AUDIENCE POLLING

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
Ontex

Hugo López Coll
Shareholder
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