Cross-border overview: anti-corruption enforcement in Latin America

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The headlines could read ‘Latin America fights back.’ Over the past year, US regulators and domestic law enforcement agencies have  ramped up efforts to fight corruption in Latin America in both the public and private sectors. Investigations into the oil giant Petrobras, FIFA, and even the government of Argentina have appeared on the front pages of newspapers worldwide. And there is no sign that anti-bribery and anti-corruption enforcement in the region will slow down any time soon.

This article highlights several trends in recent anti-corruption enforcement activity by US and Latin American regulators. The first part examines US efforts to enforce the FCPA in Latin America. The second part discusses the growing efforts by several Latin American governments to enforce their domestic anti-corruption laws.

Developments in FPCA enforcement in Latin America

According to public records, the US government is currently investigating at least 108 companies for potential FCPA violations. Several  of these investigations relate to corporate operations in Latin American countries, including Argentina, Brazil, Colombia, Mexico, Venezuela and the Dominican Republic.1

We have identified several developments in the US government’s FCPA enforcement activities in the region.

Increase in whistleblower activity

According to the SEC’s 2014 Annual Report to Congress on the Dodd-Frank Whistleblower Program, consistent with an overall rise in the number of whistleblower tip-offs worldwide, the number of tip-offs from Latin America doubled between 2013 and 2014, from 25 to 50.2 In 2014, the SEC received 14 tip-offs from Argentina, six from Brazil, four from Colombia, and six from Mexico. While this rise cannot be attributed solely to tip-offs about corrupt activity – whistleblowers worldwide sent in 159 FCPA-specific tip-offs in 2014, only 10 more than in 2013 – it is an indication that the US’s enhanced efforts to police its own companies operating abroad are gaining traction in Latin America. We expect these numbers to rise in coming years.

Refining the definition of an ‘instrumentality’

It is rare that an FCPA case reaches the US appellate courts. However, in 2014, the US Court of Appeals for the Eleventh Circuit upheld the convictions of Joel Esquenazi and Carlos Rodriguez, two former executives of Terra Telecommunications Corporation, for their roles in a bribery scheme involving officials at Telecommunications D’Haiti SAM (Haiti Telco). In doing so, the court clarified what it means to be an ‘instrumentality’ of a foreign government. This case was also the first time that an appellate court addressed (and ultimately endorsed) the theory that ‘employees of alleged state-owned or state-controlled enterprises can be “foreign officials” under the FCPA.’3

In United States v Esquenazi, defendants appealed their  bribery convictions by arguing that the entity they were said to have bribed, Haiti Telco, was not an instrumentality of the Haitian government, and that therefore they could not have violated the FCPA.4 To support this argument, defendants relied on declarations from the Haitian Prime Minister, Jean-Max Bellerive, stating that ‘Telco has never been . . . a State enterprise,’ and that ‘there exists no law specifically designating Telco as a public institution.’5 The Eleventh Circuit rejected their argument, holding that Telco was an instrumentality of the Haitian government and that, by bribing Haiti Telco officials, the defendants violated the FCPA. The court explained that:

[T]o decide in a given case whether a foreign entity to which a domestic concern makes a payment is an instrumentality of that foreign government, we ought to look to whether that foreign government considers the entity to be performing a governmental function. And the most objective way to make that decision is to examine the foreign sovereign’s actions, namely, whether it treats the function the foreign entity performs as its own.6

It then found that there was sufficient evidence to show that Haiti Telco was, in fact, an instrumentality of the Haitian government: Haiti’s national bank owned 97 per cent of the company, its director general and board of directors were chosen by the government, and it ‘performed a function Haiti treated as its own, namely, nationalized telecommunication services’.7 It therefore upheld Mr Esquenazi’s conviction. Responding to Mr Rodriguez’s additional challenge that he did not know he was dealing with a government official, the court also determined that there was sufficient evidence produced at trial that Mr Rodriguez knew he was dealing with an instrumentality of a foreign government (and, ‘thus, [the bribe recipients’] statuses as foreign officials’), and upheld his conviction.8

None of this reasoning is new to FCPA lawyers. The Eleventh Circuit essentially ratified the DOJ’s standard approach for determining whether an entity is an instrumentality of a foreign government.9 In practical terms, Esquenazi made it harder for FCPA defendants to claim ignorance when confronted with evidence that they knew they were passing bribes to foreign government officials.

