In summary
This article delves into the latest trends in the Mexican pharmaceutical and healthcare sector from an antitrust perspective. It examines the newly released antitrust proceedings in Mexico through the lens of the upcoming structural changes set forth in the recently approved bill to reform the regulatory framework in force, while shedding light on the most recent cases sanctioned by the Mexican Competition Commission. It also reviews the adjacent legal regime for civil and criminal liability claims against anticompetitive conduct, by exploring the inaugural class action lawsuit recently filed by the competition watchdog. Finally, it considers ongoing antitrust investigations in the healthcare industry, as well as relevant market studies in this sector to assess anticompetitive illegal restraints and barriers to competition. The article concludes with a discussion on the foreseeable trends in this sector by stressing the need to maintain vigilance ahead of the imminent reform.
Discussion points
- Healthcare is one of the most important household monetary expenditures in Mexico.
- Mexico is currently undergoing a series of structural changes. Congress is expected to pass a bill to reform the Federal Competition Act (FCA) in force and create a new competition authority imminently.
- The Commission remains highly vigilant in this sector, particularly regarding cartels. Cartels in the market of drug distribution and public procurement of the National Health System have already been sanctioned.
- Two ongoing investigations in the health industry are still pending resolution.
- Anticompetitive conduct can result in monetary fines and imprisonment, among other sanctions. The recent bill to reform the FCA heightens these sanctions.
- Meanwhile, the Commission has hinted at its intention to strengthen reliance on civil and criminal claims as a deterrence tool to enforce competition policy.
Referenced in this article
- Federal Competition Act
- Mexican Code of Civil Procedure
- Mexican Criminal Code
- Almacén, AstraZeneca, Marzam, Casa Saba, Diprofar, Fanasa, GCS, Iqvia, Nadro & others (docket file IO-001-2016): cartel investigation in the market of drug distribution
- Dicipa, SA de CV & others (docket file DE-011-2016): cartel investigation in the market of public procurement of the National Health System
- Study on free market and competition in the expired-patent drug markets in Mexico (2017), COFECE
In accordance with the most recent National Survey of Household Income and Expenditure released by the Mexican statistics authority, health expenses represent one of the most relevant items of the quarterly average current monetary expenditure per household in Mexico.
Notwithstanding the foregoing, the Mexican Competition Commission (the Commission) has launched just a couple of cartel investigations during the past five years in the pharmaceutical sector. Its few cases in the health industry solely address horizontal restraints, most of them in public health system procurement.
These competition investigations, and their corresponding decisions, have been limited to drug distributors or resellers of clinical laboratory test supplies but have not reached out to any pharmaceutical company or pharmacy.
It is noteworthy that in more than a decade of the Commission’s existence there are no public records of any competition investigation for abuse of dominance in the pharmaceutical sector.
As further discussed below, we do not foresee any change in the immediate future, considering the ongoing and potential investigations in the pipeline.
However, it is important to mention that the competition landscape in Mexico is currently undergoing a series of structural changes. In December 2024, Congress passed a constitutional amendment that transformed the Commission’s legal nature from a constitutionally autonomous body to an agency attached to the Executive Branch. In the first week of July 2025, Congress passed the bill to reform the FCA in force (Reform Bill). As a result, a new competition law will be published in the Official Gazette of the Federation in the next couple of weeks and a new competition authority will be created imminently.
The new authority, as part of the Executive Branch, is expected to align itself with the elected government’s agenda and to address the issues most relevant to Mexican consumers in accordance with the current administration’s priorities. Therefore, it is likely that the new competition authority will reexamine the healthcare and pharmaceutical sector.
In particular, the Reform Bill´s preamble reveals a fundamental interest in addressing the systematic abuses of power and dominant positions. In this regard, the statement of purposes of the Reform Bill reflects a growing interest in the detection and investigation of abuse of dominance, which will no longer be limited to the exclusion or displacement of an economic agent but will henceforth encompass additional scrutiny on the conduct through which market power is exercised.
A view of the most recent cases sanctioned in Mexico
Brief explanation of competition proceedings (anticompetitive conduct and illegal concentration)
In Mexico, the investigation phase constitutes the initial stage of the competition proceedings. It may be prompted by the Commission sua sponte or following a complaint, which may be filed by any interested party.
