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...

Ethisphere and Ethena just released a research report that every compliance officer should read carefully, not because it breaks new ground on AI risk, but because it turns the mirror around and asks an uncomfortable question: if ethics and compliance is the function writing the rules for how everyone else uses AI, why is it the function using AI the least itself? The report, based...

I was honored to appear on The Third Party Risk Association’s Podcast, TPRM Exchange, hosted by Hilary Jewhurst, to have an interesting discussion on Sanctions Compliance. The podcast is available HERE.

Michael Peregrine and Ashley Hoff recently published an interesting article on the importance of Board Vigilance on Corporate Fraud — a copy of this insightful article is available below.