by Juan Manuel González | Jul 20, 2023 | Noticias-en
Joint report of the ESG and Capital Markets departments | ISSB Issues Inaugural Global Sustainability Disclosure Standards
On June 26, the International Sustainability Standards Board (ISSB) issued its inaugural standards , IFRS S1 and IFRS S2 , ushering in a new era of sustainability-related disclosures in the capital markets around the world.
IFRS S1 provides a set of disclosure requirements designed to enable companies to communicate to investors the sustainability-related risks and opportunities they face in the short, medium and long term. IFRS S2 sets out specific disclosures related to weather and is designed to be used with IFRS S1. These ISSB standards are designed to ensure that companies provide sustainability-related information along with financial statements, in the same reporting package.
With the issuance of IFRS S1 and IFRS S2, the ISSB will work with jurisdictions and companies to support their adoption. The first steps will be the creation of a Transition Implementation Group to support companies applying the Standards and the launch of capacity building initiatives to support effective implementation.
The ISSB will also continue to work with jurisdictions that wish to require incremental disclosures beyond the global baseline and with GRI to support efficient and effective reporting when the ISSB standards are applied in combination with other reporting standards.
A. IFRS S1: General requirements for the disclosure of financial information related to sustainability
Its objective is to require entities to disclose all risks and opportunities related to sustainability that could reasonably be expected to affect the entity’s cash flows or its access to financing, which are useful to users of general purpose financial reports when when making decisions related to providing resources to entities.
Unless otherwise permitted or required by another IFRS sustainability disclosure standard, entities must make statements about:
— Governance : the processes, controls and procedures that the entity uses to monitor risks and opportunities related to sustainability.
— Strategy : the approach the entity uses to manage the risks and opportunities related to sustainability.
> Business model and value chain
> Strategy and decision-making
> Financial situation and performance, cash flows
> Resilience
— Risk management : the processes the entity uses to identify, assess, prioritize and monitor risks and opportunities related to sustainability.
— Measures and objectives : the performance of the entity in relation to the risks and opportunities related to sustainability, including progress towards any objectives that the entity has established or is required by legal regulation.
General requirements :
to. Guidance sources :
Yo. Identify risks and opportunities related to sustainability.
ii. Identify applicable disclosure requirements.
iii. Disclosure of information about sources of guidance.
b. Location of information (disclosure) : Entities are required to make the disclosures required by the IFRS Sustainability Disclosure Standards as part of their general purpose sustainability reporting.
c. Reporting schedule : Financial statements and financial information related to sustainability must be submitted on time.
Yo. Typically, an entity prepares sustainability-related financial disclosures for a period of 12 months. However, for practical reasons, some entities prefer to report, for example, over a period of 52 weeks. This rule does not preclude that practice.
ii. This standard does not require which entities would be required to provide sustainability-related interim financial disclosures, how often, or how soon after the end of an interim period.
d. Corporate information : The entity will disclose comparative information with respect to the prior period for all amounts disclosed in the reporting period.
and. Compliance Statement :
Yo. This standard exempts an entity from disclosing information required by an IFRS Sustainability Disclosure standard if law or regulation prohibits the entity from disclosing that information.
ii. It also exempts an entity from disclosing information about a sustainability-related opportunity required by an IFRS Sustainability Disclosure standard if that information is commercially sensitive as described in this standard.
Source: IFRS – IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information
B. IFRSS2: Weather related disclosures
Its objective is to require entities to disclose all risks and opportunities related to climate change that could reasonably be expected to affect the entity’s cash flows or its access to financing, which are useful to users of general purpose financial reports. when making decisions related to providing resources to entities.
Scope:
to. Climatic risks to which the entity is exposed :
Yo. Physical risks, and
ii. Transition risks.
b. Climate-related opportunities available to the entity.
— Governance :
> The governance body for oversight of climate-related risks and opportunities. Specifically, the entity will identify that agency or individual and disclose the information.
> The role of management in the governance processes, controls and procedures used to monitor, manage and supervise climate-related risks and opportunities.
— Strategy : Enable users of general purpose financial reports to understand an entity’s strategy for managing weather-related risks and opportunities.
