Key takeaways:
- The Mars fraud case shows how insider schemes can persist for years inside complex food companies when trust, specialist roles and fragmented oversight quietly intersect.
- Paul Steed’s 63-month prison sentence sends a clear signal that long-running corporate fraud tied to abuse of trust will result in real jail time, even when much of the money is recovered.
- As global food companies scale through acquisitions, the greatest governance risks may come not from outside threats but from internal blind spots that grow faster than controls adapt.
The Mars fraud case shows that insider schemes don’t need weak controls to succeed – they thrive in complex systems where trust, expertise and fragmentation quietly overlap.
Paul Steed’s 63-month sentence underlines that long-running corporate fraud tied to abuse of trust will draw real prison time, even when much of the money is recovered. As food companies scale through acquisitions, the risk isn’t just external threats, but internal blind spots that can grow faster than oversight keeps pace.
It took more than a decade. It took multiple schemes. And it took the quiet confidence of someone who believed he wouldn’t be questioned.
On January 22, a federal judge sentenced the former senior executive at Mars Wrigley to 63 months in prison for stealing more than $28m from his employer. The sentence closes one of the most significant insider fraud cases to hit a global food company in recent years – and opens a far more uncomfortable conversation about how easily trust can be abused inside complex organisations.
Steed, 59, was also ordered to pay $28.4m in restitution to Mars and $10.3m in back taxes to the IRS. More than $18m has already been seized from accounts he controlled. Additional assets, including a Greenwich, Connecticut, home bought with stolen funds, are now subject to forfeiture or liquidation.
“Justice is served by the imposition of this sentence,” said US Attorney David X Sullivan. “Thanks to the thorough investigative efforts by FBI, IRS-CI and USDA-OIG special agents, Mr Steed’s criminal conduct was quickly exposed. These agents not only identified the money that he stole, they successfully seized millions of dollars that will be returned to the victim company.”
For Mars, the ruling draws a line under a long-running internal breach. For the wider food and beverage industry, it lands as a warning. Not because the company lacked controls. But because it had plenty, but they still weren’t enough.
How the money moved quietly, and for years
According to court documents and statements made in court, Steed’s conduct wasn’t a single deception. It was a set of overlapping schemes that ran from roughly 2011 to 2023, each exploiting a different part of Mars’ financial machinery.
Steed worked remotely from Stamford, Connecticut, and held several roles during his career at Mars Wrigley. His final position – global price risk manager for the Global Cocoa Enterprise – placed him in a niche but powerful corner of the business. He oversaw commodity exposure; dealt with specialist programs; interacted with external counterparties who assumed he spoke for the company.
One scheme centered on the USDA’s Sugar-Containing Products Re-Export Program. In 2016, Steed created a company called MCNA LLC, deliberately echoing the name of a legitimate Mars entity, Mars Chocolate North America. Prosecutors said he then instructed sugar refineries purchasing Mars’ re-export credits to pay MCNA instead. More than $15m flowed into an account he controlled.
“Mr Steed exploited an important USDA program intended to support American exporters to market US agricultural products in international commerce for personal fraudulent gain,” said inspector general John Walk. “The USDA Office of Inspector General is pleased to support the work of our law enforcement partners including the Federal Bureau of Investigation, the Internal Revenue Service – Criminal Investigations Division, US Marshals Service, and the US Attorney’s Office to help deliver justice and protect taxpayer dollars.”
Another scheme tapped into Mars’ financial investments. Mars held shares in Intercontinental Exchange (ICE), the global markets operator that owns the New York Stock Exchange and runs commodities and derivatives trading platforms, and those shares generated regular dividend payments. Beginning in 2017, Steed directed Computershare, the company’s transfer agent, to divert those dividend payments to MCNA, siphoning off more than $700,000.
In 2023, prosecutors said Steed escalated the scheme further. Using a fraudulent letter that appeared to authorize him to trade ICE shares on Mars’ behalf, he triggered the sale of the company’s entire stake. Computershare issued a check for more than $11.3m, which Steed deposited into the same MCNA account.
