FCPA Compliance Report · 2026-06-01 · 25 min
In this episode, Tom Fox welcomes Matt Ellis of Miller & Chevalier about the ACI “Cartels, TCOs and Compliance in Latin America” forum (July 20 - 21, Washington, DC) and why cartel/TCO/FTO risk is a timely 2026 compliance priority. Ellis describes the Trump administration’s focus on cartels, fentanyl, China’s influence, and the expanded enforcement toolkit - FCPA guidance linking to cartel activity, sanctions, AML actions (including FinCEN orders against Mexican financial institutions), and cartel FTO designations implicating the Anti-Terrorism Act. They discuss how cartels infiltrate supply chains, creating “material support” exposure, and why due diligence must go beyond traditional screening to on-the-ground intelligence and nuanced red flags. Ellis notes government interest in compliance expectations, extortion-payment considerations, the Lafarge/ISIS example, anticipated investigations, broader regional risk (Mexico, Venezuela, Colombia, Brazil), and increased multi-agency coordination and potential dialogue with U.S. authorities.
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