Mexico’s New Anti-Corruption Initiative

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1 Response

  1. Luis Garcia says:

    Thanks for the very useful summary. Another issue that will be interesting to follow will be local (i.e. state and municipal) implementation: it’s not clear yet whether there will be a “race to the top” or a “race to the bottom” among states in setting up their local anticorruption systems. It would be great if business organizations or NGOs pressured local governments to compete to go beyond federal requirements and set up the best possible systems.

    Another important feature of the GL is the recognition of corporate compliance programs as potential factors in the reduction of penalties. Article 25 of the GL lists the elements of a corporate compliance program, basically adopting the requirements of an “effective” program under the US Federal Sentencing Guidelines and under OECD recommendations.