The investigation is formally launched by an order of the Commission’s Investigative Authority (prosecutor), an extract of which must be published in the Official Gazette of the Federation (and, should the Commission deem convenient, in other media) to encourage cooperation from any interested party in the investigation. However, the order to launch an investigation does not assume or imply the liability of any investigated person.
Under the newly approved Reform Bill, the maximum duration of an investigation was reduced by 20 per cent. Henceforth, the investigation stage has an initial period of no fewer than 30 business days and no more than 120 business days and the Commission may extend such period up to three times for up to 120 business days each. Throughout the investigation stage, the Commission is charged with keeping the proceedings active; failure to take any action within a 60-business day period results in the statutory termination of the investigation.
During this investigative phase, the Commission retains ample powers to perform visits to the premises (dawn raids), instruct any person to answer questionnaires, produce documents and attend depositions. In fact, it is worth mentioning that the Reform Bill establishes significantly higher fines for procedural infringements as an additional countermeasure to enhance enforcement.
On the business day following the expiration of the term afforded by the Federal Competition Act (FCA) for the investigation stage or on the date on which the Investigative Authority concludes its investigation, the Commission shall issue an order concluding this initial stage. After that, the Investigative Authority must either: (1) issue a presumptive liability statement (DPR), which is similar to what in other jurisdictions is called a statement of objections, addressed to the economic agents who are prima facie liable for the anticompetitive conduct; thus, the second stage of the proceedings (ie, the trial-type administrative proceedings) would start; or (2) order the termination of the proceedings.
Once the DPR is served, the defendants are allowed to file briefs in response to the DPR, including any relevant evidence. After the responses, evidence and conclusions are submitted or upon expiration of the term afforded for such purposes, the trial-type administrative proceeding is concluded and the plenum of the Commission (five commissioners under the newly approved Reform Bill) must issue a decision. In an effort to expedite the proceedings, the Reform Bill establishes a new hearing to express oral arguments and conclusions before the Plenum during this stage.
Henceforth, we offer a brief review of Mexican cases in the health and pharmaceutical sector that were subject to the aforementioned proceedings. This overview will also seek to emphasise the relevant implications of a redefined regulatory framework in terms of enforcement mechanisms and procedural timelines, once the Reform Bill enters into force on the day following its publication in the Official Gazette of the Federation.
Cartel in the public procurement of the National Health System
The most important public health institutes in Mexico acquire medical devices, supplies or consumables through public bids at national level. In some of them, the participants are resellers (integrators) that provide all the goods and services – acquired from different suppliers – required to provide certain medical services or run clinical tests.
In this case, these major public institutes issued – from 2008 to 2015 – public bids to acquire: (1) clinical laboratory studies, which require from an integrator everything necessary to conduct pre-diagnosis, diagnosis or treatment monitoring studies; and (2) blood bank services.
In 2016, one of these public institutes brought a competition claim before the Commission against the integrators that were part of the referred bids.
After four years of investigation and upon termination of the trial-type administrative proceeding, the Commission concluded that five integrators and several individuals exchanged information for bid rigging.
The Commission evidenced that the integrators maintained intense communications through emails and phone calls to convene meetings during the days before and after the presentation of their quotes in said bids. The integrators combined and allocated the bid by regions, following a mechanism by means of which each integrator identified the established capacity in the respective regions, so each of them would supply the region in which it had the largest capacity. In doing so, the winner would set the price to be offered, at which point the rest of the participants would present a losing proposal with higher quotes, would abstain from participating or would make their technical proposal unfeasible.
It should be noted that, in Mexico, the burden of proof to evidence a cartel activity is simple and straightforward. The Commission must demonstrate that the cartel participants are competitors, who carried out any of the five acts (ie, price-fixing, supply limitation, market allocation, bid rigging and exchanging information with the purpose or effect of any of the foregoing) set forth in the FCA as horizontal restraints. These types of anticompetitive conduct are sanctioned under the per se rule, hence, the cartel participants are not allowed to exercise any defence, even if they provide justifications based on efficiencies or consumer gains.
Based on information readily accessible to the public, 11 legal entities and 14 individuals were sanctioned under this investigation in the health sector. The fines imposed on each legal entity and individual that conducted this cartel together amounted to US$36,358,502; the estimated damage to public funds induced by this anticompetitive conduct amounted to US$69,998,050.
