Compliance into the Weeds Uncovering FCPA Violations: Millicom's Complex Case Involving Drug Cartel Funds
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Nov 19, 2025 Dive into the complex case of Millicom Cellular, where duffel bags stuffed with drug cartel cash were used to bribe Guatemalan officials. Discover how this intricate FCPA enforcement action unfolded, revealing a lack of operational control within the joint venture. The episode explores the critical implications for compliance in high-risk regions and the importance of robust due diligence. With insights on narco-trafficking connections and lessons for joint-venture compliance, this discussion is both compelling and educational.
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Majority Ownership Without Control Is Risky
- Millicom owned 55% of the Guatemalan joint venture but lacked operational control and visibility for years.
- That structural gap left Millicom exposed to prolonged corruption risks and eventual DOJ action.
Self-Disclosure Can Resurface Later
- Millicom self-disclosed in 2015, DOJ took no action in 2018, but reopened the matter after Millicom gained full control in 2021–2022.
- The case shows investigations can be dormant and later revived when new facts or control changes emerge.
Duffel Bags And A Helicopter Exposed Bribes
- Bribes were delivered in duffel bags, ferried by private helicopter, and exposed after an emergency landing at a military base.
- Soldiers spotted the cash and the scheme unraveled, revealing links to bankers and executives.