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Anti corruption in Mexico: corporate liability for bribery, the integrity policy, self reporting and criminal penalties

Last verified: 2026-10-26 · Status: Stable

Under the General Law of Administrative Responsibilities a company is sanctioned when people acting in its name commit bribery, collusion, influence peddling or other serious offences to benefit it, whether or not the official accepts the benefit. The administrative court can fine the company up to twice the benefit or, if none, up to 1.5 million UMA, bar it from public procurement for up to ten years, suspend it or dissolve it; the authority weighs whether it had an integrity policy with seven elements. The first to confess before proceedings start gets a 50 to 70 percent reduction, offences by private parties lapse after seven years, and the Federal Criminal Code separately punishes bribery of Mexican and foreign officials with up to fourteen years in prison and corporate fines, suspension or dissolution.

USD conversions use MXN 18.6638 per US dollar, the US Federal Reserve H.10 noon buying rate in New York for 23 October 2026 (FRED series DEXMXUS), the latest observation available when this page was verified. Peso amounts set in UMA use the 2026 daily UMA of MXN 117.31, in force since 1 February 2026 (INEGI publication in the DOF of 9 January 2026, as cited in IMSS Technical Council agreement ACDO.AS2.HCT.270126/9.P.DIR). Conversions are for orientation only.

Key facts

Minimum company fine for offences by private parties when no benefit is proven	1000 UMALGRA art. 81, section II, as of 2026-10-26 · in force
Maximum company fine when no benefit is proven (1,500,000 UMA, 2026)	175965000 MXNLGRA art. 81, section II, as of 2026-10-26 · in force
Maximum fine as a multiple of the benefit obtained	2 timesLGRA art. 81, as of 2026-10-26 · in force
Maximum suspension of a company's activities	3 yearsLGRA art. 81, section II, as of 2026-10-26 · in force
Maximum fine reduction for the first self reporting party	70 %LGRA art. 89, as of 2026-10-26 · in force
Period after leaving office during which hiring a former official with privileged information is restricted	1 yearsLGRA art. 72, as of 2026-10-26 · in force
Maximum prison term for bribery above 500 UMA (domestic or foreign officials)	14 yearsCPF arts. 222 and 222 bis, as of 2026-10-26 · in force

The rule

1. Offences by private parties. Private parties commit serious administrative offences when they engage in: bribery (promising, offering or delivering any undue benefit to public servants, directly or through third parties, in exchange for acts or omissions related to their functions or the abuse of real or supposed influence, regardless of acceptance or result); unlawful participation in procedures while barred, or on behalf of barred persons; influence peddling; use of false information or simulation of requirements, and obstruction of investigations; collusion in public procurement, including agreements between competitors to obtain undue benefits or harm public funds; misuse of public resources; and hiring a former public servant within one year of leaving office who has privileged information that directly benefits the hirer in the market. Collusion also covers international commercial transactions involving foreign public bodies or officials in which Mexican individuals or companies take part; for these the text names the Secretaría de la Función Pública as investigating authority.
Cost to do it: No filing; exposure only. Due diligence on intermediaries and on hires of former officials is the main preventive cost.
Example: Hiring, six months after they leave, the procurement official who ran a tender the company now bids for, and using their inside knowledge, is an offence for both the company and the former official (art. 72). / A Mexican subsidiary that agrees bid prices with a competitor in a state hospital tender commits collusion under art. 70 as well as a cartel under the competition law.Ley General de Responsabilidades Administrativas (LGRA), DOF 18 July 2016, last reform DOF 15 December 2025, Arts. 65 to 72, 2016-07-18 official text · verified 2026-10-26

2. Corporate liability and the integrity policy. Companies are sanctioned when the acts linked to serious offences are carried out by individuals acting in their name or representation seeking a benefit for the company. In deciding liability, the authority assesses whether the company has an integrity policy with at least: (I) a clear and complete organization and procedures manual with defined functions and chains of command; (II) a published and communicated code of conduct with real enforcement; (III) adequate and effective control, monitoring and audit systems that test integrity standards regularly; (IV) internal and external whistleblowing systems, with disciplinary processes and concrete consequences; (V) training on integrity measures; (VI) human resources policies to avoid hiring people who create integrity risks, without discrimination; and (VII) mechanisms ensuring transparency and publicity of its interests. Reporting or cooperating by management or shareholders, and repairing the harm, mitigate; failing to report known corruption aggravates.
Cost to do it: Building the seven elements is an internal and advisory cost (manual, code, audit, hotline, training, HR screening); no certification or filing is required.
Example: A distributor whose sales agent pays a municipal inspector can point to its code of conduct, hotline, training records and agent due diligence to mitigate the sanction. / Group wide programs built for the US FCPA or the UK Bribery Act usually cover the seven elements, but the procedures manual and local whistleblowing channel should be documented in Mexico.Ley General de Responsabilidades Administrativas, Arts. 24, 25 and 81, section II, last paragraphs, 2016-07-18 official text · verified 2026-10-26

