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Leveraging Human Rights Frameworks to Combat Emerging Cartel Risks

Corporate Compliance Insights

In this article, Nate Lankford and Matteson Ellis, together with ABB's Nisha Sawhney-Murkett, outline how companies in high-risk, cartel-influenced regions can leverage human rights due diligence (HRDD) to uncover legal and reputational risks traditional compliance programs may overlook, particularly as U.S. enforcement policy intensifies its focus on cartels designated as foreign terrorist organizations (FTOs). "Human rights due diligence, in contrast, is designed to leverage broader sources of information to identify exposure to severe human rights effects, such as violence and human trafficking, which can exist at the core of cartel/FTO activity," authors explained. "In this way, HRDD helps close the gap and position companies to understand their legal compliance risk more holistically."