On March 3, 2022, the Mexican Ministry of Economy uploaded to the National Commission for Regulatory Improvement (CONAMER) a draft amendment to the Administrative Regulation that lists dual-use goods, software and technologies which exportation is regulated by the Ministry of Economy (the “Export Control Regulation”). The main purpose of this amendment was to include an article providing that, as of the entry into force of the amendment, the Ministry of Economy was not going to authorize export permits when the destination declared in the end-use/user declaration was Russia or Belarus, and that export permits that were issued before the entrance into force of the amendment and that included Russia or Belarus as the country of destination would automatically lose their validity.

On March 4, 2022, during the President’s daily press conference, the Mexican Minister of Foreign Affairs stated that Mexico has never imposed unilateral sanctions against other countries and that it only implements the multilateral sanctions imposed by the United Nations Security Council.

With respect to the draft amendment to the Export Control Regulation, the Minister of Foreign Affairs declared that it was not necessary, since the Committee of Export Controls of the Ministry of Economy, at the time of carrying out its risk analysis, is the one that determines if a product can be exported to a determined country or not.

As a result of the above, and based on the declarations of the officials of the Mexican government, Mexico will not impose unilateral sanctions to Russia or Belarus and will only implement sanctions if they are imposed by the Security Council.