Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor

FCPA Blog Daily News

« SFO brings new charges in Unaoil investigation | Main | Karp and Mendelsohn: Is RBS the first enforcement action under DOJ policy against piling on? »

PEMEX requires compliance programs for contractors

In the next few weeks suppliers and contractors of PEMEX, Mexico's state owned oil company, will be required to submit information on the existence and state of their compliance programs.

Many of the regional and local companies working with PEMEX could have difficulty meeting this new requirement and will have to undertake significant efforts to continue working with the Mexican oil giant.

This new requirement is the result of a compliance overhaul at PEMEX. Jose Antonio Gonzalez Anaya, now Secretary of Finance and Public Credit of Mexico, committed to enhancing compliance during his tenure as CEO of PEMEX (2016-2017). The effort was funded in part by a grant by the USAID, which financed consulting, legal and related expenses.

The current PEMEX CEO, Carlos Treviño Medina, continued the project.

For PEMEX contractors and suppliers, a newly automated process (“Procura”) will award points for a robust compliance program.

PEMEX has benchmarked global best practices, in part by using information provided by multinationals about their compliance programs.

PEMEX has also adopted a Code of Ethics, Code of Conduct and a series of specific policies, and is working in their implementation. It addresses gift-giving, for example, by requiring all gifts to be delivered to a centralized reception area, and returned to senders if not permitted under Mexican law.

Companies doing business with PEMEX will need to examine their current compliance programs and undertake necessary upgrades.


Luis Dantón Martínez Corres, pictured above, is a partner leading the corporate governance and compliance practice of the Mexico-based law firm, Ritch Mueller. He previously served as head of legal and trustee services of Nacional Financiera, S.N.C., a leading Mexican development bank. He's also admitted to practice in New York. He can be contacted here.