3. Sanctions for companies and individuals. For companies, the court may impose: a fine of up to twice the benefit obtained or, if none, 1,000 to 1,500,000 times the daily UMA; a ban on public procurement, leases, services and public works for three months to ten years; suspension of activities for three months to three years; dissolution; and compensation for harm to public funds. Suspension and dissolution only apply where the company obtained an economic benefit and its management, supervisory bodies or shareholders took part, or where it is systematically used for serious offences. Individuals face up to twice the benefit or 100 to 150,000 UMA, a procurement ban of three months to eight years and compensation. Sanctions consider participation, repeat offences, economic capacity, harm and benefit.
Cost to do it: Company fine without proven benefit: MXN 117,310 to MXN 175,965,000 (about USD 6,285 to USD 9.43 million); individuals MXN 11,731 to MXN 17,596,500.
Example: A contractor that obtained a MXN 40,000,000 public works contract through bribery risks a fine of up to MXN 80,000,000 (twice the benefit) and a ban of up to ten years from public contracts. / About USD 2.14 million benefit and up to about USD 4.29 million in fines.Ley General de Responsabilidades Administrativas, Arts. 81 and 82, 2016-07-18 official text · verified 2026-10-26

4. Self reporting and limitation. A person who committed or is taking part in a serious offence may confess to the investigating authority. If no presumed offender has been notified of the start of proceedings, the first to provide sufficient evidence, cooperate fully and continuously and stop participating when asked gets a reduction of 50 to 70 percent of the sanctions and up to the full procurement ban; later applicants with additional evidence may get up to 50 percent. A confession after proceedings start brings up to 30 percent off the sanction and the ban. The procedure can be coordinated with competition leniency under LFCE art. 103. The power to sanction offences by private parties lapses seven years after the offence or after it ceased.
Cost to do it: Self reporting is free; cost is the internal investigation and counsel.
Example: A company that uncovers kickbacks in a customs agent relationship and confesses first, before any proceedings are notified, can cut the fine by 50 to 70 percent and avoid the procurement ban. / On a USD 9.43 million maximum fine, a 70 percent reduction leaves about USD 2.83 million.Ley General de Responsabilidades Administrativas, Arts. 74, 88 and 89, 2016-07-18 official text · verified 2026-10-26

5. Criminal bribery. Giving, promising or delivering any benefit to a public servant so that they act or omit an act related to their functions is bribery: three months to two years in prison and 30 to 100 days fine where the benefit does not exceed 500 UMA or cannot be valued, and two to fourteen years and 100 to 150 days fine above that; money or gifts delivered are forfeited to the State. The same penalties apply to whoever offers, promises or gives money or any gift to a foreign public official, directly or through intermediaries, to obtain or keep undue advantages in international business, including officials of foreign state companies and public international organizations; a company involved can be fined up to 1,000 days fine and suspended or dissolved. Companies can face criminal consequences for bribery and influence peddling, including suspension and closure for six months to six years, a ban on public contracts for six months to six years and judicial intervention; they can be reduced by up to a quarter if the company had a permanent compliance body before the facts and reduced the harm.
Cost to do it: The 500 UMA line is MXN 58,655, about USD 3,143.
Example: An offer of MXN 100,000 to an official to speed a permit exceeds 500 UMA, so the giver faces two to fourteen years in prison. / About USD 5,358; the bribe does not need to be accepted for the administrative offence (LGRA art. 66).Código Penal Federal, arts. 222 and 222 bis (reformed DOF 23 August 2005, 12 March 2015 and 18 July 2016) and 11 Bis (added DOF 17 June 2016), last reform of the code DOF 13 March 2026, CPF arts. 11 Bis, 222 and 222 bis, 2016-07-18 official text · verified 2026-10-26

Sanction	Companies	Individuals
Fine	Up to 2 times the benefit, or 1,000 to 1,500,000 UMA (MXN 117,310 to MXN 175,965,000)	Up to 2 times the benefit, or 100 to 150,000 UMA (MXN 11,731 to MXN 17,596,500)
Public procurement ban	3 months to 10 years	3 months to 8 years
Suspension of activities	3 months to 3 years
Dissolution	Yes, by court order, if management or shareholders took part or the company is used systematically
Compensation	Damages to public funds	Damages to public funds

Sanctions for offences by private parties (LGRA art. 81; 2026 UMA MXN 117.31; USD at MXN 18.6638)

Worked example

A foreign engineering firm's Mexican subsidiary pays a consultant who passes part of the fee to a state utility official to win a contract. Under LGRA arts. 24 and 66, the subsidiary is liable even though the payment went through a third party. If no benefit is proven, the fine runs from MXN 117,310 to MXN 175,965,000 (about USD 6,285 to USD 9.43 million), plus a ban from public contracts of up to ten years. The individuals face two to fourteen years in prison under CPF art. 222. Confessing first, before proceedings are notified, reduces the sanctions by 50 to 70 percent (LGRA art. 89).

Step by step

1. Document the seven elements of LGRA art. 25: procedures manual, code of conduct, audit, whistleblowing, training, HR screening and disclosure of interests.
2. Run due diligence and anti bribery clauses for agents, customs brokers, consultants and permit managers, since payments through third parties count (LGRA art. 66).
3. Screen hires of former public servants who left office in the last year (art. 72).
4. Set rules for gifts, hospitality and facilitation payments to officials, since CPF art. 222 covers any benefit given for an act related to an official's functions.
5. Prepare an investigation and self reporting protocol: the 50 to 70 percent reduction is only for the first party before proceedings are notified (art. 89).

Common traps

Believing an offer is harmless if refused: bribery exists regardless of acceptance or result (LGRA art. 66).
Relying on intermediaries: offers through third parties are covered by both the LGRA and the Criminal Code (LGRA art. 66; CPF art. 222 bis).
Treating bid coordination as only an antitrust issue: it is also collusion under LGRA art. 70.
Assuming old conduct is safe: offences by private parties lapse only after seven years (LGRA art. 74).
Having a paper program only: art. 25 requires real enforcement, periodic audit and concrete consequences.

Sources

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