Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
Cornerstone Research Connects: The CAT Judgment in Trucks
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JONES DAY TALKS®: Private Antitrust Litigation in the Netherlands
Antitrust Enforcement and Compliance Programs
Grassley: HSBC Should Face Criminal Charges
The US government announced two major sanctions and related actions against Mexican cartels, first targeting their involvement in timeshare fraud, followed by a broader crackdown on other revenue sources the next day....more
The Trump Administration has repeatedly signaled its prioritization of targeting traffickers of synthetic opioids, especially fentanyl. On January 20, 2025, President Trump signed an Executive Order “creating a process by...more
On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more
The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more
It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more
Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate...more
In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more
Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more
Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more
Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and...more
On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more
In a historic move that signals a new era in the fight against illicit opioid trafficking and money laundering, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued its first-ever...more
The Trump administration remains focused on countering Mexican cartels and other Latin American transnational criminal organizations (TCOs). Since designating eight TCOs as foreign terrorist organizations (FTOs), the...more
In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States,...more
U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns as their governments’ make rapid changes around trade and tariffs and ramp...more
In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more
On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more
FinCEN report reveals threat patterns and trends for financial institutions to monitor - The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury (Treasury) published a Financial Trend Analysis...more
As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more
When assessing your third-party risks, it is important to start with one important division — a company’s supply chain and on the flip side, a company’s distribution chain. Sourcing materials and supply chain links present a...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more
We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more