FCPA Compliance Report · 2026-07-20 · 31 min
Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. In this episode, Tom welcomes back Matt Ellis to discuss a newly announced FCPA enforcement action involving Scoular Company. The case invoiced about $400,000 in payments labeled as “reinspection fees” to Mexican customs and food inspectors to move agricultural goods across the Mexico - U.S. border. border, allegedly generating over $6.5 million in avoided costs and raising concerns about cartel-linked beneficiaries. They discuss why customs and customs brokers are recurring high-risk areas in Mexico, how long-running employee involvement suggests broader controls and tone-from-the-top failures, and why these payments are not facilitation payments under Mexican law and given discretionary official acts. Ellis emphasizes analytics on customs documents and broker invoices, stronger third-party diligence beyond traditional screening to address cartel/TCO risks, and defensible governance for WhatsApp/off-channel communications.
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