FCPAméricas Blog

Important Aspects of Mexico’s National Anti-Corruption System – Part 2

Author: Matteson Ellis

SNA2A prior post highlights five notable features of the new National Anti-Corruption System (SNA) in Mexico. This post discussed five more that could be particularly relevant to non-Mexican companies and individuals.

Individual Liability Bolstered. The SNA establishes the General Law of Administrative Liabilities and amends the Federal Criminal Code in ways that bolster individual liability for bribery and bribery-related offenses. Mexican and non-Mexican individuals will be liable for “serious administrative offenses,” such as bribery, collusion in public bid procedures, influence peddling, wrongful use of public resources, and wrongful recruitment of ex-public servants. The burden of proof for the administrative violation is relatively low – “beyond a reasonable doubt” – and the statute of limitations is long ... Read more

Important Aspects of Mexico’s National Anti-Corruption System – Part 1

Author: Matteson Ellis


Adoption of the many components of Mexico’s new National Anti-Corruption System (the Sistema Nacional de Anti-Corrupción or “SNA”) is well underway. The Mexican Government amended the country’s Constitution on May 27, 2015, to allow for the SNA to move forward. President Peña Nieto signed into law new anti-corruption legislation on July 18, 2016, as part of the system. The Mexican Senate is now overseeing the selection process for the newly-established National Anti-Corruption Prosecutor. And the General Law of Administrative Liabilities, a key component of the SNA, will enter into force on July 19, 2017.

This post and the next highlight key aspects of the SNA that companies and individuals doing business in Mexico sho... Read more

Anti-Bribery in Brazil: 2016 Year in Review (Part II)

Author: Carlos Ayres

BrazilCorruptionA lot has been going on in Brazil in the anti-bribery field. Some specific developments are particularly noteworthy. A previous post highlighted 5 relevant developments that took place in 2016. Four other relevant developments are summarized below.

Compliance as a requirement of public procurement. ENCCLA – Brazil’s National Strategy Against Corruption and Money Laundering – is a forum in the Brazilian government that brings together a broad range of ministries and agencies involved in the prevention and combat of money laundering and corruption. Members of ENNCLA include Federal Police, Federal Prosecutors, Office of the Comptroller General (CGU), and the Brazilian Securities and... Read more


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