or authorisations of an economic kind (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 his or her wealth without proving the legitimate increase or origin of his or her goods and properties acquired when being a public official (Article 224).

As detailed in sections 2.1 Bribery and 2.2 Influence-Peddling, the criminal offences comprise the conduct when the public official commits the criminal offence indirectly through third parties or for the benefit of third parties. 

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

Moreover, when the criminal offence is being investigated in the first half of the arithmetic mean, the investigation suspends the statute of limitation, and such term can be extended by a half.

For instance, when the bribe is more than MXN51,870.00 the imprisonment penalty goes from two up to 14 years, so the statute of limitation is of eight years, and if the investigation starts the day after the criminal offence was committed, the public prosecutor will have up to 12 years for investigating and filing charges against the defendant before a criminal judge.

The statute of limitation runs once the crime is committed and can only be stopped when the defendant is brought before a criminal judge for filing the charges against him or her.

Therefore, the statute of limitation for investigating the criminal offences detailed in the above sections is the following, without considering the extensive term previously explained:

• 2.1 Bribery: 1.15 years when the bribe is less than MXN571,870.00 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 other Mexican(s) or foreigner(s) against 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 foreign 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 the 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 the companies can also be held liable for similar criminal offences to those detailed in section 2.4 Public Officials, depending on whether such crime is of 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 of the one that can be brought against the individuals involved in the criminal offence committed, and due to such circumstance that criminal action is separate from the one related to the individuals and is not extinguished by the transformation, merger, absorption, or division of the company.

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

The defences for any criminal offences can be found in the FCC and the local criminal codes, which both comprise the same kind defences. Therefore, the defences will depend on a case-by-case basis, since any of the possible causes for excluding the crime must be proven. 

Such exclusion causes might involve one of the elements constitutive of the criminal offence not being met, or that the action is carried out under an error since the defendant was not aware of illicit conduct. 

The defence causes constitute the exceptions of a criminal offence, so a defence cause is not applicable when it cannot be proven. 

The Mexican Criminal Law does not provide de minimis exceptions, since once the criminal offence is proved and the perpetrator is charged, the criminal proceeding needs to be concluded unless an alternative solution is applied, as explained in 7.4 Discretion for Mitigation; an exclusion cause of the crime is proven 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 kind of criminal offences. However, as explained in section 6.1 National Legislation and Duties to Prevent Corruption, having a compliance programme can help to diminish the penalty for companies when they are convicted. 

The criminal offences detailed in 2. Classification and Constituent Elements have different penalties. In summary, pursuant to the FCC for individuals the penalties go from three months up to 14 years of imprisonment and from 100 up 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 up to six years;
• closing down of an establishment or premises from six months up to six years;
• prohibition for carrying out the activities where the crime was, for a period of six months up to ten years;
• prohibition to participate or bid in public tenders for a period of six months up to ten years;
• judicial intervention for safekeeping the employees or creditors’ interests for six months up to six years.
• fine;
• dissolution of the legal entity.

The judicial authority has sole discretion and power to determine the quantum of the penalty, and 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 such crime; the employment position of the perpetrators within the legal entity; the compliance compromise level of the company; the damages caused and the social interest of the consequences.

Considering that dissolution is the most serious penalty, the judicial authority also assesses whether such penalty is strictly necessary to warrant the national and public security and to assess whether the national economy or public health is jeopardised; or that 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 in law. 

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

• the interest protected by the criminal offence;
• if the conduct was wilfully committed or not;
• the means used for the commission of the criminal offence;
• the circumstance in which the criminal offence was committed;
• the contribution of the perpetrator on the criminal offence commission;
• assess whether the perpetrator was avoiding the 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 the criminal judges take  the following into consideration:

• the hierarchical level of the public official;
• the level of responsibility he or she had pursuant to the job, charge, or commission;
• the level of seniority;
• the backgrounds of the public service performed, incomes, and degree of education;
• any other special circumstance connected to the illicit conduct executed by the public official.

