Part one of this series laid out why forced labor risk has moved from the sustainability report to the balance sheet: tariffs tied directly to a country’s forced labor record, an import presumption in the United States that can freeze finished goods over a single sub-tier component, and a European regulation that can pull products off shelves entirely. Part two addresses the harder question: what...

For years, forced labor risk sat comfortably in the sustainability and corporate responsibility part of the organization. It showed up in an annual ESG report, maybe a supplier code of conduct, and rarely made it onto the desk of a CFO. That era is over. Forced labor exposure is now a direct line item risk, capable of inflating cost of goods sold, freezing inventory at...

Part one of this series examined how Mexican cartels function as a de facto taxing authority over certain border corridors, ports, and crossings, and how legitimate-looking fees paid to customs brokers and logistics providers can conceal payments that ultimately benefit criminal organizations. This second installment turns to what compliance programs actually need to do about it. If your company moves goods across the U.S.-Mexico border,...

There is a hard truth that compliance officers overseeing Mexico operations need to internalize, and it is the same truth prosecutors have started building into recent enforcement actions: at many points along the U.S.-Mexico border, cartels function as a de facto taxing authority. Goods, cash, and people do not move through certain crossings, ports, and corridors without someone, somewhere in that chain, paying a fee...

The Securities and Exchange Commission has announced a new specialized unit inside its Enforcement Division dedicated specifically to accounting and financial reporting fraud, and the announcement is worth reading closely, not just for what the unit will do, but for what its creation says about how the agency is currently defining its own enforcement priorities. A New Unit With a Specific Mandate The unit will...