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Risk Management Department of Justice (DOJ) Cartels

The Volkov Law Group

Episode 377 — Refocusing Due Diligence on Cartel and TCOs

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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

The Volkov Law Group

Episode 377 -- Refocusing Due Diligence on Cartels and TCOs

The Volkov Law Group on

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

The Volkov Law Group

Refocusing Due Diligence on Cartel and TCOs (Part I of II)

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Companies face a dual challenge — the pressing need to unravel their supply chains, and the immediate task of recalibrating due diligence systems to examine potential presence of cartel and transnational criminal...more

J.S. Held

South of the Border Compliance: Enhancing Integrity & Risk Management in Latin American Operations

J.S. Held on

In February 2025, the Trump administration directed a significant shift in the US Department of Justice’s (DOJ) enforcement priorities by announcing a 180-day suspension of new actions under the Foreign Corrupt Practices Act...more

American Conference Institute (ACI)

[Event] Global Anti-Corruption, Ethics & Compliance - June 10th - 11th, New York, NY

ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more

Morrison & Foerster LLP

FTO Designations Heighten Risks for Companies Operating in Latin America / Las designaciones de FTO aumentan los riesgos para las...

Key Takeaways- • Recent Foreign Terrorist Organization (FTO) designations affecting cartels and transnational criminal organizations (TCOs) have equipped the Department of Justice (DOJ) with a powerful source of authority...more

Morgan Lewis

Cartels, TCOs, ‘Instrumentalities of a Government’: Reassessing FCPA Risk Amid Shifting US Enforcement Priorities

Morgan Lewis on

Whether cartels do or do not qualify as “instrumentalities of a government” under current FCPA law or based on the AG’s forthcoming revised FCPA guidance, their entanglement with corrupt officials and influence over local...more

King & Spalding

Recent FTO Designations Raise FCA Liability Concerns for Multinational Organizations

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

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 Volkov Law Group

The Brave New World — Due Diligence to Identify Cartels and TCOs

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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

King & Spalding

State Criminal and Civil Liability for Material Support: How the FTO Designation of Drug Cartels Increases the Risk of State...

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The State Department’s February 20, 2025, designation of specific Mexican drug cartels and Transnational Criminal Organizations (TCOs) as foreign terrorist organizations (FTOs) creates serious new risks for businesses...more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

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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

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

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On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

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

Paul Hastings LLP

Implications for Mexican Banks and Financial Institutions of President Trump’s Designation of Drug Cartels as Foreign Terrorist...

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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

The Volkov Law Group

Antitrust Enforcement and Compliance Programs

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The Department of Justice had a record year in criminal antitrust enforcement. Global enforcement and coordination continues to increase. As a result, global companies face significant antitrust risk from cartel activity. ...more

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