Regarding the criteria for determining the quantum of the penalty against legal entities, please refer to 5.1 Penalties on Conviction.

The FCC in connection with the NCCP provides that the companies must have, prior to the commission of the criminal offence, an effective compliance programme which evidences a due control within the organisation for not being held criminally liable, and assists in diminishing the sanction to 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:

• A clear and complete organisational and procedures manual that clearly defines the functions and responsibilities of each department of the company, and clearly 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.
• Adequate 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).

The lobbying activities are regulated in the internal regulations for the Mexican Congress which is comprised by the Senator and Deputies Chambers; however, there is no regulation for lobbying activities before the executive and judicial branches. 

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

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

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

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. Most of the states also have a law applicable for the protection of persons and witnesses in connection to local criminal proceedings.

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

The protective measures for such individuals are focused to protect the physical, psychological, patrimonial and family aspects. Among such measures are the constant surveillance by the relevant authority, forbidding disclosure of the individual’s identity, and the assurance of the individual being safely removed to another place when needed, or, in certain cases, being granted a new identity when strictly needed due to potential risk. 

On the other hand, the Federal Government has issued guidelines for establishing a whistle-blower system for acts of corruption connected to administrative offences and for determining the protective measures to be granted. Such a system and its protective measures are in the charge of the Ministry of Public Service.

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 worst criminal offence than the one for which he or she is being prosecuted or if it is in connection with the same crime.

If the co-operation is with the same crime, the perpetrator's contribution to such crime shall be lower than one of the other perpetrators, and in both cases referred to above the perpetrator shall 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.

In Mexico there is no law which develops the content of a whistle-blowing system for companies and for protective measures regarding the investigation of criminal and administrative offences: please refer to the relevant regulation stated in 6.4 Protection Afforded to Whistle-Blowers.

The anti-bribery and anti-corruption regulations are applicable in both the criminal local and federal jurisdiction 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 Mexico’s Attorney General 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 Offices have an autonomous Prosecutor Agency for the Prosecution of Corruption Crimes that is in charge of an alternative prosecutor to the Attorney General. This was implemented as the National Anti-Corruption System as a consequence of 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 the internal control bodies have jurisdiction for the investigation and prosecution of said 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 the 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 the criminal and administrative proceedings can be carried out in parallel.

Pursuant to Article 222 of the NCCP, the criminal complaint can be filed before the public prosecutor in writing (including digitally) or orally. If orally,  a record will be produced by the public prosecutor.

For corruption crimes the denouncement shall be filed before the Prosecutor Agency for the Prosecution of Corruption Crimes.

When filing the complaint, or once the criminal investigation starts, the complainant can provide any kind of relevant information or present witnesses. 

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

Proceeding Suspension

When the criminal offence does not exceed five years and the defendant pays the damage caused, for suspending the proceedings the defendant becomes subject to several conditions (ie, is ordered not leaving the country, and may be expected to appear before the authority several times) which shall be fulfilled within a period of six months to three years. Once such conditions are fulfilled, the criminal proceedings are concluded with an acquittal judgment.

For sentences relating to criminal offences detailed in this guide, please refer to 3.1 Limitation Period.

Abbreviated Procedure

The NCCP provides the abbreviated procedure, where the imprisonment penalty of the defendant could be reduced between 2/3 and 1/3 of the minimum imprisonment time penalty.

The abbreviated procedure can be requested by the public prosecutor before the criminal judge, but the damages caused shall be repaired or indemnified and there shall not be opposition from the victim. Finally, the defendant shall acknowledge having committed the criminal offence to the oral trial. 

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 diminishing the penalty of imprisonment.

Please refer to 7.2 Enforcement Body.

Agronitrogenados

In 2012, the CEO of Altos Hornos de México (AHMSA), a company that owned the Agronitrogenados plant for agricultural fertiliser, allegedly bribed the former Director of Petróleos de México (PEMEX, a state-own company) in exchange for PEMEX purchasing this plant for a higher amount than the price market.

