Mexico

DLA Piper advised Empresa Distribuidora y Comercializadora Norte S.A. (Edenor), Argentina’s largest electricity distribution company, in its issuance of new additional Class 7 notes.  The additional issuance of Class 7 notes further increased the outstanding volume, enabling Edenor to strategically harness favorable market conditions in parallel with other prominent issuers. The notes are denominated and payable in US dollars, at a fixed annual nominal interest rate of 9.75 percent. The notes mature on October 24, 2030, under the company’s global issuance program for up to US$750 million (or its equivalent in other currencies), as authorized by the Argentine Securities Commission. The additional notes were issued in the amount of V/N US$90 million, thereby increasing the total nominal value of the outstanding Class 7 Notes to US$475 million. DLA Piper acted as legal counsel under New York and Argentina law to Edenor with a team comprising of Partners Joshua A. Kaufman (New York), Marcelo Etchebarne, Alejandro Nobila, Of Counsel Nicolás Teijeiro, and Associates Daiana Suk and Federico Vieyra (all Buenos Aires). Edenor’s additional issuance of Class 7 notes exemplifies DLA Piper’s international reach, sophisticated cross-border structure, and seamless collaboration and coordinated efforts across the firm’s Latin America and US teams. DLA Piper in Latin America’s team offers full-service business legal counsel to domestic and multinational companies with interests in and operations throughout the region. Our integrated approach to serving clients combines local knowledge with the resources of the DLA Piper global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, in addition to our US-based cross-border attorneys, our teams frequently work with our professionals throughout the LatAm region, Iberian Peninsula, and around the globe. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve all our clients’ legal and business needs, whether they are based in Latin America or wish to do business there. Related professionals:Josh Kaufman, Marcelo Etchebarne, Alejandro Noblía, Nicolas Teijeiro, Daiana Suk, Federico Vieyra

Written by: Sonia Torres Pabón, Nereida Melendez-Rivera, Francisca Franzani, Alberto Rubio, Antonio Cardenas Arriola, José Marcelo Allemant Transparency International recently published its 2025 Corruption Perceptions Index (CPI), which ranks 182 countries and territories by their perceived levels of public-sector corruption. According to the report released on February 10, 2026, Latin America scored an average of 42 out of 100, with two countries – Dominican Republic (37) and Guyana (40) – showing significant improvement. However, 12 of 33 countries’ scores have declined since 2012. This alert summarizes the key findings and implications for businesses and institutions operating in the region. Overview of the CPI 2025 The CPI uses a scoring scale from 0 (highly corrupt) to 100 (very clean) for its rankings. Notably, for the first time in more than a decade, the global average CPI score dropped to 42, with 122 out of 182 countries scoring below 50. The CPI report notes that persistent corruption in Latin America has been associated with challenges in governance, public services, and security. These factors remain relevant for foreign investors, multinational corporations, and legal practitioners operating in the region. Regional rankings – Americas The following table summarizes the CPI 2025 scores and its observations for selected American countries:   Country 2025 CPI score Key observations Uruguay 73 Regional leader; among the strongest democracies in the Americas Chile 63 Recent decline noted despite historically strong institutions United States 64 Sustained decline to its lowest score Argentina 36 Investigations into alleged corruption in the management of funds for medicines for people with disabilities Dominican Republic 37 One of two Latin American countries showing significant improvement since 2012 Guyana 40 One of two Latin American countries showing significant improvement since 2012 Ecuador 33 Decline in transparency and civic freedoms; laws limiting NGOs' access to funding and obstructing operations El Salvador 32 Increased intimidation and hostility toward independent media Peru 30 Corruption in public services has had severe consequences, including scandals involving contaminated food in public schools Mexico 27 Ranked 141/182 globally and last among OECD countries; linked to institutional weakness and organized crime infiltration Guatemala Below 27 Ranked just below Mexico Haiti 16 Among the three lowest in the region; marked by high repression and failed institutions Nicaragua 14 Among the three lowest in the region; entrenched corruption and repression Venezuela 10 Lowest-scoring country in the Americas; widespread corruption has fueled poverty and malnutrition   Key CPI 2025 themes and risks Organized crime and political infiltration: In several Latin American countries, corruption is increasingly linked to organized crime. In Mexico, the CPI findings highlight the infiltration of organized crime into politics, facilitating political influence and undermining accountability. This nexus between corruption and criminality poses heightened compliance and security risks for businesses operating in affected jurisdictions. Weakening of democratic checks and balances: Countries, including