Scoular's FCPA Settlement Highlights Cartel Risk in Cross-Border Trade

The recent FCPA enforcement action against Scoular, an agricultural supplies company, for bribing Mexican officials, reveals a critical new dimension for internal audit and assurance professionals: the intersection of corporate corruption and drug cartels. This case underscores the heightened compliance risks for companies engaged in cross-border trade, particularly in regions with significant cartel activity, and signals a new priority for the Justice Department. Audit teams must re-evaluate risk assessments and internal controls to account for potential indirect benefits to transnational criminal organizations (TCOs) through bribery schemes, even if the company is unaware of the ultimate beneficiaries.