While the original fine imposed by the competition watchdog was higher, a federal court reversed this decision in the interests of one legal entity and one individual. In fact, according to publicly available information, there are other pending trials before the federal courts that may reduce the total amount of the fine and therefore accentuate the gap between these fines and the actual damage caused in the public health sector.
Cartel in drugs distribution
In May 2016, the Commission launched an investigation for horizontal restraints in the market for the production, distribution and commercialisation of drugs in Mexico. This investigation was ambitious, but the final decision only sanctioned some distributors for exchanging information.
In Mexico, there are no more than five companies in charge of drug distribution at the domestic level. Typically, the pharmaceutical companies sell or hand over their drugs to third-party distributors that resell or deliver these products to the retail outlets, including chain pharmacies, local pharmacies or supermarkets, among others.
In 2021, the Commission entered its final decision, concluding that the cartel between the distributors was formed over 10 years through the following conduct: (1) an agreement with the purpose of avoiding any drug distribution on Good Friday (Easter week) and the Day of the Dead (2 November); (2) through the Mexican Drug Distribution Association, the distributors created a Credit Committee in which each distributor shared confidential and detailed information about their clients, which allowed them to jointly determine either to reduce or cancel their clients’ credits; and (3) the cartel was carried out through price-fixing, by setting a limit on the discounts offered to their clients and agreeing on the mark-up profits on certain drugs. As specified by the decision, the Mexican Drug Distribution Association played a key role reviewing the adherence of the distributors to said agreements.
The fines imposed on the economic agents involved in these anticompetitive practices amounted to US$45,525,635, whereas the estimated damage amounted to US$118,868,257.
In addition to the fines imposed on five distributors, 21 individuals and the Mexican Drug Distribution Association, for the first time, the Commission coupled these fines with an additional sanction to sharpen its prosecution strategy against any anticompetitive practice, which resulted in disqualifying executives from serving as directors, managers, executives, agents, representatives or attorneys-in-fact of the distributors for up to four years.
Surprisingly, the fines imposed in these revisited cases have been much lower than the damage caused to the public health sector. This could be viewed as an unsuccessful deterrence weapon to hinder illegal restraints of competition, while the economic agents continue to exert anticompetitive conduct in public bids.
Civil and criminal liability
The recently approved Reform Bill increases the aforementioned fines as follows: up to 10 per cent of the economic agent’s annual income for engaging in abuse of dominance, up to 15 per cent of the economic agent’s annual income for the consummation of cartel activity and a 50 per cent increase in fines for individuals who assisted, induced or participated in such conduct or acted on behalf of the responsible entities.
Notwithstanding the economic sanctions imposed upon conclusion of a competition proceeding, the entities and individuals that perpetuate cartels might also be subject to civil and criminal liability.
Civil liability
Any person who has suffered damage or losses due to any anticompetitive conduct or any illegal concentration has legal standing to claim civil damages before the specialised federal courts in Mexico. In terms of the FCA, it is mandatory to hold a decision in force issued by the Commission to claim civil damages.
During the civil trial, the judge may summon the Commission to assist with the estimation of the damage and losses suffered due to the illegal restraint.
It is noteworthy that the generic statute of limitations (two years) for claiming civil damages will be paused once the Commission launches the formal investigation. The Commission’s powers to investigate anticompetitive conduct expire 10 years after the last day on which the illegal restraint took place.
Alongside civil liability claims, the Commission has legal standing to bring class actions based on the rules set forth in the Federal Code of Civil Procedure. This Code provides that to file a class action, a formal decision must have been issued by the Commission.
It should be noted that the civil claim would still be applicable even if the defendant involved in abuse of dominance conduct settles the investigation with the Commission or if any participant in a cartel activity applies to the leniency programme.
Moreover, the Commission may only initiate class action proceedings against economic agents who, through the cartel formation, abuse of dominance, or illegal concentrations have caused harm to consumers.
Once a class action lawsuit is filed before a Federal Judge specialised in competition matters, a preliminary review phase is carried out wherein the admissibility of the claim is thoroughly assessed.
The Judge verifies whether the action meets the substantive and formal criteria outlined in the Federal Code of Civil Procedure. This includes ensuring the existence of a commonality of facts and legal issues affecting at least thirty individuals and confirming that the claim seeks to protect group or collective rights. If this class action is initiated by the Commission, the claim must be based on conduct that has already been sanctioned through a prior investigative procedure that concluded in a definitive and binding resolution.
