Cross-border FCPA enforcement: implications of the Rovirosa case

On August 7, 2026, Resolution 115/2026 was published in the evening edition of the Federal Official Gazette (Diario Oficial de la Federación, the “DOF”), amending the General Rules (the “New Rules”) referred to in the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita, the “LFPIORPI”).

This week, the U.S. government designated the Juárez Cartel (La Línea) and Los Viagras as Foreign Terrorist Organizations (FTOs), expanding existing sanctions on both groups. Companies should review their compliance programs and the due diligence processes applicable to their counterparties, with particular attention to those with operations, suppliers, or supply chains connected to Chihuahua and Michoacán.

It explores blockchain as an immutable, decentralized record for documenting compliance evidence and limiting the manipulation or concealment of relevant information. It describes a Mexican pharmaceutical-sector implementation to register reports, transactions, events and complaints.

The piece explains how Ponzi and pyramid schemes exploit interest in cryptoassets, often by offering purported high returns without a genuine underlying investment. It highlights regulatory coordination, user education and transaction-tracing tools as safeguards against fraud.

Globalization and the evolution of transnational crime have reinforced the relevance of international criminal law and its response mechanisms.

The article frames tax evasion as a form of corruption because it diverts resources intended for public spending to private benefit. It links tax contributions to shared services and collective welfare.