El Salvador and Ecuador, are experiencing a decline in transparency and civic freedoms. New laws limiting NGOs' access to funding, combined with intimidation and hostility toward independent media, have reduced citizen oversight and the ability to hold governments accountable. These developments signal heightened regulatory unpredictability and reputational risk. Impact on public services and human rights: In Peru, corruption in public services has resulted in severe consequences, including scandals in which alleged bribes to bypass health inspections reportedly led to contaminated food being distributed in public schools. In Venezuela, widespread corruption has contributed to a rise in poverty and malnutrition as millions of families survive on limited access to food, water, and electricity. These conditions underscore the human cost of unchecked corruption and the importance of robust due diligence. US FCPA enforcement considerations: The temporary freeze of Foreign Corrupt Practices Act (FCPA) enforcement pursuant to an Executive Order issued by President Donald Trump ultimately resulted in the revised FCPA Guidelines promulgated in June 2025. Among other things of note, the FCPA Guidelines prioritize enforcement against conduct involving criminal cartels (even if tangentially) and “transnational criminal organizations” (TCOs) more broadly. Those countries with significant cartel or organized criminal activity are encouraged to be alert to the enhanced risk to legitimate business that may unwittingly have contact with cartel members or organized crime, which is fairly common across multiple industries and sectors. The FCPA Guidelines also underscore “enforcement actions against conduct that directly undermines US national interests” – a broad category. Although DOJ leadership has pushed back on the suggestion that there has been any retreat in FCPA enforcement, the new policies shift the enforcement landscape for companies with operations in Latin America. Implications for businesses and compliance programs The CPI 2025 findings underscore the importance of robust anti-corruption compliance frameworks for companies operating in or expanding into Latin America. Businesses may consider the following: Enhanced due diligence: Companies are encouraged to strengthen third-party due diligence processes, particularly for agents, distributors, and joint-venture partners in countries with persistently low or declining CPI scores. Updated risk assessments: Organizations can update their country-level risk assessments to reflect the latest CPI data and country-specific factors, such as organized crime infiltration, weakened institutions, and civic space restrictions. Training and awareness: Anti-corruption training can be tailored to address the specific risks identified in the CPI, including bribery in public procurement, corruption in public services, and political exposure. Monitoring regulatory developments: Companies are encouraged to closely monitor developments in FCPA enforcement and other anti-bribery regimes, given signals of potential shifts in enforcement priorities. Conclusion Given the anti-corruption landscape in Latin America, as assessed in the CPI 2025 report, businesses and institutions are encouraged to remain vigilant. We will continue to monitor developments and provide updates as warranted. For further information or assistance with anti-corruption compliance matters in Latin America, please contact our US Latin America White Collar practice group: Sonia Torres – US and Puerto Rico Nereida Meléndez – US and Puerto Rico Francesca Franzani – Chile Alberto Rubio – Argentina Antonio Cárdenas – Mexico José Allemant – Peru  

The Mexican mining sector is entering a new regulatory and policy cycle under the federal administration of President Claudia Sheinbaum Pardo. This cycle is structured around Plan México 2030, a long‑term industrial and economic development strategy grounded in the doctrine of Mexican Humanism, which prioritizes social welfare, environmental sustainability, and national sovereignty. Mining has been formally positioned as a strategic industry for the country’s energy transition, industrial self‑sufficiency, and technological development. As a result, federal authorities have articulated five regulatory and policy pillars that will shape mining operations, permitting, financing, and compliance in the coming years:   Water regulation and corporate water responsibility; 2. Forest sustainability and land‑use management; 3. Mining education, innovation, and technological sovereignty; 4. Adoption of international sustainability standards (TSM) 5. Institutional financing through the Mining Development Trust (FIFOMI);   For mining companies, these pillars represent not only regulatory compliance obligations, but also a framework for securing legal certainty, access to public incentives, institutional financing, and long‑term operational continuity in Mexico.  I. Plan México 2030 and the New Industrial Policy Framework.   Plan México was formally presented on January 13, 2025, as the federal government’s roadmap to position Mexico among the world’s ten largest economies by 2030. The strategy seeks to rebalance industrial development through:   a) Increasing productive investment to more than 25% of GDP, with an initial portfolio estimated at approximately USD 277 billion across nearly 2,000 projects. b) Ensuring that at least 50% of domestic supply and consumption in strategic sectors is sourced from national production, reducing structural dependence on Asian imports. c) Developing 100 industrial parks and 12 “Welfare Hubs” designed to promote regional specialization, nearshoring, and territorial economic integration.   