On July 19, 2017, the General Law of Administrative Responsibilities (GLAR) went into effect in Mexico, making it a “serious administrative offense” for individuals and companies to engage in bribery, collusion in public bid procedures, influence peddling, and misuse of public funds and resources. Sanctions for violations include significant fines, temporary disqualification from participation in public bids, payment of damages and lost profits, suspension of business activities, and dissolution of a company.
When determining a company’s liability, GLAR allows the relevant enforcement authority to take into account whether the company self-disclosed the violation, and whether the company had in place a real and effective compliance program or “integrity policy”—analogous to what federal law enforcement authorities in the United States can consider when resolving matters involving companies.