> Business model and value chain
> Strategy and decision-making
> Financial situation and performance, cash flows
> Climate resilience
— Risk management : Enable users of general purpose financial reports to understand an entity’s processes for identifying, assessing, prioritizing, and monitoring weather-related risks and opportunities, including whether those processes are integrated with and inform the overall risk management process. risk management of the entity and how.
— Measures and objectives :
— Measurements
to. Greenhouse Gases (GHG) :
Yo. Disclose your gross absolute greenhouse gas emissions generated during the reporting period, expressed in metric tons of CO 2 equivalent , classified as:
> Scope 1 Greenhouse gas emissions;
> Scope 2 Greenhouse gas emissions;
> Scope 3 Greenhouse gas emissions.
ii. Measure your greenhouse gas emissions in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004).
iii. Disclose the approach it uses to measure its greenhouse gas emissions, including:
1. The measurement approach, inputs and assumptions the entity uses to measure its greenhouse gas emissions;
2. The reason why the entity has chosen the measurement approach; and
3. Any changes the entity has made in the measurement method and the reasons for those changes.
b. Climate-related transition risks .
c. Weather-related physical hazards .
d. Climate-related opportunities .
and. Deployment of capital .
F. Internal carbon prices .
g. Compensation :
> Whether and how climate-related considerations are factored into executive compensation.
> the percentage of executive management compensation recognized in the current period that is linked to climate-related considerations.
— Objectives :
to. The metric used to set the goal;
b. goal objective;
c. Part of the entity to which the goal applies;
d. Period during which the goal applies;
and. Base period from which progress is measured;
F. intermediate goals;
g. Absolute or intensity target; and
h. How the most recent international treaty has informed the target.
Source: IFRS – IFRS S2 Climate-related Disclosures
For more information contact:
Gustavo Papeschi | Partner de Beccar Varela | gpapeschi@beccarvarela.com
by Juan Manuel González | Jul 19, 2023 | Noticias-en
The Financial Crimes Enforcement Network (FinCEN) recently announced its first enforcement action against a trust company for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. The BSA imposes compliance and reporting obligations on “financial institutions,” which includes among other entities, any “commercial bank or trust company,” to help detect and prevent money laundering. And yet, until last month, FinCEN had not brought an enforcement action against a trust company.
Background
On April 2023, FinCEN announced a $1.5 million civil penalty against the Kingdom Trust Company (Kingdom Trust or the Company) for willful violations of the BSA stemming from the Company’s failure to have sufficient controls around filing Suspicious Activity Reports (SARs).
According to the Consent Order, Kingdom Trust is a trust company organized under South Dakota law that operates the majority of its trust services business out of Kentucky. Though its primary offering is custody services to individuals with self-directed IRAs, during the relevant time period, Kingdom Trust also provided account and payment services to foreign securities and investment firms and money services businesses in high-risk circumstances. Specifically, in 2014, Kingdom Trust began a business relationship with a consulting group that worked with broker-dealers in Argentina and Uruguay that had difficulty establishing bank accounts in the United States. Through this business relationship, Kingdom Trust provided accounts to the foreign firms to custody fixed income securities and to hold cash. As a result, Kingdom Trust processed more than $4 billion in transactions.
Among the other shortcomings identified, FinCEN characterized Kingdom Trust’s process for identifying and reporting potential suspicious transactions as “severely underdeveloped and ad hoc.” According to the Consent Order, prior to December 2018, the Company had no standalone process to screen for, identify, and report suspicious transactions. Rather, staff were instructed to simply flag potentially suspicious activity identified in the ordinary course of performing their duties. After December 2018, Kingdom Trust created a process to identify potentially suspicious activity but relied upon a single compliance employee with no prior anti-money laundering (AML) or BSA experience to conduct a daily review of a large volume of transactions. The daily transaction review did not include relevant contextual information about the customer or counterparty beyond their name. In 2020, Kingdom Trust hired a compliance analyst with AML experience. However, given the manual nature of the review process among other shortcomings, the Company filed only four SARs between February 2020 and March 2021.
In addition, Kingdom Trust maintained correspondent bank accounts for customers at other financial institutions – and at least 11 of those other financial institutions closed the accounts maintained by Kingdom Trust. In response, Kingdom Trust management questioned whether to continue with the foreign custody business and engaged a third party to conduct a BSA/AML audit. The audit identified deficiencies related to Kingdom Trust’s high-risk customers, but the Company did not exit the high-risk customer relationship, make meaningful changes to its controls, or file SARs.
