Refocusing Due Diligence on Cartel and TCOs (Part I of II)
Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal organizations (“TCOs”) in a company’s supply chain and distribution channel. The Justice Department has adjusted its enforcement priorities to elevate the importance of prosecuting cartels and TCOs. This initiative will involve a two-fold...