Corruption in North America: Canada, US, Mexico

Last Updated: July 2026

Overview

Three countries share a continent, a trade agreement and a set of anti-corruption treaty obligations, and they score 75, 64 and 27 on the same index. Transparency International put Canada at 75, the United States at 64 and Mexico at 27 on the 2025 corruption index, with the American score its lowest ever recorded and the country ranked 29th globally.

The interesting thing is not the ranking gap, which has been roughly stable for years. It is that each country’s problem takes a different form. Canada has strong rules and almost no foreign bribery prosecutions. The United States has the world’s most developed enforcement machinery and is narrowing it from two directions at once. Mexico has scandals reaching admirals and cabinet-adjacent figures, and has just rebuilt its judiciary through elections that the government called an anti-corruption measure and critics called the opposite.

This page describes the landscape and does not take a side. It is a maintained reference, revised as laws and circumstances change.

The Competing Frames

Legal integrity and prosecution. The frame that treats corruption as a crime problem solved by investigators, prosecutors and deterrent sentences. It is the organizing assumption of the Foreign Corrupt Practices Act, of Canada’s foreign bribery statute, and of the treaty architecture all three countries have signed. Its measure of success is cases brought and penalties imposed, which is also its weakness: a country can produce few cases because there is little corruption or because nobody is looking.

Overcriminalization and prosecutorial discretion. The counter-frame, held seriously by defence lawyers, federalism scholars and a majority of the current United States Supreme Court. It holds that federal corruption statutes are written so vaguely that ordinary politics, constituent service and post-hoc gifts can be recast as felonies, and that this hands prosecutors the power to choose targets. Critics respond that the practical effect of each narrowing decision is to legalize conduct most people would call bribery. Both descriptions of the same rulings are accurate, which is why the argument does not resolve.

Capture and elite impunity. Used across the political spectrum in all three countries, though about different targets. It holds that the formal rules are fine and the people who write and enforce them are the problem, whether through lobbying access, revolving doors, party financing or personal enrichment in office. It is the dominant popular frame and the hardest to test, since it describes influence that is often lawful.

Corruption as a security problem. Central in Mexico and increasingly present in United States border and customs enforcement. Where organized crime can buy customs officials, port authorities and naval officers, corruption is not a fiscal leak but the mechanism through which criminal groups operate. This frame implies different remedies from the others, closer to counterintelligence than to audit.

Measurement scepticism. Worth naming because the numbers do so much work in this debate. The corruption index measures the perceptions of business people and country experts, not corruption itself, and Transparency International says so. A falling American score partly reflects observed institutional change and partly reflects how the country is being talked about, and separating those is not possible from the index alone.

The Policy Spectrum

All three countries have ratified the United Nations Convention against Corruption and the OECD Anti-Bribery Convention, and all three are bound by the anti-corruption chapter of their trade agreement. Chapter 27 of the agreement requires each party to criminalize bribery, enforce those measures effectively, promote official integrity and involve the private sector. It also preserves each party’s right to exercise enforcement discretion and to allocate its own resources, which is the clause that makes the chapter largely unenforceable against a government that chooses not to act.

Criminal enforcement led by a national prosecutor. The United States model, with the Department of Justice and the Securities and Exchange Commission bringing domestic and foreign bribery cases, supported by whistleblower incentives and corporate settlements.

Administrative ethics regulation. Canada’s emphasis, running through a conflict of interest and ethics commissioner, a lobbying commissioner and the auditor general. These bodies investigate and report publicly, and they cannot prosecute. Sanctions are political and reputational rather than criminal.

Constitutional anti-corruption architecture. Mexico’s approach since 2016, building a National Anti-Corruption System linking audit, prosecution and administrative tribunals. The design is comprehensive on paper and has been criticized from all sides for under-resourcing and for a specialized anti-corruption prosecutor’s office that has produced few high-level convictions.

Subnational enforcement. Increasingly important in the United States as federal statutes narrow, with state attorneys general and state bribery laws picking up conduct federal law no longer clearly reaches.

The gap between architecture and outcome runs in both directions here. Canada’s rules are strong and its foreign bribery record is thin. Mexico’s system is elaborate and its high-level conviction rate is low. The United States has produced more corruption prosecutions than the rest of the world combined and has a falling score.

The Regional Map

Canada. Scores highest of the three and has the weakest foreign bribery enforcement in the G7 by most measures. The OECD Working Group on Bribery has called Canadian action exceedingly low, noting that charges have been laid in roughly nine cases since the foreign bribery act came into force in 1999, with two individuals convicted and four companies sanctioned. Domestically, the pattern is investigation without prosecution: the SNC-Lavalin affair produced an ethics commissioner finding that the prime minister had breached the Conflict of Interest Act, and the ArriveCAN contracting failures produced an auditor general report and parliamentary hearings. Neither produced criminal liability for officials.