In April 2021, the CEO entered into a deferred payment agreement with PEMEX for USD200 million to repair the damage caused and his criminal process is still suspended until he finishes paying the agreed amount.

However, the former director of PEMEX is still facing the criminal proceedings connected to this case. 

Master Fraud

Between 2013 and 2014, the federal government deflected MXN7.67 billion through a resource triangulation scheme by 11 government agencies to eight public universities, which in turn improperly awarded contracts to shell companies.

Even though to date there is no conviction in criminal proceedings against any former public official or private party involved in such scheme, in administrative proceedings three former public officials, who were involved in the signing of the agreements through which MXN52 million were deflected, have been sanctioned.

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 led in the delivery of bribes in exchange for being awarded with contracts and tenders for PEMEX.

The former Director of PEMEX is also involved in this case, and so far there has been no criminal conviction relating to Odebrecht case.

So far, there has not been a high level of sanctions either to individuals or to legal entities. For example, in the instance of a master fraud, sanctions have been imposed on former public officials for administrative offences but not for crimes.

The Federal Court of Administrative Justice sanctioned three ex-public servants for damages of MXN52 million in 2021.

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

Transparency International

In the 2022 edition of the Corruption Perception Index (CPI), the organisation Transparency International presented the ratings of 180 countries evaluated from 0 to 100 the level of corruption, taking into account the experiences revealed by the surveys of various experts.

This year, Mexico occupies 126th place in the board with 31 points, along with Bolivia, Laos and Uzbekistan, and there was no change with respect to the previous year since Mexican citizens perceive corruption as an intrinsic part of the public sector, which is attached to the fact that there are still no judicial resolutions that condemn the most notorious acts of corruption in the country, such as the case of Odebrecht.

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. Through 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 the 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.

Within the 2022 report, Mexico obtained overall the position of 115 out of 140 countries in the Rule of Law, with an index score of 0.42, along with Mali and Turkey. Regarding the absence of corruption, Mexico was positioned 134 of 140 with an index score of 0.26, just above Bolivia, Haiti, Gabon, Cameroon, Cambodia and the Democratic Republic of the Congo. 

Internally in Mexico a trend towards stagnation was reported in 2022, as seven federal entities decreased their scores, ten remained unchanged and 15 showed marginal increases in their scores.

Mexican Institute for Competitiveness

The Mexican Institute for Competitiveness AC (IMCO by its acronym in Spanish) developed a data analysis of all federal public purchases made between 2018 and 2021 called the Corruption Risk Index (IRC by its acronym in Spanish), with which risk practices or failures in the public procurement system in Mexico are identified through 27 indicators of competition, transparency, and compliance with the law.

Of the purchases that were carried out in 2021, the IMCO observed that 29% of federal institutions increased their corruption risk score in public purchases compared to 2020. Likewise, it indicated that in general terms federal institutions failed to comply with the procurement laws by awarding more than MXN9 billion to risky suppliers such as ghost companies, sanctioned and recently created.

Regarding transparency within public procurement, the IRC results indicated that only one of three public tenders failed to publish one or more documents required by law, as well as highlighting that 53% of purchases could not be verified in its entirety by IMCO because the internet links from which said information can be obtained are not available or do not work correctly, which causes a lack of transparency on behalf of said public institutions.

In Mexico, initiatives of law amendments in general terms are constantly presented and, since the creation in 2015 of the National Anti-Corruption System, more and more have been presented to combat and prevent acts of corruption and bribery.

Currently there are no relevant initiatives of law amendments on the horizon that could be made to the CPF or the LGRA on anti-corruption and bribery issues. However, it is worth noting that the United Nations Office on Drugs and Crime (UNODC) in Mexico and the organisation Global Compact Mexico recently announced (7 November 2023) a collaboration to promote collective anti-corruption actions in the business sector in Mexico. Therefore, the presentation of various initiatives by the civilian population is expected through this new collaboration.