Mining is explicitly identified as the foundation of industrial sovereignty, given its essential role in supplying critical minerals for energy infrastructure, manufacturing, telecommunications, and advanced technologies.   Federal authorities, including the Ministry of Economy, have emphasized the need to prevent strategic vulnerabilities in mineral supply chains and to align extractive activity with environmental protection, social development, and technological autonomy.   From a regulatory perspective, adherence to these policy pillars enables mining companies to benefit from incentives established under the federal Relocation Decree, including accelerated depreciation of new investments and enhanced tax deductions for workforce training conducted in partnership with academic and research institutions. II. Water as a Human Right: Regulatory Reform and Corporate Water Responsibility.   The first pillar is anchored in the National Water Plan 2024–2030 and the National Agreement for the Human Right to Water and Sustainability, which redefine water as a public, strategic national asset rather than a purely economic resource.   Recent reforms to the National Water Law and the enactment of the new General Water Law introduce the concept of corporate water responsibility, which prioritizes human and domestic consumption, imposing stricter obligations on concession holders, including mining companies, to:   Measure and digitally report extracted volumes; Monitor usage efficiency and reuse processes; Comply strictly with authorized parameters and technical conditions; and Implement mitigation and compensation mechanisms where applicable.   Voluntary corrective measures, such as the formal return of unused concession volumes, may mitigate regulatory exposure and significantly reduce the risk of sanctions, including the revocation of water concessions, suspension of operations, or administrative closure.   In parallel, the federal “Water for Well‑being” digital platform will centralize reporting and permitting procedures, granting preferential administrative treatment to companies that demonstrate sustained compliance and best operational practices.   Legal and transactional impact: Water compliance will become a core component of regulatory due diligence, asset valuation, project finance structuring, and M&A risk allocation in the Mexican mining sector.   III. Forest Sustainability: Toward Net‑Zero Deforestation by 2030.   Under the Institutional Program of the National Forestry Commission (PIC) 2025–2030, Mexico has formally committed to halting ecosystem degradation and achieving net‑zero deforestation.   Mining projects are now expected to adopt an integrated land‑use and environmental management approach, supported by:   166 federal lines of action for ecosystem restoration; Strengthened inspection and sanction mechanisms; and Increased scrutiny of unauthorized land‑use changes.   This regulatory evolution is particularly relevant given that more than 50% of Mexico’s forest territory is socially owned (ejidos and agrarian communities), which directly links environmental compliance to land tenure security and community relations. Legal and operational impact: Environmental permits, land access agreements, and social license to operate will be evaluated holistically. Reforestation and restoration programs are becoming not only environmental obligations but practical tools to mitigate operational risk, community disputes, and climate‑related contingencies. IV. Mining Education, Innovation, and Technological Sovereignty.   The Ministry of Economy has established the Mexico 2025 Mining Education Committee, a multi‑sector body aimed at transforming mining from a predominantly extractive activity into a knowledge‑based industry.   The committee’s objectives include: Establishing partnerships with more than 26 academic institutions; Expanding dual education models and professional internship programs; Promoting domestic research and the registration of Mexican patents; and Reducing structural dependence on foreign mining technologies.   Legal and strategic impact: Companies that participate in these initiatives may benefit from preferential treatment under industrial integration programs, improved labor stability, reduced turnover, and enhanced positioning in public procurement and development projects. V. International Sustainability Standards: Adoption of TSM.   The formal adoption of the Towards Sustainable Mining (TSM) standard from the Mining Association of Canada (MAC) by the Federal Mexican Government´s Ministry of Economy, the Mexican Mining Chamber (CAMIMEX) and the Canadian Chamber of Commerce in Mexico (CANCHAM) introduces objective, measurable, and auditable indicators for environmental, social, and governance performance.   TSM Protocols require: Periodic external audits (every three years); Public disclosure of performance metrics; and Continuous improvement benchmarks across environmental protection, community relations, safety, and governance.   