Five Key Takeaways
- Heightened Scrutiny of U.S.-based Trust Companies by FinCEN: In a press release accompanying the enforcement action, FinCEN’s Acting Director, Himamauli Das underscored that the instant matter “is an important statement that we will not tolerate trust companies with weak compliance programs that fail to identify and report suspicious activities, particularly with respect to high-risk customers whose businesses pose an elevated risk of money laundering.” It is still too early to know whether the enforcement action against Kingdom Trust signals that FinCEN will more actively investigate and initiate actions against U.S. trust companies, and many of the services offered by Kingdom Trust are similar to those offered by traditional banks (i.e., providing accounts to foreign brokerage firms to custody fixed income securities, including U.S. government bonds, and to hold cash). Nevertheless, in light of FinCEN’s Consent Order and public statements, all trust companies (including those that provide only administrative trust services) should consider whether its AML program is sufficient to address the level of risk that accompanies the services it offers. This includes private trust companies without a federal functional regulator (i.e., an oversight agency such as the Office of the Comptroller of the Currency (OCC) or the U.S. Securities and Exchange Commission (SEC)), which, as of March 2021, are no longer exempt from certain BSA requirements.
- Compliance Resources Must Track an Evolving Risk Profile: According to the Consent Order, even after Kingdom Trust expanded into a new line of business offering services to customers that involved heightened risks of money laundering, the Company failed to recruit sufficient personnel with AML compliance experience and relied on manual processes to monitor thousands of transactions daily. As a company’s risk profile grows (whether because of new service/product offerings, new market entry, or otherwise), it is critical that the resources dedicated to complying with BSA requirements track the heightened risk profile. For example, most entities subjected to the BSA’s requirements find that implementing automated transaction monitoring software to flag suspicious behavior and to monitor daily cash flows for potential signs of illegal activity is far more efficient and effective than manual reviews. Furthermore, if all transaction-facing employees (not just the compliance team) are trained to spot red flags of money laundering and other atypical transactions, there is a higher likelihood that the institution will identify and timely report suspicious activity. This is particularly important in companies with a limited number of compliance team members.
- Check-the-Box Compliance Activities are Not Sufficient: FinCEN acknowledged that Kingdom Trust undertook certain AML efforts but highlighted significant shortcomings. The Consent Order indicated that Kingdom Trust provided AML training, but noted that training presentations were not tailored to the Company’s risk mitigation activities. For example, training presentations included red flags – such as “customer requests for anonymity, customer attempts to open an account without identification, and an account opened with a nominal balance that subsequently increased rapidly and significantly” – that employees could not have identified based on a review of the daily transaction reports alone. The order also notes that after financial institutions began closing correspondent accounts that Kingdom Trust maintained, Kingdom Trust engaged a third party to conduct a BSA/AML audit. The audit identified deficiencies related to Kingdom Trust’s high-risk customers and their transactions. However, according to FinCEN, Kingdom Trust did not exit relationships with high-risk customers, failed to make “meaningful changes” to its controls, and failed to file any SARs related to the high-risk business line. These examples serve as an important reminder that firms covered by the BSA’s requirements should engage in compliance-related activities that not only “check the box” but that drive firms and their personnel to actually mitigate risks posed.
- The Role of Cooperation: Kingdom Trust did not voluntarily disclose the violations, but the order reveals that the company “provided substantial cooperation to FinCEN” and cooperated with federal law enforcement regarding certain of the Company’s high-risk customers. However, the BSA’s SAR reporting obligations serve as proactive, ex ante cooperation, and the order makes clear that post-investigation cooperation cannot make up for failing to meet such preemptive obligations.
- Hiring of an Independent Consultant: In addition to agreeing to pay a $1.5 million civil penalty, Kingdom Trust undertook to hire an independent consultant, subject to FinCEN’s approval, (1) to conduct a SAR Lookback Review related to certain of the Company’s transactions; and (2) to test the effectiveness of Kingdom Trust’s AML program though an AML Program Review and to provide recommendations for enhancements. The independent consultant must submit written reports of the activities to FinCEN. The requirement to hire an independent consultant, like other forms of corporate monitorships, can be costly and create administrative burdens. Companies can seek to avoid such requirements by taking proactive measures to assess the effectiveness of its AML program, rather than waiting for enforcement authorities to mandate such assessments.