Continued industry sweeps

For several years, the US government has conducted global industry-focused ‘sweeps’. Last year, we discussed the ongoing sweeps in the medical device, and oil and gas industries. Since then, the DOJ has announced additional prosecutions in the airline industry that have involved corrupt activity in Latin America.

  • On 24 July 2014, Bernd Kowalewski, the former CEO of Lufthansa subsidiary BizJet, pled guilty to bribing officials in Mexico and Panama, making him the third BizJet official to agree on a plea deal since the DOJ began investigating the aircraft maintenance and repair corporation in 2012.10 BizJet had previously entered into a deferred prosecution agreement (DPA) with the DOJ in which it agreed to pay US$11.8 million to resolve charges against the company. Kowalewski was arrested in Amsterdam and extradited to the United States. Kowalewski admitted to securing contracts through illicit payments made directly to Mexican officials as well as payments routed through a shell company.11
  • On 10 December 2014, Dallas Airmotive Inc admitted to violating the FCPA and agreed to pay US$14 million in criminal penalties to resolve charges that it bribed officials in Brazil, Peru, and Argentina between 2008–2012.12 These bribes had been characterised as ‘commissions’ or ‘consulting fees’ in company documents and communications. The company and the DOJ entered into a DPA in which the company agreed to fully cooperate with the government’s ongoing investigation and to improve and enhance its compliance controls.13 Dallas Airmotive is the latest in a string of aircraft maintenance companies to resolve FCPA actions.14

We have no reason to suspect that the US government has suspended its existing sweeps of the medical device and oil and gas industries. However, there have been no announcements of new prosecutions in those cases since last year.


On 27 May 2015, the Justice Department indicted 14 individuals in connection with alleged corruption and mismanagement of FIFA, football’s (or soccer’s, to us Americans) governing body.15 The indictment charged the individuals, 13 of whom were from Latin American and Caribbean football organisations,16 with racketeering, wire fraud and money laundering conspiracies. The alleged crimes took place over 24 years, and involved over US$150 million in total improper payments. According to the DOJ:

Swiss authorities in Zurich arrested seven of the defendants charged in the indictment, the defendants Jeffrey Webb, Eduardo Li, Julio Rocha, Costas Takkas, Eugenio Figueredo, Rafael Esquivel and José Maria Marin, at the request of the United States....

The guilty pleas of the four individual and two corporate defendants that were also unsealed today include the guilty pleas of Charles Blazer, the long-serving former general secretary of CONCACAF [a regional football organization in the Americas] and former U.S. representative on the FIFA executive committee; José Hawilla, the owner and founder of the Traffic Group, a multinational sports marketing conglomerate headquartered in Brazil; and two of Hawilla’s companies, Traffic Sports International Inc. and Traffic Sports USA Inc., which is based in Florida.17

The FIFA indictments are not FCPA actions. None of the individuals charged were alleged to have paid any bribes to foreign government officials. Going forward, however, we cannot dismiss the possibility that the DOJ may uncover evidence of FCPA violations in connection with FIFA-sanctioned events. This investigation warrants continued attention from FCPA practitioners.

Local efforts to combat bribery and corruption

As we noted last year, when the US Congress enacted the FCPA in 1977, it sought to (i) protect US foreign policy interests that could be undercut if US companies bribed foreign officials, (ii) protect global markets from the distorting effects of bribery, (iii) help companies resist demands for bribes by creating stiff criminal penalties for corrupt behaviour, and (iv) claim a global leadership role and push other countries to take a stand against corruption.18 Over the past several years, and following significant enforcement activity by the US, Latin American governments – particularly those that have or may expect to have high levels of foreign investment – have either passed new anti-bribery laws or revived languishing ones to police corruption within their borders.

With all due credit to US efforts to enforce the FCPA in Latin America, many of the most significant anti-corruption developments in the region have come from local law enforcement. Many states, including Argentina, Brazil, Chile, Colombia, Mexico and Venezuela, are parties to international agreements requiring them to criminalise the bribery of foreign government officials, and several have passed their own domestic anti-corruption laws.19 Below, we discuss several examples of those laws in action.


