2025 Corruption Perceptions Index: Key points for Latin American operations

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:

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

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