For more information contact:
Jeffrey Lehtman | Parner Miller & Chevalier | jlehtman@milchev.com
by Juan Manuel González | Jul 18, 2023 | Noticias-en
Law 31814 was recently published in Peru, which promotes the use of artificial intelligence in favor of the economic and social development of the country (the “Law”), within the framework of the national process of digital transformation.
The Law sets forth the principles that should guide the actions of the State in promoting the use of artificial intelligence, and the participation of the private sector in this activity. Some of these principles are: Risk-based security standards, Multi-stakeholder approach, Internet Governance, Digital Society, Artificial Intelligence Privacy, etc.
Likewise, the Secretariat of Government and Digital Transformation of the Presidency of the Council of Ministers is appointed as the technical-regulatory authority responsible for directing, evaluating and supervising the use and promotion of the development of artificial intelligence and emerging technologies. Said secretariat will have the obligation to submit an annual report to Congress on the progress in the implementation of the National Digital Transformation Policy and the National Artificial Intelligence Strategy, and to immediately inform the Intelligence Commission of Congress, in the event that threats are identified. serious or breach of national cybersecurity.
Finally, the Law establishes a period of 90 business days for the Executive Branch to approve the corresponding Regulation.
Access the Law here: https://bit.ly/3pyPe9J
For more information contact:
Mario Pinatte | CPB Partner | mpinatte@cpb-abogados.com.pe
by Juan Manuel González | Jul 11, 2023 | Noticias-en
The Investigative Authority of the Federal Economic Competition Commission (“COFECE”) published on July 3, 2023 the notice of initiation of an investigation for a complaint for the possible performance of related monopolistic practices with file number DE-023-2023, in the market for the development, marketing and sale of digital goods and/or services, as well as related services in the national territory.
In this regard, COFECE noted that this investigation focuses on products such as electronic books, software, video games, photographs, music, and online movies, among others. These digital goods and services are created by developers and marketed to end users through various channels. In addition, COFECE indicated that it will analyze the negotiation and payment processing mechanisms associated with these transactions. In this regard, he pointed out that, in 2021, video game sales in the country increased by 24% compared to the previous year, while digital book sales grew by 35% and digital photo and video sales by 19%.
In this investigation, COFECE may request information in writing, carry out verification visits, as well as summon economic agents that participate in or are related to said market to testify. Pursuant to the Federal Law on Economic Competition (“LFCE”), there is an obligation for economic agents that are requested and visited to cooperate and submit the information requested to COFECE.
The purpose of publishing said investigation is to provide any economic agent with an interest in it, the opportunity to contribute and express what is appropriate to their right in relation to the investigated conduct or circumstances that may be contrary to the LFCE. Therefore, any person or company that considers that it has an affectation in the investigated market will have the opportunity to manifest it before COFECE.
For more information contact:
Juan José López de Silanes | Partner Basham, Ringe and Correa | lopez_de_silanes@basham.com.mx
by Juan Manuel González | Jul 5, 2023 | Noticias-en
At present, respect for human rights in business has become an issue of increasing importance throughout the world and is already part of the central core of business activity that must be aligned with principles of environmental, social and governance standards. (IS G). Regulatory compliance plays a critical role in protecting human rights and promoting ethical business practices. This article focuses on analyzing the relevance of compliance in Latin America and the United States and its relationship with Human Rights.
Regulatory compliance in companies not only refers to compliance with laws and regulations, but also to respect for and promotion of Human Rights. Companies have a responsibility to carry out due diligence to ensure that their operations do not contribute to violations of fundamental rights, both within their own facilities and in their supply chain. This implies adopting measures to prevent and address cases of discrimination, forced labor and child exploitation, among others.
In Latin America, the relationship between compliance and human rights presents particular challenges. The region is characterized by the presence of industrial sectors that present greater risks both related to corruption and Human Rights. These risks exist in the extractive industries, which include mining and oil, and which are often associated with negative impacts on local communities and the environment or agriculture that features a greater presence of informal or child labor. In this context, Compliance plays a crucial role in ensuring that companies comply with environmental and social regulations, and respect the rights of neighboring communities, in response to the multiple considerations that have been adopted internationally by various countries.
