Corruption Crime & Compliance Refocusing Due Diligence on Cartel and TCOs
Jul 14, 2025
15:36
Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate recalibration of due diligence systems to detect links to cartel and transnational criminal organizations (TCOs). With the Department of Justice sharpening its focus on both direct prosecutions and financial facilitators, global companies must prepare for heightened scrutiny. Michael breaks down the mounting risks, enforcement priorities, and practical steps companies must take to protect themselves from becoming unwitting participants in criminal operations.
You’ll hear him discuss:
- How DOJ’s new two-pronged enforcement strategy is bringing corporate facilitators of cartels and TCOs into the crosshairs
- Why traditional due diligence no longer goes far enough, especially with "Nth Party" risks buried deep in supply chains
- How cartels and TCOs exploit legitimate businesses in sectors like logistics, agriculture, mining, and construction
- The importance of identifying beneficial ownership and tracing complex corporate structures across jurisdictions
- Red flags to watch for, from nominee arrangements and shell companies to unexplained wealth and layered financial flows
- How cartels are adapting with fake websites, fake bios, and cryptocurrency to mask illicit activities
- What companies must do to modernize their compliance systems with open-source tools and workflow automation
- Why trade-based money laundering, remittance services, and decentralized platforms are growing areas of concern
Resources