Upon admission of the claim, the Judge orders the publication of notices intended to inform potential beneficiaries of the collective action, allowing them the opportunity to either opt in or submit objections. A procedural calendar is then established, delineating the phases for the disclosure of evidence, submission of pleadings, and other incidental matter.
After the admission, the procedure enters a conciliatory phase. If no settlement is reached or if conciliation is deemed inappropriate, the proceedings advance to the evidentiary stage, where both the claimant and the defendant are required to substantiate their positions with documentary, testimonial or expert evidence. The judge exercises a supervisory role, ensuring that the evidentiary process respects due process and adequately reflects the collective nature of the harm.
Once the trial phase concludes, the court issues a judgment, which may establish remedial actions, such as monetary compensation, injunctive relief or the restoration of rights. The judgment may also include provisions for the calculation of damages and its enforcement, including mechanisms for the appropriate distribution of compensations among the affected parties. The Commission may be tasked with overseeing aspects of compliance, reporting or coordination with the parties involved.
It is important to highlight that the statute of limitations for class action lawsuits is three and a half years from the day the damage is caused or the conduct ceases; however, said term is suspended while the Commission is investigating the alleged anticompetitive conduct. Ultimately, this legal mechanism strengthens the enforcement of competition law in Mexico and provides meaningful access to justice for consumers harmed by systemic anticompetitive practices.
At the outset of 2024, the Commission’s chair, Andrea Marván, announced that the Commission would encourage the filing of class actions to claim civil damages suffered by consumers, acknowledging that this tool has not been employed recently by the Commission.
Consequently, in October 2024, the Commission filed its first-ever class action lawsuit against three pharmaceutical companies and the Mexican Drug Distribution Association before the Mexican Federal Courts. The lawsuit claims damages up to 2 billion pesos for horizontal restraints in the market for the production, distribution and commercialisation of drugs in Mexico, which were previously investigated.
In a clear attempt to align itself with the elected government, the Commission stated that the amount would be allocated to the improvement of the Mexican public healthcare system. The class action lawsuit was promptly dismissed on grounds that have not yet been made public. The Commission appealed the decision. In March 2025, the Mexican Supreme Court of Justice agreed to hear the case through a discretionary review mechanism, and in the first week of July, ordered the admission of the class action.
Although this effort remains the only class action lawsuit filed by the Commission to this date, the Reform Bill includes a relevant amendment worth mentioning. The bill clarifies that class actions may be filed once the administrative resolution has been issued. Therefore, this amendment could be interpreted as an attempt to introduce a more streamlined procedure for the reparation of harm for anticompetitive behaviour.
However, we expect that this amendment will provoke future legal challenges once it reaches a judicial forum, as it may contravene the amparo proceeding, a unique legal remedy in Mexico’s judicial system and a cornerstone of its legal framework and idiosyncrasy. Notwithstanding the above, we have reason to anticipate that the Commission will continue to promote class actions within the scope of its preventive and corrective powers.
Criminal liability
The FCA also provides that the Commission (through its Investigative Authority) has standing to file complaints before the Mexican Public Prosecutor’s Office. It is noteworthy that the criminal complaint could be filed once the DPR has been issued; in other words, the criminal procedure might start even if the Commission has not issued its final decision.
Currently, the Mexican Federal Criminal Code mandates a criminal penalty of between five years’ and 10 years’ imprisonment, coupled with at least 1,000 days and up to 10,000 days of fines imposed on any individual who participates in a cartel activity. The statute of limitations for claiming such criminal penalties is seven and a half years.
Importantly, there is no criminal liability for applicants to the leniency programme.
In recent years, the Commission has filed two criminal complaints before the Public Prosecutor’s Office for cartel practices in the public health sector.
The Commission’s ongoing investigations
During 2022, the Commission initiated two additional cartel investigations in the health industry, the first in the market of radiological material acquired by the national health system, which confirmed the Commission’s appetite for going after bid rigging cases in public bids.
Based on publicly available information, the Commission recently issued a statement of objections under this investigation, whereby entities and individuals have been summoned. As previously mentioned, these summoned participants could counter that statement and submit additional evidence to dispute the accusation. Therefore, this administrative trial is expected to conclude during the first semester of 2026.
The second investigation considers the distribution and commercialisation of scopolamine in Mexico. This is an active ingredient that serves as a base for the creation of common drugs, indicated in adults for the prevention of nausea and vomiting associated with motion sickness and post-operative nausea and vomiting. It is expected that the Commission will conclude this second investigation during the first semester of 2025.
