Gifts, Travel & Entertainment: Shifting Sands in Terms of Regulation and Policy in Mexico

March 27, 2019 10:45am

Patricia Rivas Mandujano
Regional Compliance Officer LatAm
Bausch Health Companies Inc.

Ángel de León Zamora
Head of Legal and Compliance, Americas Division

Hugo López Coll
Greenberg Traurig LLP

  • Interpreting the GLAR’s explicit prohibition of gifts, travel, entertainment & hospitality versus AMLO’s program to combat corruption (“Ningún funcionario público podrá recibir regalos, cuyo valor exceda los 5 mil pesos”)
  • Status update on enforcement of the policy
  • How does the law apply to public versus private officials?
  • Who determines what is a “reasonable” gift, entertainment or hospitality request? What guidelines can businesses use to adapt their corporate policies to the requirements of the law?
  • How to identify who is involved in the authorization and approval of gifts, hospitality and other requests?
  • Clarifying the policy’s scope of application: Trips to conduct investigations, marketing-related activities, etc.
  • How to handle business interactions with both corporate entities and officials from high risk jurisdictions