July 21, 2025
Alejandro Gil Ortiz
General Counsel
Mexican Economic Development Inc.
General Anaya No. 601 Pte.
Colonia Bella Vista
Monterrey, NL 64410 Mexico
Re: Mexican Economic Development Inc.
Form 20-F for the Fiscal Year Ended December 31, 2024
Filed April 24, 2025
File No. 001-35934
Dear Alejandro Gil Ortiz:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.
Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Form 20-F for the Fiscal Year Ended December 31, 2024
Risk Factors
Risks Related to Our Company, page 4
1. We note your disclosure at the bottom of page 8 regarding risks linked
to international
cartels and transnational criminal organizations present in
jurisdictions that you have
operations. We further note media sources indicate your OXXO operations
in Nuevo
Laredo, Mexico were temporarily closed in 2024 due to cartel related
concerns. In
future filings, please revise your disclosure to expand on the risks
related to
heightened criminal activity in Mexico. Your revised disclosure should
address, but
not be limited to, how criminal activity affects companies and employees
through
extortion, theft, kidnapping, and violence. If material, include impacts
such as, lost
income and associated costs due to store closures, increased insurance
and security
costs, theft, and extortion losses. Also, consider discussing how
corruption and ties
between criminal organizations and authorities may affect your
operations and how
July 21, 2025
Page 2
cartels may attempt to control the sale, distribution, and pricing of
goods. Please
provide us with your draft disclosure enhancements in your response.
In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.
Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at
202-551-3723
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing