Episode 443 — Nothing Crosses the Border for Free

In this episode of Corruption, Crime and Compliance, Michael Volkov examines the compliance risks lurking in ordinary U.S.-Mexico cross-border trade, explaining how the plaza system allows cartels to function as a de facto taxing authority over certain border corridors, extracting piso payments from legitimate commercial shipments that pass through their territory, often through customs brokers and logistics providers who absorb and disguise the cost as routine fees. Drawing on The Scoular Company’s FCPA resolution, in which bribes paid to Mexican officials to clear failed agricultural inspections were later found to have partly benefited a border cartel without the company’s knowledge, Volkov explains how the government’s designation of major cartels as Foreign Terrorist Organizations has activated material support liability under the Anti-Terrorism Act, exposing companies to cartel-related risk regardless of intent or awareness. He closes with a practical compliance roadmap: reclassifying customs brokers and logistics providers as high-risk third parties, sharpening due diligence beyond standard sanctions screening, testing the substance behind every recurring border-related payment, building and actually enforcing audit rights, giving compliance real visibility into operational payment data, and breaking down the silos between sanctions, anti-money laundering, and anti-corruption teams so that cartel-linked risk doesn’t fall through the cracks between them











