Takeaways from the Anti-Corruption Chapter of the USMCA

The FCPA Blog


In this article, Richard Mojica, Marc Alain Bohn*, and Collmann Griffin, with input from Alejandra Montenegro Almonte, discuss the proposed anti-corruption provisions in Chapter 27 of the United States-Mexico-Canada Agreement (USMCA), which stand out as one of the noteworthy differences between the newly negotiated pact and its predecessor, the North American Free Trade Agreement (NAFTA). The article covers the requirements of Chapter 27 of the USMC; how the USMCA's obligations would be enforced; how Chapter 27 could change U.S., Mexican, and Canadian anti-corruption law; and what Chapter 27 means for companies and compliance departments. "Despite the uncertainty of the USMCA's ratification and ultimate enforceability, there are a few key takeaways that smart companies and their compliance departments can act upon now or in the near future," the authors wrote.

*Former Miller & Chevalier attorney