Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
Cornerstone Research Connects: The CAT Judgment in Trucks
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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
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
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
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
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
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 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to...more
The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more
U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more
The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more
On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more
On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more
On April 21, 2015, the Treasury Department’s Financial Crimes Enforcement Network issued a geographic targeting order, an anti-money laundering device focused on trade-based money laundering schemes used by drug cartels,...more