Brazil’s Clean Companies Law came into effect on 28 January 2014. The law imposes liability on companies for bid rigging, fraud in public procurement, and for bribing domestic or foreign officials.20 It authorises penalties of up to 20 per cent of a company’s annual revenue, and applies to Brazilian companies as well as foreign companies doing business in Brazil.21 Recently, Brazilian prosecutors filed charges against eight employees of the aircraft manufacturer Embraer. The officials are alleged to have offered representatives from the Dominican Republic US$3.5 million in bribes to secure a military plane supply contract worth nearly US$100 million.22 This case in ongoing.

The most significant development in Brazil since last autumn, however, is the investigation – by both US and Brazilian regulators – of Petroleo Brasileiro SA, or Petrobras, Brazil’s state-run energy company. On 24 November 2014, Petrobras confirmed that it had received an SEC subpoena.23 Brazilian prosecutors allege that Paulo Roberto Costa, Petrobras’s refining director from 2004–2012, inappropriately granted lucrative contracts to a cartel of construction companies who kept prices artificially high in return for a cut of the profits.24 Costa was placed under house arrest by November 2014, and pled guilty to corruption and laundering funds abroad.25 Reports indicate that nearly 50 former and current legislators, including former Brazilian President Fernando Collor de Mello, are being targeted by investigators following the Supreme Court’s March 2015 decision allowing the investigation to proceed.26 An additional 27 executives from Petrobras and other construction firms have been charged by Brazilian law enforcement authorities.27 Petrobras is also defending against a class-action suit launched by its shareholders in federal court in New York, which alleges unspecified damages as a result of the artificial inflation of the company’s assets through the bribery scheme.28


In October 2014, the Argentinian Supreme Court created a special group of experts to support judges in the prosecution of anti-corruption cases. The group of 10 will include lawyers, accountants and engineers who will provide specialised counsel and increase courts’ capacity to tackle anti-corruption issues. They will answer directly to the Supreme Court.29

Outside groups have expressed concerns about Argentina’s commitment to fighting foreign bribery. In 2014, Argentina was examined by the OECD Working Group on Bribery regarding the implementation of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and related instruments. In its conclusions, the OECD Working Group expressed doubts about Argentina’s commitment to fight foreign bribery because Argentina still has no law to punish companies for foreign bribery or to prosecute its citizens who commit this crime abroad; widespread delays continue to plague complex economic crime investigations; and executive contact with, and disciplinary processes against, judges and prosecutors threaten their independence.

The Working Group also made recommendations to improve Argentina’s fight against foreign bribery, including that it should:

  • promptly implement the new Criminal Procedure Code;
  • reduce the very high number of judicial vacancies and the use of surrogate judges;
  • seriously investigate and prosecute all foreign bribery cases as appropriate;
  • encourage companies to adopt measures to prevent and detect foreign bribery; and
  • better protect whistleblowers from retaliation.

The Working Group will evaluate Argentina again in early 2016 to assess progress. We expect to see legislative reform and more enforcement activity as this deadline approaches.

The Working Group’s conclusions notwithstanding, there has been recent noteworthy enforcement activity. For example, on 17 June 2015, Argentine prosecutors charged eight people in a case involving alleged bribery by German steelmaker Ferrostaal to win defence contracts. In April 2014, an Argentine provincial prosecutor began a probe of alleged payments by BP Plc’s Argentine venture Pan American Energy LLC to extend the concession of the country’s main oil field. In addition, the Minister of Planning, Julio de Vido, and the governor of the Chubut province, Mario das Neves, are under investigation by the United States SEC for involvement in a bribery scheme in connection with oil contracts.30

The most significant developments in Argentina, however, have involved allegations against sitting politicians. A series of high-profile corruption cases, involving current President Christina Fernandez de Kirchner, her late husband and former president Nestor Kirchner, as well as other top officials, roiled Argentina in 2014. According to filings with the federal Anti-corruption Office, the current and former Presidents Kirchner saw their total wealth increase from US$2.5 million to US$17.7 million during Nestor Kirchner’s term in office.31 This raised questions regarding the source of the funds, and prompted further investigation into the business dealings of the Kirchners and their associates.

