Exporting Compliance – Conducting Compliance Investigations Across Latin America
The world is a turbulent place in 2025 and doing business outside of the U.S. means needing to understand and to be able to react to a dynamic and evolving risk environment. The many countries and amazing people comprising Latin America are an important customer base and trading partner for most global organizations. Many global businesses have significant operations in the region and despite the turbulence, the region is full of opportunity.
Drug cartels, transnational crime groups and gang violence, corrupt public officials, unstable governments, and professional kidnap for ransom operations are just a handful of the challenges that face global organizations operating in Latin America.
To take advantage of the bountiful opportunities across the region, organizations need to be able to proactively identify, manage and mitigate these and other operational risks. It starts with knowing who you are doing business with, their reputations, prior conduct and whether their political connections are a help or a significant hindrance.
Likewise, it is equally important to be able to deploy international counsel and their partners to triage crises, investigate negative events, stabilize volatile situations, understand and act upon the compliance implications and pursue avenues of recovery when losses occur.
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30:08
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30:08
The Last of the Watchdogs
On inauguration day, President Trump rescinded numerous Executive Orders from prior administrations including one in which appointees within each Executive Branch Agency was required to sign a pledge not to accept gifts from lobbyists, recuse themselves from matters related immediate former employers or clients for 2 years, and not to participate in any matter for which they lobbied the government as a registered lobbyist for 2 years. The pledge also required appointees upon leaving government not to communicate with their former agency or senior White House Senior Staff for 2 years, not to assist others to do so, not to lobby the U.S. government or on behalf of a foreign government or political party, not to accept a golden parachute payment coinciding with the acceptance of an appointment and to make employment decisions on their merits. The President has made a series of unorthodox appointments to head major government agencies including people who have publicly advocated for disbanding and/or radically changing those agencies and calling them “irredeemably corrupt” or other extremely derisive terminology. Also on inauguration day, the President pardoned ~1500 January 6th rioters and commuted the sentences of 14 others. Then, the DOJ mandated that the FBI turn over the names of all FBI personnel who participated in the January 6th investigations and fired or threatened to fire anyone who refused to comply. This was preceded by over a dozen firings of senior FBI and DOJ officials who played a substantive role in the January 6th investigations and prosecutions. Ultimately, the names of ~5000 FBI personnel were turned over without much assurance that their names wouldn’t be publicly released posing genuine safety concerns. But perhaps the biggest body blow to the federal law enforcement community came on January 24, 2025 when President Trump fired 16 inspectors general of the 16 largest, most complex U.S. government agencies and a 17th, the IG for USAID Paul Martin, 2 weeks later. In case that purge wasn’t enough to upend the government’s ability to police itself, Hampton Dellinger, the head of the Office of Special Counsel and David Huitema, Director of the Office of Government Ethics were also fired. And the upheaval continues unabated.
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38:57
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38:57
Bank Robbery is a Very Stupid Crime
Today’s episode is the continuation of a new series in which my former FBI Colleague Kevin Cearlock and I explore the funnier side of the FBI based on our own experiences and our friends. The working title is “You can’t make this sh*t up”.
Law enforcement is full of great story tellers. Hard to say whether storytellers tend to become law enforcement officers in disproportionate numbers or, perhaps more likely, it’s the fact that ridiculous things sometimes happen during the course of one’s law enforcement career and they can make for some great stories. Some of the best stories Kevin Cearlock and I have relate to bank robberies, and this episode shares one of my favorite stories witnessed first-hand.
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28:51
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28:51
Pig Butchering: The Intersection of Romance Fraud and Human Trafficking
Of the various fraud scheme names that have been coined over the years, “Pig Butchering” is one that provokes the most visceral response based on the name alone. And yet, the actual act of Pig Butchering is even more horrible than the name suggests. It is the latest variation of an age-old type of crime under the umbrella of “Romance Schemes”. People who prey on the lonely and elderly pretending to be a potential romantic partner with the express purpose of defrauding them.
Guest Erin West, founder of Operation Shamrock, speaks about the mission to raise awareness of pig butchering with everyone, everywhere, all the time.
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23:12
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23:12
You can’t make this sh*t up
Today’s episode is the introduction of a new series in which my former FBI Colleague Kevin Cearlock and I explore the funnier side of the FBI based on our own experiences and our friends. The working title is “You can’t make this sh*t up”.
Learn more about your ad choices. Visit megaphone.fm/adchoices
Join us to hear about crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, warlords, and kleptocrats. The Fraud Eats Strategy series is the distillation of experiences, whether it's an accounting scandal, arrests, search warrants, loss of market cap, or all of those things at once – one thing is sure. Failure to consider fraud and corruption risk can upend your strategy and lead to disaster.
México