Along these lines, in July 2024, the Commission’s steadfast commitment regarding the health sector was renewed. Following up on the preceding investigations initiated in 2022, the Commission publicly announced an upcoming investigation into the procurement of medical services for neonatal metabolic screening tests and related products by public health institutes in Mexico. It is noteworthy that these laboratory tests have been mandatory in Mexico since 1998 and are performed on newborns to detect hereditary and congenital conditions and diseases for their early treatment. According to the official statement, the Commission is investigating horizontal restraints in the referred market. Based on the explanation previously given about competition proceedings, this statement does not imply a liability pre-judgment. We should await the final official statement of objections to be issued by the last semester of the year 2026.
Finally, amid the imminent regulatory transition, and to underscore the Commission’s ongoing commitment to safeguarding strategic sectors, the Investigating Authority publicly announced in early June 2025 that it had found evidence of potential anticompetitive practices alleged illegal agreements between companies that participated in public tenders for the procurement of insurance services including life insurance, but also relating to accident, health and pension insurances.
Moreover, a recent initiative was also published in the Official Gazette in early June 2025, concerning public procurement procedures in the pharmaceutical sector. In line with the Executive Branch’s current agenda, which prioritises self-sufficiency and strategic development in key sectors, a recent regulatory initiative, the Decree for Fostering Investment in the Pharmaceutical Sector, has been introduced to further support the evolving landscape of Mexico’s pharmaceutical and healthcare industries.
This measure seeks to strengthen domestic production of pharmaceutical and medical devices, encourage scientific research and promote innovation by rewarding companies that demonstrate significant investment in Mexico’s supply chain or undertake onshore research and development activities in Mexico. It also contains provisions aimed at streamlining administrative procedures, especially with respect to securing and preserving regulatory approvals, and incentivises participation in public tenders through criteria reflecting national content and scientific collaboration.
Recent market studies in the health industry in Mexico
As part of its advocacy role, the Commission regularly issues competition assessments on different industries, by means of which it can review the market structure and its dynamics, while flagging potential competition concerns, which may point to regulatory or behavioural barriers or conduct carried out by one or more entities or individuals; likewise, the Commission generally proposes a specific course of action to solve or mitigate them.
It should be noted that, after the release of any of these assessments, the Commission has launched investigations for cartel activities or abuse of dominance. In some cases, the Investigative Authority has also brought investigations to identify competition barriers or essential facilities; or state the lack of competition conditions in specific markets, which may trigger a tariff regulation or any other suitable regulation by the corresponding sectoral authority.
In recent years, the Commission’s studies have addressed the following markets: medical insurance (2022); freight railroad services (2021); food and beverages in the retail channel (2020); ground transportation (2019); digital economy (2018); expired patent drugs (2017); agribusiness (2015); and financial services (2014).
As mentioned above, the Commission released a competition study in the expired-patent drug market in Mexico. The purpose of this study was to assess whether the market for drugs worked properly and efficiently once the patent of an original drug expired, since upon expiration, other laboratories may produce and trade generic versions, which, theoretically, should make drugs available to a larger group of consumers at a lower price.
In Mexico, a generic drug must satisfy two legal conditions to enter the market: the drug must not infringe patent rights and must have a sanitary authorisation.
There are different types of drug patents, namely: product patents, which protect the active ingredient or initial chemical compound, as well as variants of a known active ingredient; formulation or pharmaceutical composition; use; or procedure.
The first patent granted for an active ingredient is known as a primary or basic patent, and the others are known as secondary or second-generation patents (follow-on patents).
According to the study, the entry of generic drugs into the market has been late and slow. In Mexico, after the expiration of a patent and until the first generic is released, more than two years elapse, on average. In the United States, the most demanded drugs are immediately launched once the patent expires, whereas, in the EU, this time frame lasts seven months, approximately.
The study stressed several competition concerns, identifying failures of both the government and the market itself, which prevented its efficient functioning. Specifically, the Commission identified the following major concerns: drugs with expired patents face no competition, albeit some generic pharmaceutical manufacturers have sanitary authorisations to launch the generic drugs; generic drugs do not pose enough competitive pressure; patent pharmaceutical manufacturers have adopted strategies to delay or prevent the entry of generic drugs; and barriers in the regulatory framework have delayed the release of generic drugs.