United States. Two simultaneous narrowings define the current period. The Supreme Court has spent fifteen years reducing the reach of federal corruption statutes, most recently holding in Snyder v. United States that the main federal bribery provision covering state and local officials does not criminalize gratuities paid after an official act. That followed decisions tightening the definition of an official act and limiting honest services fraud. Separately, the executive branch paused foreign bribery enforcement by executive order in February 2025, pending a review of guidelines.

Mexico. The most serious active scandal in the region involves fuel imported under false tariff classifications to evade duty, a practice known as huachicol fiscal. Investigators and journalists have traced dozens of shipments and hundreds of millions of litres, and arrests have reached serving naval officers including two admirals. Analysis of the contraband fuel trade puts the sums involved in the hundreds of millions of dollars. The Sheinbaum government has pursued the cases publicly, including against United States companies, and supporters treat that as evidence the system works while critics note the scheme ran for years inside the armed forces the previous administration had empowered.

Mexico’s judiciary. A separate development with direct anti-corruption consequences. In June 2025 the country held the world’s first nationwide election of all judges, filling around 2,600 positions including the Supreme Court. Turnout was about 13 percent. The governing party presented the reform as removing a corrupt and unaccountable judiciary; opponents argued it delivers judicial appointments to whoever controls electoral mobilization, and pointed to candidates with criminal or cartel-adjacent histories. Which reading is correct will be visible in how courts handle cases against powerful defendants over the next several years.

The cross-border dimension. Corruption in North America is frequently transnational rather than national. Fuel smuggling requires customs officials on both sides of a border. Drug trafficking revenue moves through American and Canadian financial institutions. Foreign bribery statutes in all three countries reach conduct abroad. This is the strongest argument for treating the region as one system rather than three, and it is the argument the trade agreement’s anti-corruption chapter was written to reflect.

Recent Changes

American foreign bribery policy shifted twice within a year. The February 2025 executive order paused new investigations and ordered a review; in June 2025 the Department of Justice issued revised enforcement guidelines directing prosecutors to focus on conduct that undermines United States interests and on cartel and transnational criminal organization cases. Enforcement resumed on narrower and more explicitly policy-driven terms. Because American enforcement has historically supplied a large share of global foreign bribery cases, the change matters well beyond the region.

Mexico’s changes have been institutional rather than prosecutorial. The judicial election restructured the third branch in a single day, and the huachicol investigations have reached higher into the security apparatus than any recent corruption case. Whether either produces convictions of senior figures is the open question.

Canada has changed least. Foreign bribery enforcement remains low, with a conviction recorded in late 2024 breaking a long gap, and the domestic accountability system continues to run through commissioners and auditors rather than courts. Foreign interference has become the more politically salient integrity question, following a public inquiry that reported in January 2025.

Across all three, the trend line on perception is downward. The global index average itself fell in 2025 for the first time in over a decade, so the North American decline is not purely regional.

Active Debates

United States. Whether the narrowing of federal statutes is corrected by Congress or absorbed by state law. Bills to reverse the gratuities holding have been introduced without passing, and state legislatures have moved faster than the federal one. The separate question, whether foreign bribery enforcement tied to stated policy priorities is enforcement or industrial policy, is contested by practitioners rather than settled.

Canada. Whether to give the foreign bribery regime enforcement capacity comparable to its statutory ambition. Proposals include dedicated police resources, expanded deferred prosecution use, and beneficial ownership transparency, and none has moved quickly. The domestic question is whether an ethics regime without prosecution powers deters anything.

Mexico. Whether the huachicol prosecutions reach the political level or stop at uniformed officers, and whether an elected judiciary is willing to convict senior figures. These are the same question asked twice.

Trilateral. The trade agreement is subject to a joint review process, and anti-corruption obligations are one of several chapters that could be reopened. Chapter 27 has never been the subject of a dispute settlement claim, and whether it can be given teeth without removing the enforcement discretion clause is the design problem.

Measurement. Whether perception indices can capture what is happening in a country whose institutions are changing quickly. Both those who cite the American decline and those who dismiss it are relying on the same limited instrument.

This is a maintained reference page, last updated July 2026. It is revised as laws and circumstances change. Major developments are covered as dated posts in the News section and linked from here.

Discussion Questions

Would you be able to name a corruption case in your own country from the last five years?
Canada scores well and prosecutes almost no foreign bribery. Does a low number of cases mean less corruption or less looking?
The US Supreme Court says vague corruption laws let prosecutors pick targets. Is that a fair concern?
Accepting a payment after doing a favour is no longer a federal crime in the US for state and local officials. Should it be?
Mexico elected all its judges at once and about 13 percent of voters took part. What does that turnout tell you?
Is an ethics commissioner who can investigate but not prosecute worth having?
Imagine you are a customs officer offered a year’s salary to look away from one shipment. What would actually stop you?
All three countries signed the same treaty chapter and enforce it very differently. What would make a treaty like that bite?
The corruption index measures what experts perceive, not what happens. Should governments respond to it at all?
Which is worse for a country: bribery that is illegal and common, or influence that is legal and routine?

Corruption in North America: One Treaty, Three Very Different Failure Modes