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.
Key highlights:
Why This Conference Now
Due Diligence Goes Deeper
Extortion and Self-Reporting
Beyond Mexico Regional Risks
Whole-of-Government Focus
When to Engage Government
Resources:
Cartels, TCOs and Compliance in Latin America, July 20-21
Matt Ellis on LinkedIn
Tom Fox
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To learn about the intersection of Sherlock Holmes and the modern compliance professional, check out Tom’s latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.
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