Von Wobeser y Sierra Recognized in Global Investigations Review 100

Following up on our October 2024 communication regarding the reform initiative to the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) and the Federal Penal Code (CPF), we inform you that after being postponed in previous months, on June 18, the United Commissions of Justice and Legislative Studies of the Senate discussed and generally approved the corresponding reform opinion.

On June 9, 2025, Agreement 77/2025 was published in the Official Gazette of the Federation (DOF), through which the Ministry of Finance and Public Credit (SHCP) adopts administrative simplification and regulatory improvement measures that directly impact various procedures related to the Federal Law for the Prevention and Identification of Operations with Illicit Resources (LFPIORPI).

On June 9, 2025, the United States Department of Justice (DOJ) released a memorandum titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” in compliance with Executive Order 14209. The new DOJ guidance shifts anti-corruption enforcement toward cases that impact U.S. strategic interests, such as national security, drug cartels, or transnational criminal organizations.

Flash News: Reform to the Anti-Money Laundering Law (LFPIORPI) and Federal Penal Code. As we informed you in our communications from October 2024 and June 2025, the Congress of the Union approved, in an extraordinary session, the decree that substantially reforms the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) and the Federal Penal Code (CPF).

On February 21, 2025, the Federal Judicial Weekly published a criterion on the criminal liability of legal entities in Mexico. The thesis, with digital registration number 2029987, derived from the amparo in review 318/2023, of the Second Collegiate Court in Criminal Matters in the State of Mexico, is titled: 'Criminal liability of legal entities. Requirements for the respective motivation, in accordance with article 11 bis of the Penal Code of the State of Mexico.'

In light of the imminent designation of Mexican drug cartels as terrorist organizations by the current United States administration, Mexican companies and individuals may be subject to OFAC's stringent regulations. These regulations prohibit any financial or commercial interaction with sanctioned actors.