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MEXICO: An Introduction to Compliance

Contributors:

Raymundo Soberanis

Julieta Béjar

Ricardo Cacho

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Navigating Mexico’s Shifting Anti-Corruption Landscape in 2025

Mexico stands at a critical juncture in its battle against corruption. With a complex interplay of progress, setbacks, and evolving regulatory landscapes, the country faces both opportunities for reform and challenges that threaten to undermine transparency and accountability. This analysis delves into recent developments impacting Mexico’s regulatory framework, the role of civil society in anti-corruption initiatives, and the compliance strategies essential for navigating this dynamic environment.

Mexico’s economic outlook for 2025 presents significant challenges for compliance professionals. The International Monetary Fund (IMF) projects economic growth to slow to approximately 1.3%, driven by capacity constraints and weakening external demand. The government’s fiscal tightening, aimed at deficit reduction, could further constrain public sector projects, creating potential compliance risks related to public procurement and due diligence obligations. As public sector spending becomes increasingly scrutinised, corporate compliance programmes must adapt to manage these emerging complexities effectively.

The widespread use of direct awards in public procurement during Andrés Manuel López Obrador’s administration, with 82% of contracts granted through this method in 2023, underscores significant risks to transparency in Mexico’s public contracting processes. The dissolution of key institutions, such as the National Institute for Transparency, Access to Information, and Personal Data Protection (INAI), alongside the consolidation of oversight functions within the newly created Ministry of Anti-Corruption and Good Governance, has raised concerns about the concentration of power in the executive branch and weakened external accountability mechanisms. These developments align with judicial reforms that may undermine the independence of the judiciary and complicate dispute resolution. Against this backdrop, perceptions of corruption in Mexico remain high, as reflected in the country’s stagnation on Transparency International’s Corruption Perceptions Index. The diminished access to public information and weakened institutional accountability make it imperative for companies to strengthen compliance programmes, emphasising robust internal controls and proactive strategies to navigate an increasingly uncertain and politicised regulatory environment.

Inflationary pressures are expected to ease, with Banxico targeting a 3% rate, paving the way for interest rate reductions to stimulate domestic investment. However, economic volatility presents unique risks. Compliance leaders must remain vigilant against financial misconduct, including fraud, misrepresentation, and market manipulation, particularly in sectors susceptible to price volatility. Strengthening internal controls, enhancing transparency, and proactively managing risk will be critical as Mexico strives to address its historically low ranking in the 2024 Corruption Perceptions Index (CPI), which underscores ongoing challenges in combating corruption.

The recent election of President Claudia Sheinbaum has introduced new momentum to Mexico’s regulatory landscape, particularly through proposed constitutional reforms aimed at restructuring the judiciary. While these reforms are positioned as anti-corruption measures, they bring significant uncertainty concerning judicial impartiality and the enforceability of contracts. For businesses with cross-border operations, understanding and mitigating these risks will be vital, as predictable legal frameworks form the foundation of effective compliance strategies. Companies must evaluate the implications of these changes on their contractual obligations, dispute resolution mechanisms, and overall risk management protocols.

To further reshape Mexico’s anti-corruption landscape, the Sheinbaum administration established the Ministry of Anti-Corruption and Good Governance, replacing the former Ministry of Public Function. This new ministry seeks to strengthen ethical conduct among public servants, promote transparency in public projects, and adopt a preventive approach to corruption. However, the consolidation of oversight functions previously managed by the National Institute for Transparency, Access to Information, and Personal Data Protection (INAI) has raised concerns over potential conflicts of interest and concentration of power within the executive branch. Compliance professionals must closely monitor the ministry’s effectiveness in enhancing accountability and transparency amid such centralisation.

