DLA Piper Mexico

The Ministry of Economy in Mexico recently published the Institutional Program 2026–2030 of the Federal Consumer Protection Agency (PROFECO) in the Official Gazette of the Federation. The Program establishes the objectives and strategies that will guide PROFECO's actions over the next five years. In accordance with the Program, PROFECO will intensify its regulatory and oversight activity, directing its resources toward correcting commercial practices that it considers structurally harmful to consumers in Mexico. In practical terms, the Program anticipates a more active regulatory environment with higher compliance expectations for suppliers operating in Mexico – particularly in terms of advertising, e-commerce, adhesion contracts, labeling, product quality, and handling of consumer complaints. Strengthening PROFECO's oversight and sanctioning powers will likely involve increased scrutiny of business practices and internal compliance programs over the next few years. For companies that offer goods or services in the Mexican market, the Program is a reference point for regulatory priorities and expectations in the consumer-protection compliance environment. Companies that do not implement this new regulatory approach could face more frequent verification procedures, harsher penalties, and increased public scrutiny of their business practices. Context and assessment of the problems identified by PROFECO PROFECO identified five structural problems in consumer relations that are directly relevant to suppliers’ operations in Mexico: Misleading advertising and marketing of unsafe or poor-quality products Abusive business practices Informational inconsistencies in contracts and contracting processes Inadequate access to information for responsible consumption Low trust in public institutions Strategic objectives and implications for suppliers The Program is structured around five strategic objectives that have a direct impact on the regulatory obligations and risks of suppliers. Ensure access to clear information on goods, products, services, and consumer rights Action plans for information access include the following: Preparation of quality studies on goods and products Evaluation of goods and products through technical analysis and standardized testing methods Dissemination of information on goods, products, and services that could represent risks to the life, health, or integrity of consumers Identification of misleading advertising in mass media and digital platforms Strengthening of the "Who's Who" programs Promote fair consumer relations by suppliers of goods, services, and products The Program lists the following action steps for promoting fair consumer relations: Review compliance with Official Mexican Standards applicable to labeling and commercial information Execute verification and surveillance actions, especially during high-consumption seasons Disseminate information on the behavior of suppliers through the PROFECO Commercial Bureau Promote responsible fair-trade practices and trade information Supervise compliance with obligations related to commercial promotions Strengthen the imposition and execution of administrative sanctions through the Administrative Enforcement Procedure, in its capacity as a tax authority Strengthen mechanisms for the defense of consumer rights In the Program, PROFECO puts forward the following approaches for defending consumer rights: Strengthening digital mechanisms for dispute resolution Modernizing face-to-face and remote conciliation and arbitration systems Promoting the use of class actions and their legal representation Strengthening the processes for registering, reviewing, and approving adhesion contracts Developing additional protection mechanisms derived from the increase in electronic commerce Implementing special projects related to the use of artificial intelligence (AI) and algorithms in digital platforms Promote a culture of responsible and sustainable consumption Action plans for promoting responsible consumption consider: Dissemination of didactic and informative materials on goods and services through physical and digital media Holding of educational sessions on consumer rights in the Consumer Protection Offices Strengthening of institutional mechanisms for the promotion of responsible consumption, including the Consumer Advisory Council Strengthen the institutional performance of PROFECO Among the main actions planned for PROFECO are: Promoting adjustments to the Federal Consumer Protection Law (LFPC), its regulations, and other applicable provisions – particularly in terms of electronic commerce, AI, and algorithms in commercial platforms Promoting inclusive and accessible care mechanisms for groups in vulnerable situations Strengthening the dissemination of PROFECO's functions and the quality of its advisory, conciliation, arbitration, and opinion processes Regulatory exposure and mitigation for suppliers Against this backdrop, suppliers operating in the Mexican market are encouraged to adopt a proactive compliance approach – aligned not only with applicable legislation, but also with the regulatory specifications and supervisory criteria announced by PROFECO in the Program. In the area of adhesion contracts, the Program anticipates a simplification of registration processes, accompanied by more intensive supervision of existing contracts. The review will likely focus on verifying that the content, language, and structure of such regulatory records are accessible to the average consumer. The systematic monitoring of advertising will be one of the regulatory priorities during the period of validity of the Program. Consequently, suppliers must check that all commercial messages – including those disseminated on social networks and digital platforms – are truthful, verifiable, and do not omit information that could lead to error. Likewise, the strengthening of internal compliance programs in consumer protection will be increasingly relevant, not only for the adequate handling of claims and procedures before PROFECO, but also from a reputational perspective – particularly in the face of the public information available in the Commercial Bureau of the authority. Finally, in terms of product labeling and quality, companies are encouraged to ensure that the commercial information accurately reflects the composition and characteristics of the goods and that they comply with the applicable Official Mexican Standards. How DLA Piper can help DLA Piper’s Mexico-based team has extensive experience in consumer protection; regulatory compliance before PROFECO; defense in conciliation proceedings; arbitration, verification, and infringement of the LFPC; design of trade compliance programs; and strategic advice in the face of evolving regulatory environments. We are available to our clients to analyze their specific exposure to the new Program and strategize mitigation measures adapted to each sector and business model.