Alongside all of this ran a more familiar play. From 2013 to 2020, Steed used another company he owned, Ibera LLC, to invoice Mars for services that were never provided. That brought in more than $700,000.
None of it was flashy. None of it looked obviously criminal on its own. Payments moved through legitimate channels; names looked right; programs were real; and the money accumulated slowly. That’s why it lasted.
What the judge focused on
At sentencing, the debate wasn’t just about numbers. It was about mindset.
Steed’s lawyers had urged the court to impose a shorter sentence, arguing that federal guidelines put too much weight on loss figures and too little on restitution. Prosecutors pushed for a tougher outcome, pointing to the scale, duration and deliberate nature of the conduct.
Judge Kari A Dooley made it clear where she stood, saying Steed “viewed himself as somehow above the fight” and describing “a level of entitlement on the part of this defendant that I find really quite disturbing.”
The 63-month sentence still landed well below the highest guideline range but far above what the defense had sought, reflecting a court unwilling to treat the case as a technical accounting failure or a victimless corporate dispute.
“Today’s sentencing is a great example of what happens when the FBI, and our partners at the IRS, USDA-OIG, and the USAO combine to bring our investigative resources to bear on a complex, multi-faceted fraud scheme involving tens of millions of dollars,” said FBI New Haven special agent in charge PJ O’Brien. “Utilizing forfeiture statutes, expert forensic accounting techniques and court authorized search warrants, investigators recovered millions in embezzled funds and ensured that over nine years of back taxes, totaling millions of dollars, would be paid.”
Add IRS Criminal Investigation special agent in charge Thomas Demeo, “Today’s sentencing sends a strong message to all those who think that corporate embezzlement is a victimless crime: we will find you and we will prosecute you to the fullest extent of the law. Steed utilized his position of trust and authority within the Mars corporation to siphon off millions of dollars for his own personal gain and self-enrichment. Not only did he steal from the Mars Corporation, but he also stole from every American family when he chose to conceal his ill-gotten gains from the IRS resulting in less tax revenue that could be used to enhance public welfare.”
Steed, who had been free on a $5m bond, is due to report to prison on March 5.
Why controls didn’t catch it sooner
The Steed case doesn’t point to negligence: it points to structure.
Global food companies are complex by design. They operate across commodities, currencies, government programs and financial instruments that sit far from production lines and brand teams, where oversight is layered, responsibility divided and expertise concentrated.
Steed operated exactly where that concentration lives. Programs like re-export credits don’t attract daily scrutiny: dividend flows are routine; equity transactions are rare but legitimate; vendor invoices are processed at scale. When different teams own different parts of those processes, no single person sees the whole picture.
Remote work likely didn’t help. While hybrid models are now normal, many internal control systems were built around proximity – informal checks, in-person escalation, physical separation of duties. Distance can dull those instincts.
Most importantly, nothing about Steed’s behavior forced attention. There was no sudden wealth, no extravagant spending spree, no obvious anomaly that demanded investigation – the money sat in accounts, moved slowly and blended in, making it the kind of fraud that’s hardest to catch.
The risk that comes with scale
Insider fraud isn’t rare in food and consumer goods. What’s rare is how long it can run undetected.
Employees with authority, access and specialist knowledge don’t need to break systems to exploit them: they just need to understand where scrutiny is light and patience is assumed.
The Steed case shows how multiple small vulnerabilities can align. Trade programs, investment administration and vendor payments all worked as designed, but together they failed.
The 63-month sentence sends a clear signal. Long-running corporate fraud will be punished, even where much of the money is recovered. For food companies, the takeaway is sharper. The biggest risks don’t always come from outside attackers or volatile markets. Sometimes they come from inside – quietly, patiently and wrapped in trust. And when that trust turns toxic, it rarely announces itself. It just keeps going, until someone finally looks closely enough.
Mars Incorporated did not respond to a request for comment by publication time.
The case is United States v Paul R Steed, No. 3:25-cr-00048, US District Court for the District of Connecticut.
