Tomás Enrique Carrillo-Batalla Lucas – GC Powerlist
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Mexico Rising Stars 2025

Financials

Tomás Enrique Carrillo-Batalla Lucas

Senior vice president legal and ethics | Banco Nacional de México (Banamex)

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Mexico Rising Stars 2025

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Tomás Enrique Carrillo-Batalla Lucas

Senior vice president legal and ethics | Banco Nacional de México (Banamex)

How do you approach managing legal aspects during periods of instability or crises, and how does your legal strategy align with the broader business strategy to ensure the organisation’s resilience?
I approach instability by reinforcing ethics and integrity in the organisation’s decision-making process. As Banamex separates from Citi, I have led the establishment of Banamex’s first independent Ethics Office, ensuring that legal, ethical, and reputational risks are managed proactively and not through reactive controls. Our legal strategy is aligned with our business priorities, focusing on transparency, accountability, and sustainability, which all strengthen resilience and our clients’ trust. By embedding ethical behaviour and considerations into every decision, we protect our values and growth.

What are the major cases or transactions you have been involved in recently?
A key legal milestone has been the adaptation of Citi’s Global Code of Conduct and Whistleblowing system to Banamex following the separation process. This has required building a professional local team and conducting detailed legal analysis of Mexican regulatory obligations while preserving the integrity and core ethical principles of Citi standards.

This project has involved aligning with Citi policies and processes for ongoing investigations while also identifying local legal challenges and harmonising them with international best practices, ensuring that due process protections are fully aligned with Mexican laws and regulatory obligations. This has provided business continuity alongside a strong and sustained model designed for resilience and institutional credibility.

How do you prioritise diversity and inclusion within your legal department, and what initiatives have you implemented to foster a more inclusive and equitable work environment?
Our Code of Conduct includes anti-discrimination and equal opportunity principles that are embedded in our culture. We have transparent procedures to prevent conflicts or bias in investigations and evaluations. All our training programmes focus on awareness and the implications of discriminatory conduct under the law. Cultural reinforcement and normative clarity have ensured that inclusion is both a requirement and an expectation in our conduct across the institution.

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