Corporate Investigations in Mexico

The seventh edition of Latin Lawyer’s The Guide to Corporate Compliance examines ultimate beneficial ownership requirements and key risks associated with tax noncompliance in Mexico.

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.

The strategy expands the U.S. approach to synthetic drug trafficking toward supply chain security, financial flows and international cooperation, with potential compliance implications for Mexican and multinational companies operating in Mexico.

The case provides an early reference point for FCPA enforcement following the U.S. Department of Justice’s 2025 guidance update.

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.