The document referred to also sets forth a list of recommendations to enhance the competition conditions, most of them relating to granting patents and sanitary authorisation.
In this regard, the Commission assessed, together with the regulatory authorities, the limitations of granting follow-on patents; granting a new sanitary authorisation when a manufacturer requests the modification of the authorisation of a drug, considering a marginal improvement that is associated with a new patent with subsequent validity to the initial patents granted. These proposals would prevent those marginal innovations on a drug whose patent is about to expire, delay the entry of generic drugs and would allow the publication – periodically – of a list of drugs whose patents will expire over the next three years.
Finally, as part of a larger public policy, the Commission suggested to the Health Ministry the promotion of a media campaign aimed at medical personnel and consumers in general, to heighten reliance on the quality of generic drugs.
The Commission’s active interest in the health sector was restated in 2022 with a study on the market of medical expenses insurance (SGM). This study was conducted in response to increasing concerns for the Mexican population’s ageing and the corresponding increase in demand for health services. In Mexico, 13 million people are covered by SGM, a financial instrument that allows collectivisation of the economic loss faced by an individual.
The study reveals that in Mexico, 79 per cent of hospitals with more than 100 beds and 70 per cent of insurance payments are concentrated in Mexico City, Jalisco, Nuevo León and the State of Mexico. Therefore, prices for hospital services are significantly higher in these regions. This suggests that insurance companies have little bargaining power against larger hospitals. Further, SGM premiums are 12 per cent more expensive in regions that have private hospitals with more than 100 beds.
The switching costs secure a lock-in of the policyholder, that is, consumers who already have insurance are compelled to remain with their insurance company, even though other insurers might offer more attractive plans in terms of price or quality. Moreover, insurers are not required to recognise the seniority of clients coming from other insurers, and do not cover pre-existing conditions. As a result, consumers prefer to stay with the same insurer.
Another distortion in this market is associated with the brokers, who are the main sales channel for SGMs: eight of every 10 individual or collective products are marketed through them. Economic agents can commercialise insurance from a single company or several; however, larger insurers pay higher commissions. Consequently, economic agents have incentives to work harder to commercialise products that give the brokers the highest commissions. This strategy prevents incoming insurers from incorporating their products into the pre-existing brokers’ portfolios.
In response to these concerns, the Commission issued the following recommendations:
- the Mexican Consumer Protection Authority is encouraged to develop and release indicators that measure the price–quality relationship of hospital services;
- insurance portability should be enhanced by recognising the coverage period of the policyholder;
- insurers must share information about prices, coverage, exclusion clauses and contract requirements for every insurance plan;
- brokers must disclose to consumers information about the commissions and bonuses they receive from each insurer; and
- broker bonuses or commissions subject to sales goals for the same plan or the same company should be prohibited.
Emerging horizons in the pharmaceutical and healthcare sector in Mexico
Overall, this article has endeavoured to shed light on pertinent precedents and ongoing investigations pending decisions in the pharmaceutical and healthcare industries in Mexico. As we conclude our examination of the current legal landscape, the trends set out below are expected.
In essence, pursuant to the competition authority’s approach to antitrust investigations in recent years, the Commission is expected to magnify the ongoing pursuit of cartel practices, particularly in public bids.
Likewise, economic agents involved in anticompetitive conduct should envisage the Commission’s prospective reliance on criminal and civil liability, namely by filing criminal complaints and promoting class actions, to reinforce the deterrence of illegal restraints to competition or cartels.
Based on the recent investigations revisited, we anticipate that the competition watchdog will remain vigilant in the SGM market and foreseeably mindful of the market distortions identified at present, as well as any other relevant antitrust concern formerly diagnosed or yet to be uncovered within the health sector.
The newly approved regulatory framework implies significantly shorter procedural timelines for investigations and trial-like proceedings, while reaffirming the federal government’s role in directing competition policy. Therefore, the policy alignment with the elected administration’s priorities will predictably prompt new and ambitious investigations in the health and pharmaceutical industry.
In fact, this regulatory transition is already having early repercussions in the pharmaceutical and healthcare sector, as evidenced by recent investigations published by the Commission in this sector and the new initiative aimed at promoting local investment in the pharmaceutical industry.
* The authors would like to thank Natalia García ([email protected]), associate at the firm, for their valuable contribution to this article.
Endnotes
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