Compliance aligns Mexican mining operations with the Mexico–Canada Action Plan 2025–2026 and significantly strengthens credibility with regulators, development banks, institutional investors, and international partners subject to ESG investment criteria.   Legal and financial impact: TSM compliance is increasingly relevant in project finance, cross‑border transactions, public listings, and regulatory negotiations, functioning as a reputational safeguard and a facilitator of access to international capital markets. VI. FIFOMI: Strategic Financing for the Mining Sector.   The Mining Development Trust (FIFOMI) is a public development finance institution whose trustor is the Ministry of Finance and Public Credit, whose trustee is Nacional Financiera, and which is regulated by the National Banking and Securities Commission.   Since December 2024, FIFOMI has undergone significant institutional restructuring, resulting in:   An upgrade of its credit rating to A+ (stable) by Fitch Ratings; A reduction of its delinquency rate from 37% to 24.9%; Reactivation of first‑tier lending; Evaluation of more than 40 mining projects nationwide; and Expansion of technical assistance and training programs benefiting more than 4,000 individuals annually.   FIFOMI currently operates in direct alignment with:   Objective 3.10 of the National Development Plan 2025–2030 (increase national content in production chains); and Plan México’s objective to increase small and medium size companies (PYMES) access to credit in strategic sectors to at least 30% by 2030. Its financial instruments include:   Direct loans (simple credit, refurbishment, working capital, refinancing); Factoring under the FIFOMI‑NAFIN Production Chains program; Technical advisory services in exploration, operation, processing, commercialization, environmental compliance, and industrial safety; and Specialized training programs offered both virtual and in person.   Looking forward, FIFOMI is expected to consolidate as a central institutional partner for mining project development, particularly for junior and mid‑tier operators, and to play an active role in the administration of strategic mining allocations and national processing infrastructure.   VII. Conclusion: Regulatory Compliance as a Strategic Business Asset.   While these five pillars undeniably increase regulatory density and compliance obligations, they also provide a comprehensive framework for legal certainty, institutional financing, operational continuity, and reputational strengthening.   Mining companies that proactively align their governance structures, operational practices, and investment strategies with this new policy architecture will be better positioned to:   Secure permits and concessions; Access public and private financing; Navigate ESG‑driven investor scrutiny; Strengthen relationships with authorities and communities; and Maintain their social license to operate.   In the context of Plan México 2030, regulatory compliance is no longer merely defensive. It has become a strategic asset for sustainable growth in the Mexican mining industry.     ALN Mining Law Firm Joel Gonzalez Javier Andujo Marco Perea Legal Alert – For informational purposes only. This publication does not constitute legal advice.

DLA Piper advised Artistic Milliners, a global denim manufacturer, in its acquisition of a majority stake in denim supplier Cone Denim from textile supplier Elevate Textiles. Cone Denim will continue to operate as a standalone portfolio company under Artistic Milliners. The new entity will seek to operate a global platform spanning both hemispheres and will be comprised of a combination of selected assets from each organization. Cone Denim will also now operate mills in Mexico, China, and the US. “We were excited to work with Artistic Milliners on this strategic matter, showcasing the breadth of our cross-border experience,” said deal lead Michael J. McGuinness, US-LatAm Practice Group Regional Co-Leader, Corporate M&A and Private Equity. “It’s not just the firm’s global reach, but it's cohesive service, that helps clients navigate complex deals with clarity.” "Working with DLA Piper has provided us with a comprehensive global perspective,” said Murtaza Ahmed, CEO of Artistic Milliners. “The firm's ability to integrate insights across multiple jurisdictions exemplifies the level of collaboration we seek as we expand our international operations.” In addition to McGuinness (New York), Of Counsel Violeta Libergott (US/Brazil) co-led DLA Piper’s cross-border and multi-practice team across the US, United Arab Emirates (UAE), China, and Mexico. The team also consisted of Partners Nick Klein, Elyssa Kutner, Brian Janovitz, Larissa Bifano, Amadeu Ribeiro (all US), Therese Abou-Zeid (UAE), Jorge Benejam (Mexico); Partner Tina Xia and Senior Legal and Tax Manager Peter Chen (both China); Head of Sovereign and LP Investment, MENA, Kurt Alfrey (UAE); Of Counsel Andy Eklund (US); Associates Regina Esparza (Mexico), Regine Lewis, and Michael Haggerson, and Syeda Kamal (all US). With more than 1,000 corporate lawyers globally, DLA Piper helps clients execute complex transactions seamlessly while supporting clients across all stages of development. The firm has been rated number one in global M&A volume for 15 consecutive years, according to Mergermarket, and ranked as number one in VC, PE and M&A in combined global deal volume according to PitchBook.