Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
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Antitrust Enforcement and Compliance Programs
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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
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
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in coordination with the Office of Foreign Assets Control (OFAC), the US Drug Enforcement Administration (DEA), the Federal Bureau of...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
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 February 20, 2025, the State Department designated multiple Mexican drug cartels and Transnational Criminal Organizations (“TCOs”) as foreign terrorist organizations (“FTOs”). At the same time, these groups were designated...more
On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more
The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...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 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
Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...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
This Order declares a national emergency under the International Emergency Economic Powers Act (IEEPA) to designate certain international cartels and other organizations as Foreign Terrorist Organizations or Specially...more