One such investigation led to the ‘K-Money trial’, an investigation into construction magnate Lazaro Baez. Details of the investigation leaked in April 2013 on a popular news show. Later that year, the prosecuting attorney was dismissed for inappropriately disclosing information to the media (though he has since been reinstated). The prosecutor alleged that Baez planned to launder US$65 million in funds diverted from public works programmes through shell companies on behalf of the Kirchners. Baez maintains his innocence, acknowledging legitimate business dealings with the Kirchners and stating that his company has succeeded in winning – and delivering on – public works and infrastructure projects that have helped modernise Argentina’s infrastructure.32 A complaint laying out money laundering charges against Baez has been filed.33

Additionally, there have been further developments in the prosecution of current Vice President Amado Boudou since last year. On 28 June 2014, a federal judge indicted Boudou and five others on criminal corruption charges. The indictment – the first against a sitting Vice President – alleged that Boudou and a business associate asserted improper influence in lifting the bankruptcy of printing company Ciccone Calcografica through a beneficial payment plan, then securing the award of a government minting contract to the company while it was allegedly under the Vice President’s control.34 In May 2014, shortly before the indictment was announced, Jose Guillermo Capdevila, former legal director in the Ministry of Economy and key witness in the proceedings, fled the country citing concerns for his safety. The court called the Vice President to testify, and he complied at an expedited hearing on 9 June 2014, maintaining his innocence during lengthy testimony.35 Additional charges relating to a car purchase in the early 1990s were filed against the Vice President in December 2014.36 The Federal Court confirmed the prosecution against the Vice President on 19 February 2015, for ‘bribery and negotiations incompatible with the public administration’.37

However, Argentina’s anti-corruption efforts have not been without tragedy. Alberto Nisman, a prosecutor investigating President Kirchner for attempted cover-up of a terrorist act in 1994, was found dead at his apartment on 18 January 2015, days after he publicly accused the President of the cover-up. Investigators found an indictment against the President stuffed in his trash can during the investigation into his death. On 26 February, a federal judge dismissed the allegations in Nisman’s indictment, stating that they did not ‘minimally hold up’.38


Chile has taken a hard line against domestic corruption. President Michelle Bachelet announced a series of new rules on 19 March 2015 that require public officials – federal and local – to release information on their finances and assets for the two years prior to their government service.39 Since 2013, Chile has passed measures to facilitate the investigation and prosecution of corruption cases, and prosecutors have initiated high-profile anti-bribery cases against senior government officials and congressmen. For example, the Chilean Public Prosecutor’s Office stated that 1,431 investigations into misconduct by governing officials were initiated in 2013.40

President Bachelet’s new rules followed on the heels of a string of high-level corruption investigations that rocked Chile:

  • There is an ongoing investigation into allegations of insider trading and improper use of public office by President Bachelet’s son, Sebastian Davalos, and his wife, Natalia Compagnon.41
  • On 7 March 2015, Chile’s National Prosecution Service announced the detention of six defendants in an ongoing corruption scandal involving conglomerate Grupo Penta, one of Chile’s largest companies, on charges of tax fraud, bribery and money laundering.42 The individual charges suggest the corporation may face a criminal action. The detained individuals include the company’s owners Carlos Delano and Carlos Lavin, former accounting manager Marcos Castro, tax official Ivan Alvarez, a subsidiary’s director Hugo Bravo, as well as Chile’s former deputy mining minister, Pablo Wagner.43
  • Chile’s tax authority also issued a criminal complaint alleging tax fraud and bribery against Chilean chemical company SQM in March 2015 for events between 2006–2014.44 According to local lawyers, the case highlighted the difficult of initiating bribery investigations alone – the prosecutors in that case used the issuance of a criminal complaint from the tax authorities to search for evidence of corrupt behaviour.45
  • The Public Prosecutor’s Office is investigating a scheme involving LAN, an airline company that allegedly bribed the Transport Minister for authorisation to enter Argentina in June 2014.46
  • An investigation into an alleged tax fraud scheme led to the arrest of an Internal Revenue Service official last November.47 The investigation, involving allegations that the tax official was bribed to fabricate tax losses, is ongoing.48

In addition, ongoing corruption investigations involve the Education Ministry and National Certification Commission, the national university certifying body, as well as other senior government officials and congressmen in the Penta tax fraud case.49


On 4 May 2015, Mexican President Enrique Peña Nieto signed legislation to amend Mexico’s constitution in order to create a comprehensive National Anti-Corruption System (Sistema Nacional Anticorrupción, or SNA) to tackle bribery issues.50

The Mexican Federal Congress has one year to issue general laws in the following areas:

  • Powers of the Federal Audit Office.
  • Distribution of powers to establish administrative responsibilities for, obligations towards, and sanctions against public servants and private parties who participated in illicit acts, as well as procedures for their application.
  • Organisation and function of the Federal Court of Administrative Justice, and resources to challenge its resolutions.