There are certain factors that have contributed to the increase in importance of this topic. Several Latin American countries have enacted stricter laws and regulations to promote regulatory compliance with positive impacts on the promotion and respect of Human Rights, for example, in defense of the environment, decent wages and the protection of children. In this same context, civil society and non-governmental organizations have contributed to the surveillance and denunciation of irresponsible business practices, thus focusing on a greater commitment to Human Rights.
“In Chile, the promotion of Human Rights in the business context has been reinforced with regard to the work that different industries have carried out to achieve international compliance. This has not only meant an ethical commitment to the promotion of Human Rights, but also an improvement in the reputation and sustainability of companies”, explains Jaime Viveros, associate of the firm AZ de Chile.
Aligned with these trends, more and more countries have converted into law the United Nations Guiding Principles on Business and Human Rights, due diligence in the field of human rights (DDHR) and hold companies accountable for infringing human rights with their activity. abroad. In this context, one can mention France with its “loi sur le devoir de vigilance” or Germany with its recent law on due diligence in the value chain “LkSG”. The European Union, in turn, has its project for a Directive on due diligence of companies in terms of sustainability, which will unify the standards of all member countries in terms of human rights and the environment and will globally require suppliers of European companies, including those from Latin America and the US, to comply with the new legal requirements.
In the United States, Human Rights compliance has gained prominence in recent years, promoting its application in other jurisdictions. Indeed, the Law for the Protection of Human Rights Abroad and the Supply Chain Transparency Law require companies to report on their measures to prevent human trafficking and forced labor. Another important Law on import restriction is the Uighur Forced Labor Prevention Act (UFLPA), which has been in force since 2022 and prohibits the importation of goods extracted, produced, manufactured in whole or in part in the People’s Republic of China, especially in the Xinjiang Autonomous Region or by any other entity within the UFLPA List.
However, there are challenges in the effective implementation of these laws and in the supervision of business practices, since globalization and the complexity of supply chains make it difficult to identify and eradicate practices that violate Human Rights. In this regard, it is essential to strengthen compliance mechanisms and promote collaboration between the private sector, government, and civil society to address these challenges.
From a business perspective, while Human Rights due diligence has many similarities to traditional due diligence in business compliance programs, there are some important differences to consider. The main differences are: (i) the need to analyze the risks from the perspective of the rights holders (eg, the people affected by the negative impacts) and not only from the perspective of the company’s risks; and (ii) placing greater emphasis on stakeholder engagement and transparency, with the expectation that the company should share information with a broader range of stakeholders (eg, employees, community members), should seek their feedback. and reactions and publicly report the efforts made.
Regulatory compliance and the protection of Human Rights are interdependent aspects that must be addressed jointly in Latin America, the United States and throughout the world. Only through a comprehensive and committed approach can we ensure that companies act ethically, respect and promote with integrity the fundamental guarantees of people in all their business activities.
by Juan Manuel González | Jun 30, 2023 | Noticias-en
On June 8, 2023, the long-awaited Official Mexican Standard NOM-037-STPS-2023 was published in the Official Gazette of the Federation. Teleworking – Safety and health conditions in teleworking, after an analysis of the labor and business sectors to the project that was originally published on July 15, 2022. The creation of this Official Mexican Standard is the result of compliance with the reform that added Chapter XII Bis of the Federal Labor Law, in matters of Teleworking, in the month of January 2021, where it granted the Federal Executive Power a period of eighteen (18) months to publish a regulation that reflected the provisions, obligations and guidelines on health and safety in the provision of services under the teleworking modality.
The Standard contemplates the following points:
General considerations.
It distinguishes between the workplace, where the activities are carried out in person, and the workplace, which is different from the workplace, where the teleworking worker carries out their activities.
Obligations of the employer.
Have an updated list of workers under the teleworking modality, which reflects name, gender, marital status, name and job profile, activities to be carried out, time (in percentage) under the teleworking modality, contact telephone number , address, the place or places agreed for the provision of remote services, reason and address of the workplace and a list of computer and ergonomic equipment granted to the worker.
Ensure that the workplaces in which the services are carried out under the teleworking modality meet specific conditions, such as having connectivity, complying with safety and health conditions at work (good condition of electrical installations, lighting, ventilation and ergonomic conditions), and the employer can carry out a physical or virtual verification of the referred place, through its Safety and Hygiene Commission.