DLA Piper advised Grupo Cox (Cox), a leading Spanish multinational water and energy company, on the closing of its US$4.2 billion acquisition of Iberdrola’s Mexico assets and related financing – one of the energy sector’s most significant cross-border transactions of 2025. The deal closed on the terms, timeline, and structure announced to the market last July, when Cox and Iberdrola first signed the agreement. The landmark transaction incorporates a generation platform with 2,600 MW of installed operating capacity, a pipeline of approximately 12,000 MW of renewable projects at various stages of development, and the largest private power supplier in Mexico, with more than 25 percent market share, 20 TWh of commercialization, and 500-plus large corporate customers. Cox secured bank financing totaling US$2.65 billion for the acquisition, structured as a syndicated facility with seven top-tier financial institutions (Citi, Barclays, BBVA, Deutsche Bank, Goldman Sachs, Scotiabank, and Santander). The tranche not covered by bank financing was supplemented by capital contributed by Cox, together with financing from institutional investors such as Allianz Global Investors, Gramercy, and GMO. The DLA Piper team, co-led by attorneys in the United States and Mexico, supported Cox across all workstreams of the transaction. This included corporate, regulatory, financing, and corporate governance matters, working in close coordination with the international lenders and investors that backed the transaction. "The closing of this acquisition is a milestone for Cox and for the energy sector across the region,” said Francisco J. Cerezo, Chair of the US-Latin America and Ibero-American practices, who co-led the deal team. “It has been a privilege for us to accompany Cox in a transaction of this complexity and scale, combining highly sophisticated regulatory, financial, and cross-border components. We are grateful for the trust placed in us by the Cox team and proud of the result achieved.” “This transaction reaffirms Mexico’s strategic role as a long-term investment destination in the energy and water sectors,” said Mauricio Valdespino, US-Latin America Practice Group Regional Co-Leader – Corporate M&A and Private Equity, who co-led the M&A deal alongside Cerezo. “Supporting Cox in the integration of a platform of this magnitude – fully aligned with the country’s public policy priorities – has been an extraordinary opportunity for our team and reflects the depth of our practice across the region,” said Edgar Romo, US-Latin America Practice Group Regional Co-Leader – Finance, who co-led the financing transaction along with Rob da Silva Ashley, Global Co-Chair of the firm’s Energy and Natural Resources sector. In addition to Cerezo, Ashley (both Miami), Romo, and Valdespino (both Mexico City), the broader cross-border team of more than 75 attorneys included Partners Guillermo Aguayo, Roberto Ríos (both Mexico City), Joseline Rodriguez (Miami), Michael McGuinness, Amadeu Ribeiro, Jamie Knox, and Frank Mugabi (all New York). In Europe, the team was led by Yoko Takagi (Madrid) in collaboration with Richard Normington (London) and Xavier Guzman (Luxembourg). 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. DLA Piper advises on all aspects of financing across borders, sectors, and financial products. The firm’s lawyers advise issuers, underwriters, selling shareholders, sponsors, arrangers, lead managers, originators, dealers, trustees, and depositaries on a broad range of capital markets offerings, including equity, equity-linked and debt securities, structured and project financings, and securitizations. DLA Piper's Latin America 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, the 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. For more information, visit Latin America | DLA Piper.

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  

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.

August 1, 2025 – DLA Piper advised Grupo Cox (Cox), a leading Spanish multinational water and energy company, in its acquisition of Iberdrola’s assets in Mexico for US$4.2 billion – one of the largest cross-border energy deals of the year. “We appreciated the opportunity to work with the Cox team on this landmark acquisition and look forward to advising the company on its future cross-border initiatives,” said Francisco J. Cerezo, Chair of the US-Latin America and Ibero-Américan practices, who co-led the deal team. “I want to express my deep appreciation for the service provided in this transaction by the DLA Piper team, led by Francisco Cerezo and Mauricio Valdespino,” said Antonio Medina Cuadros, Chief Legal Officer and Secretary General of Grupo Cox. “Their professionalism and tireless work ethic went far beyond what one could expect from legal counsel. Without a doubt, their outstanding effort and dedication were among the key factors in the success of this complex transaction.” In addition to Cerezo (Miami), the cross-border DLA Piper team was co-led by Partner Mauricio Valdespino (Mexico City) and included Partners Edgar Romo, Guillermo Aguayo, Roberto Ríos (all Mexico City), Robert da Silva Ashley (Miami), Michael McGuiness, Amadeu Ribeiro, Frank Mugabi (all New York), Yoko Takagi (Madrid), and Senior Associate Joseline Rodriguez (Miami), and Associates Eduardo Gallástegui, Regina Esparza, and Manuel Domínguez (all Mexico City), among a team of more than 40 DLA Piper attorneys. 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. 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.  For more information, visit Latin America | DLA Piper The firm recently received the highest ranking for law firm client service in the BTI Client Service A-Team 2025 report, which identifies law firms providing exceptional service based on client feedback. About DLA Piper DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa, and Asia Pacific, positioning us to help clients with their legal needs around the world. In certain jurisdictions, this information may be considered attorney advertising. dlapiper.com Contact Geneva Youel, Media Relations, DLA Piper, +1 213 330 7779