The administration’s focus on economic resilience, particularly through nearshoring initiatives and agricultural development, presents new investment opportunities but also elevates compliance risks. Companies must navigate stringent labour regulations, anti-bribery laws, and environmental standards to minimise exposure to enforcement actions. This is especially pertinent given Mexico’s dual compliance obligations under domestic legislation and extraterritorial statutes, such as the US Foreign Corrupt Practices Act (FCPA). Ensuring adherence to these complex regulatory frameworks will be pivotal for businesses seeking to operate ethically and competitively.

Fiscal tightening aimed at reducing Mexico’s deficit is expected to heighten scrutiny of tax compliance and anti-evasion efforts. Regulatory oversight may intensify, particularly as the government seeks to optimise public spending while adhering to fiscal discipline. Corporate compliance programmes must evolve to address these emerging challenges, strengthening their capacity to detect and mitigate potential violations of tax laws, accounting standards, and financial regulations.

The election of Donald Trump as President of the United States has introduced new uncertainties in the Mexico-US trade relationship. Given that the USA. remains Mexico’s largest trading partner, proposed tariffs on Mexican imports and stricter immigration policies could have far-reaching implications for bilateral trade and economic stability. President Sheinbaum’s administration aims to leverage Mexico’s strategic role in migration management to negotiate more favourable terms and mitigate potential disruptions. Compliance professionals must remain attuned to changes in trade policy and cross-border regulatory requirements to minimise operational and legal risks.

In this shifting environment, compliance is not merely a risk management necessity but a strategic differentiator. Businesses operating in Mexico must remain agile in responding to evolving regulatory expectations, leveraging robust internal controls, transparent governance practices, and proactive engagement with government reforms. By fostering a resilient and adaptive compliance culture, companies can better navigate the complexities of Mexico’s regulatory landscape and contribute to a more transparent, accountable society.

Mexico’s constitutional reforms under former President Andrés Manuel López Obrador have redefined critical pillars of governance, particularly within the judiciary, transparency, and anti-corruption efforts. The judicial reform, now constitutionally enshrined, reduces the Supreme Court from 11 to 9 justices and mandates the popular election of judges and magistrates. While positioned to increase democratic accountability, critics argue that these reforms risk politicising the judiciary, potentially undermining its independence and compromising judicial checks and balances crucial for protecting citizens’ rights.

Additionally, the dissolution of the National Institute for Transparency, Access to Information, and Personal Data Protection (INAI) and the transfer of its functions to the Ministry of Anti-Corruption and Good Governance have sparked concerns about conflicts of interest and weakened transparency. Placing public access to information under direct executive oversight risks eroding accountability and may hinder the public’s ability to scrutinise government actions effectively. Similarly, the elimination of the Executive Secretariat of the National Anti-Corruption System (SESNA) and its integration into the new ministry could disrupt co-ordinated anti-corruption initiatives, reducing collaboration among key entities and potentially weakening overall efforts to combat systemic corruption.

In 2024, civil society organisation Tojil achieved a significant victory by leveraging its citizen-reporting technology to hold corrupt public officials accountable. Through its mobile app for public complaints, Tojil facilitated the prosecution of police officers implicated in corruption, demonstrating the power of civic engagement and technology-driven transparency initiatives. This milestone reinforces the pivotal role that civil society can play in promoting accountability and challenging entrenched corruption within law enforcement and public institutions.

Despite ongoing reforms and initiatives, enforcement challenges persist. According to Impunidad Cero, only 1.14% of reported crimes in Mexico are resolved, underscoring the severity of systemic impunity and the pressing need for effective compliance strategies. Addressing these challenges will require sustained collaboration between public institutions, private entities, and civil society to drive meaningful change and build a culture of accountability.

Mexico’s journey toward a more transparent and accountable society remains complex and fraught with obstacles. However, opportunities for impactful reform and resilient compliance frameworks persist. Businesses operating in this dynamic environment must remain vigilant, adapting to shifting regulatory demands and championing ethical governance. The ongoing fight against corruption will hinge on collaboration across sectors – public institutions, private actors, and civil society – to foster sustainable growth and reinforce a culture of integrity.