Establish and implement a Teleworking Policy with a gender perspective, which includes rest time for working women who are breastfeeding.
Have the validation of the “Verification list of health and safety conditions in teleworking”, either through a visit or through a questionnaire that is given to the worker that allows determining whether or not they have the conditions necessary for the development of remote work. These visits may be carried out by the Safety and Hygiene Commission, with the consent of the worker.
Establish in writing the procedure to migrate from face-to-face to teleworking.
Provide ergonomic chairs and other supplies and accessories necessary for the performance of their tasks.
Create and document programs regarding how to provide maintenance to electronic equipment delivered to teleworkers.
Provide training to teleworkers on health and safety conditions that they must maintain in their remote workplace, at least once a year.
Guarantee reversibility to the face-to-face scheme, when justified, or because it suits their interests.
Carry out the medical examinations that correspond to workers in accordance with NOM-030-STPS-2009 (Preventive services for safety and health at work-Functions and activities), and follow up on notices of work accidents.
Have care mechanisms for cases of family violence, which include the return to face-to-face modality.
Guarantee the confidentiality of the lists of people who are under the teleworking modality.
Provide support and facilities for teleworking workers to participate in the Safety and Hygiene Commission or in the Mixed Training, Training and Productivity Commission.
Include union rights and provisions of the applicable collective agreement in the Teleworking Policy.
Obligations of workers under the teleworking modality.
Provide the Safety and Hygiene Commission with the necessary facilities to check the health and safety conditions in their workplace, for the first time, and then with the established periodicity.
Comply with the Teleworking Policy.
Inform the employer of any alteration that, in terms of safety and health at work, prevent the development of their activities in the place agreed by the parties. The basic elements of the temporary change of workplace document are: date of preparation, name of the worker, and description of the change of address.
Safeguard and keep in good condition the electronic equipment, materials, tools and ergonomic material delivered by the employer.
Comply with the provisions on occupational health and safety, and submit to medical examinations, in accordance with NOM-030-STPS-2009 (Preventive occupational health and safety services-Functions and activities).
Comply with the policies and mechanisms for the protection of data and information, the restrictions on use and storage, established by the employer.
Inform the employer in writing regarding any change of temporary or permanent address from where they carry out their remote activities.
Participate in the information and training processes on the risks related to Teleworking.
Notify the employer and the Safety and Hygiene Commission of the work risks suffered.
Safety and Health Conditions at Work / Training and Instruction.
The Standard establishes the occupational health and safety conditions that the parties must comply with in order to avoid work risks caused by physical agents, ergonomic risk and psychosocial risk factors, as well as the terms and conditions under which training and training for workers under the teleworking modality.
Verification of Health and Safety Conditions.
Employers may contract evaluation agencies in charge of inspecting health and safety conditions -without them visiting the workplace-, called “Inspection Units”, which must have accreditation and approval for this. For this purpose, a “Conformity Assessment Procedure” is established, which will be applicable both for the aforementioned Inspection Units, as well as for inspection visits carried out by the labor authority in the work centers.
The Standard also establishes the type of verification (documentary and/or interview) and the acceptance criteria with which the employer may accredit, through the Safety and Hygiene Commission, due compliance with its obligations regarding safety and health in teleworking and contains various reference guides that the employer can take as a basis for the observance of the corresponding provisions.
In this latest version of the Standard, a preponderant role was given to the Safety and Hygiene Commission, with the aim of being in charge of verifying the conditions in which workers will perform under the teleworking modality, which can be verified through photos or videos.
Another important aspect of the Standard is that it highlights the gender perspective as an element in the implementation of the teleworking modality, establishing special protections for people who may suffer violence in the home and recognizing the rights of lactating women to take breaks.
Based on the foregoing, through this Standard it is intended to encourage the importance of work-family balance, to avoid social isolation and techno-stress (negative psychosocial effects derived from the use of information technologies), as well as the role of employers to prevent risks that could negatively affect the health and life of their workers.
The Standard will enter into force one hundred and eighty (180) calendar days after its publication in the Official Gazette of the Federation, that is, in December of this year 2023.
For more information contact:
Juan José López de Silanes | Partner Basham, Ringe and Correa | lopez_de_silanes@basham.com.mx