Once the general laws mentioned above have been published, within 180 days, the federal congress, the state legislatures, and Federal District Assembly will issue corresponding laws and make the necessary regulatory modifications, according to their respective role and powers.

The new legislation endows congressional and law enforcement anti-graft agencies with broader investigative powers, heightens the disclosure requirements on public servants related to possible conflicts of interest, and creates strong penalties for private corruption.51 By requiring buy-in through state approval and local legislation, the new legislation aims to tap resources at all levels of government in tackling corruption, rather than focusing narrowly on a highly centralised anti-corruption agency that is most likely to pursue high-profile cases. In addition, the new legislation puts a greater focus on state and local financial transparency in an effort to fight corruption across the board.52

This development came on the heels of a series of corruption scandals reaching the highest levels of Mexico’s government. In early November 2014, an investigative news report alleged that President Peña Nieto and his wife, Angelica Rivera, had close ties to business group Grupo Higa, a subsidiary of which was part of a consortium that had just won a $3.7 billion high-speed rail contract from the Mexican government.53 The report alleged that the first lady’s house was owned by a member of Grupo Higa, and that another member of Grupo Higa rented helicopters and airplanes to Peña Nieto during his presidential campaign.54 The Treasury Secretary was also alleged to be living in a home purchased from the same contractor.55 In response to the public outcry, the Peña Nieto administration cancelled the rail contract.56

Mexico’s National Water Commission Director, David Korenfeld, also drew criticism in April 2015 for using an agency helicopter to transport his family to the airport.57 After photos of the family with an agency helicopter surfaced, an investigation was launched by the anti-corruption agency. On 9 April 2015, Korenfeld resigned.58


Our analysis of DOJ and SEC trends in anti-corruption enforcement remains unchanged from last year. We expect US regulators to continue the same basic FCPA enforcement strategies that have served them well in recent years, though with a slightly recalibrated focus where required.

First, the DOJ and the SEC likely will continue to concentrate on investigating activities in BRIC countries (Brazil, Russia, India, and China), and to rely on whistleblowers and tip-offs to identify new cases.

Second, US regulators likely will continue to probe key industries where the risk of corruption is high (such as in the oil and gas industry, and the airline industry).

Third, it is all but certain that the US government will continue to encourage cooperation amongst its various regulators and law enforcement agencies, and between those agencies and their counterparts in other countries. Companies facing FCPA investigations should therefore remember to retain counsel who can interface with local authorities as needed, and, if needed, to retain lead counsel capable of coordinating a cross-border investigation.

However, US enforcement priorities represent – thankfully – only a small portion of the effort to police corruption in Latin America. As the past year saw a significant increase in domestic enforcement actions throughout the region, we expect to see these efforts continue in years to come.


