In this episode, Tom Fox welcomes back Matt Ellis of Miller & Chevalier to recap ACI’s inaugural two-day Cartel Conference in Washington, DC, highlighting an unusually collaborative, high-energy atmosphere around emerging cartel/TCO/FTO compliance risks in Latin America.They discuss DOJ’s Scoular FCPA action as illustrating the long tail of enforcement and a high bar for managing cartel-related and national security risks, while noting the DPA’s remedial steps focus more on traditional anti-corruption controls than TCO/FTO-specific guidance. Government participants emphasized a “whole of government” approach, voluntary disclosure, and potential public-private engagement (including embassy attachés and Treasury) in high-risk scenarios. Key themes included narrow duress defenses, complex “imposter” risks, evolving due diligence beyond traditional screening using data/anomaly detection and local intelligence, and the need to integrate compliance across AML, sanctions, security, and supply chain given severe reputational and business consequences of terrorist or cartel support.Key highlights: Conference Vibe and Energy Scoular FCPA Case Takeaways When to Engage Government Duress Defense and Safety Payments Cartel-Focused Due Diligence AML Lessons for Banks Breaking Silos in Compliance Parallels to Early FCPA Era National Security StakesResources:ACI National FCPA and Global Anti-Corruption Conference, December 10-11 at the Gaylord National Resort & Convention Center, Washington, DCMatt Ellis on LinkedInTom FoxInstagramFacebookYouTubeTwitterLinkedInTo learn about the intersection of Sherlock Holmes and the modern compliance professional, check out my latest book, The Game is Afoot-What Sherlock Holmes Teaches About Risk, Ethics and Investigations on Amazon.com.Learn more about your ad choices. Visit megaphone.fm/adchoices