tcos Archives - Corruption, Crime & Compliance

9 Jul, 2025

Cartel and TCO Due Diligence and Risk Factors (Part II of II)

Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and financial interests through shell companies, sophisticated networks of third parties and legitimate businesses in real estate, construction, mining, agriculture, export/import, casinos, fintech platforms and finance. The Sinola Cartel in Mexico operates in...

General

17 Jun, 2025

DOJ’s Fresh FCPA Enforcement Initiative — What’s New, What’s Not (Part II of II)

DOJ’s new approach to FCPA enforcement presents some interesting opportunities — the headlines from the DOJ FCPA Guidance Memo will bring some significant changes but at the same time some things will not change. Here is my list of what’s new and what’s the same. 1. Increased individual prosecutions and reduced emphasis on corporate prosecutions: The DOJ FCPA Guidance Memo prioritizes individual prosecutions and avoidance...

General

16 Jun, 2025

Justice Department Resumes FCPA Enforcement with New, Focused Guidance (Part I of II)

The Justice Department has returned to the FCPA enforcement arena — in a significant development, DOJ announced the resumption of FCPA enforcement, with a new set of enforcement guidance principles. The new guidance is an important statement governing FCPA investigations and prosecutions. The impact of this new approach will be significant — the precise scope of this renewed focus will depend on certain legal factors,...