News & Analysis as of

Department of Justice (DOJ) Office of Foreign Assets Control (OFAC)

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Reinforces Focus on Cartels and Transnational Criminal Organizations

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

Husch Blackwell LLP

Week Seventeen in Trade

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CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more

Troutman Pepper Locke

DOJ’s Criminal Division Announces Updates to White-Collar Enforcement and Corporate Policies

Troutman Pepper Locke on

On May 12, 2025, the Head of the Criminal Division (the Criminal Division or Division) at the Department of Justice (DOJ), Matthew R. Galeotti, issued key memoranda to Criminal Division personnel on the Division’s new...more

DLA Piper

US Treasury Takes on Cartels Part Deux: Combating Cartel-Connected Oil Smuggling Schemes

DLA Piper on

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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

The Volkov Law Group

Practical Issues and the New DSP (Part II of III)

The Volkov Law Group on

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding.  The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

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

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

BakerHostetler on

The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

Miller Canfield on

Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Troutman Pepper Locke

Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast

Troutman Pepper Locke on

In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more

BakerHostetler

Weekly Blockchain Blog - April 2025

BakerHostetler on

U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

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

Torres Trade Law, PLLC

Torres Trade Trump Table

The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump’s administration from January 2025 to the present. It focuses on critical areas...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

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

Foley & Lardner LLP on

Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

Jones Day on

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

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on

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

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Dorsey & Whitney LLP

Attorney General Bondi Reorients National Security Enforcement Resources to Focus on Illegal Immigration and Drug Trafficking

Dorsey & Whitney LLP on

Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more

White & Case LLP

DOJ Implements Major Changes to National Security Priorities

White & Case LLP on

On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

Seward & Kissel LLP on

As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

Bracewell LLP on

Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more

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