Matteson Ellis Comments on Mexican Anti-Corruption Enforcement in Anti-Corruption Report

"Understanding the Interplay Between Mexican and U.S. Anti-Corruption Laws"

Anti-Corruption Report

10.16.2019

Matteson Ellis commented on Mexico's new approach to anti-corruption enforcement, discussing differences between U.S. and Mexican anti-corruption laws and compliance expectations in both countries. Mexico's General Administrative Liabilities Act (GALA) applies to corporations, individuals, and public officials, while the U.S. Foreign Corrupt Practices Act (FCPA) only applies to individuals and corporations, Ellis said. Additionally, Mexico's National Anti-Corruption System (NAS), which applies to conduct in Mexico, focuses on payments to both foreign and local officials, while the FCPA is limited to foreign officials. Multinational corporations should engage in localization efforts to make sure their compliance policies are appropriate for each jurisdiction in which they operate and consistent with local expectations, Ellis said.