Is your routine payment actually a bribe?

Scolar, an Omaha agricultural company, resolved an FCPA case for over $10 million after using customs brokers to bribe Mexican officials, about $2,000 for each train that crossed the border. It was invoiced as reinspection fees paid routinely for six years.

Nobody asked what the money actually bought.

Stop treating customs brokers, freight forwarders, and logistics providers like ordinary vendors. They interact directly with foreign officials on your behalf, and that makes them high-risk third parties, deserving the same scrutiny as a sales agent or government relations consultant.

Test your recurring fees, your routine fees. Any charge that repeats, described in vague language – reinspection, expediting, special handling – should trigger one question every time: can we prove exactly what the payment was for?

If not, that’s your red flag, regardless of the dollar amount.

Small, consistent, unexplained fees at the border are exactly how bribery hides.

Go look at your own customs and logistics payments this week.

The Ethics and Compliance Q and A show is produced by One Stone Creative.