  1. Certain companies do not disclose any countries where potential violations might have occurred, and many companies do not disclose all countries involved.
  2. US Securities and Exchange Commission, 2014 Annual Report To Congress On The Dodd-Frank Whistleblower Program (17 November 2014); available at; see also Carlos Ayres, Whistleblowers: 2014 Year in Review, FCPA Americas Blog (4 December 2014),
  3. Mike Koehler, ‘Foreign Official’ Cert Petition Filed in Supreme Court, FCPA Professor (15 August 2014),
  4. United States v Esquenazi, 752 F.3d 912, 919-20 (11th Cir. 2014).
  5. United States v Esquenazi, 752 F.3d 912, 919-20 (11th Cir. 2014).
  6. United States v Esquenazi, 752 F.3d 912, 924-25 (11th Cir. 2014).
  7. United States v Esquenazi, 752 F.3d 912, 928-29 (11th Cir. 2014).
  8. United States v Esquenazi, 752 F.3d 912, 930 (11th Cir. 2014).
  9. See US Department of Justice, A Resource Guide to the US Foreign Corrupt Practices Act 20-21 (2012).
  10. Press Release, Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges, US Department of Justice (24 July 2014);
  11. Press Release, Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges, US Department of Justice (24 July 2014);
  12. Press Release, Dallas Airmotive Inc. Admits Foreign Corrupt Practices Act Violations and Agrees to Pay $14 Million Criminal Penalty, US Department of Justice (10 December 2013),
  13. United States v Dallas Automotive, Deferred Prosecution Agreement, available at:
  14. See Michael Koehler, Dallas Airmotive Inc, The Latest Aircraft Maintenance Company Enforcement Action, FCPA Professor Blog (12 December 2014),
  15. Press Release, Nine FIFA Officials and Five Corporate Executives Indicted for Racketeering Conspiracy and Corruption (27 May 2015),
  16. Santiago Perez and Juan Forero, FIFA Scandal Puts Latin America in the Spotlight, Wall Street Journal (27 May 2015)
  17. Press Release, Nine FIFA Officials and Five Corporate Executives Indicted for Racketeering Conspiracy and Corruption (27 May 2015),
  18. Mike Koehler, The Story of the Foreign Corrupt Practices Act, 73 OHIO ST. L.J. 929, 943, 949 (2012).
  19. Michael Martinez, What anti-corruption developments in Brazil and Latin America mean for you, Inside Counsel (25 June 2014),; OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions: Ratification Status as of 21 May 2014,; List of OECD member countries,; Freshfields Bruckhaus Deringer LLP, Bribery Watch (available via subscription) (Freshfields Bribery Watch).
  20. The Clean Companies Law: Brazil joins the global fight against corruption, Freshfields Bruckhaus Deringer LLP (January 2014),
  21. Id. For additional discussion of the Clean Companies Law, see last year’s GIR Review of the Americas.
  22. Freshfields Bribery Watch.
  23. Paul Kiernan, Petrobras Says Received Subpoena From SEC Requesting Documents, Wall Street Journal (24 November 2014),; Paul Kiernan, Petrobras Corruption Scandal Draws Attention of US Investigators, Wall Street Journal (12 Nov 2014),
  24. Id.
  25. Will Connors and Luciana Magalhaes, How Brazil’s ‘Nine Horsemen’ Cracked a Bribery Scandal, Wall Street Journal (6 April 2015),
  26. Id.
  27. Id.
  28. Jeb Blount, Petrobras Faces Class-Action Lawsuit in New York Court Over Graft, Reuters (8 Dec 2014),
  29. Freshfields Bribery Watch. See also
  30. Emilia Delfino, Investigan a De Vido en EE.UU. y llaman a declarar a empresarios, Perfil (10 May 2015),
  31. Santiago Perez and Taos Turner, In Argentina, Mix of Money and Politics Stirs Intrigue Around Kirchner, Wall Street Journal (28 July 2014),
  32. Id.
  33. Freshfields Bribery Watch.
  34. Id.
  35. Freshfields Bribery Watch.
  36. Tihomir Gligorevic, Argentina: VP Boudou to Stand Trial for ‘Illegal Car Purchase’, In Serbia (17 December 2014),
  37. Freshfields Bribery Watch.
  38. Karen Zraick, The Mysterious Death of Alberto Nisman, New York Times (20 February 2015),
  39. Adam Dobrik, Chilean Anti-Corruption Measures Ignore a Fundamental Problem, Global Investigations Review (24 March 2015),
  40. Freshfields Bribery Watch. These cases included, but were not limited to, bribery cases.
  41. Id.
  42. Adam Dobrik, Chilean Anti-Corruption Measures Ignore a Fundamental Problem, Global Investigations Review (24 March, 2015),
  43. Adam Dobrik, The Chilean Corruption Case That’s Making Companies Nervous, Global Investigations Review (12 March 2015),
  44. Adam Dobrik, Chilean Anti-Corruption Measures Ignore a Fundamental Problem, Global Investigations Review (24 March 2015),
  45. Id.
  46. Freshfields Bribery Watch.
  47. Id.
  48. Id.
  49. Freshfields Bribery Watch.
  50. Mexico’s Pena Nieto Signs New Anti-corruption Law, VOA News (4 May 2015),
  51. Id.
  52. Id.
  53. Joshua Partlow, Luxurious Presidential House Draws Mexican Press Scrutiny, Washington Post (9 November 2014), available at
  54. Id.
  55. Associated Press, Mexico Water Commission Director Resigns Following Uproar, Investigation Over Helicopter Trip, FOXNEWS.COM (9 April 2015),
  56. Joshua Partlow, Luxurious Presidential House Draws Mexican Press Scrutiny, Washington Post (9 November 2014), available at
  57. Associated Press, Mexico Water Commission Director Resigns Following Uproar, Investigation Over Helicopter Trip, FOXNEWS.COM (9 April 2015),
  58. Id.

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