About this episode

Tom Fox interviews Matt Ellis about cartel risks and compliance in Latin America.

In this episode, Tom Fox welcomes Matt Ellis of Miller & Chevalier about the ACI “Cartels, TCOs and Compliance in Latin America” forum (July 20–21, Washington, DC) and why cartel/TCO/FTO risk is a timely 2026 compliance priority. Ellis describes the Trump administration’s focus on cartels, fentanyl, China’s influence, and the expanded enforcement toolkit—FCPA guidance linking to cartel activity, sanctions, AML actions (including FinCEN orders against Mexican financial institutions), and cartel FTO designations implicating the Anti-Terrorism Act. They discuss how cartels infiltrate supply chains, creating “material support” exposure, and why due diligence must go beyond traditional screening to on-the-ground intelligence and nuanced red flags. Ellis notes government interest in compliance expectations, extortion-payment considerations, the Lafarge/ISIS example, anticipated investigations, broader regional risk (Mexico, Venezuela, Colombia, Brazil), and increased multi-agency coordination and potential dialogue with U.S. authorities. Key highlights: Why This Conference Now Due Diligence Goes Deeper Extortion and Self-Reporting Beyond Mexico Regional Risks Whole-of-Government Focus…

People in this episode

Host: Tom Fox

Guest: Matt Ellis

Topics covered

• cartels
• compliance
• Latin America
• due diligence
• fentanyl
• supply chains
• government coordination

Mentioned in this episode

Organizations: Miller & Chevalier, ACI, FinCEN, ISIS

Books & works: The Game is

Places: Washington, DC, Mexico, Venezuela, Colombia, Brazil

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