From Corruption to Cartels: A Shifting Focus of DOJ Enforcement for Companies Operating in Latin America

Latin America has long been a critical focus for US prosecutors bringing corporate enforcement matters. In the past decade, in the Foreign Corrupt Practices Act (FCPA)[1] arena alone, the US Department of Justice (DOJ) has brought cases against 35 companies,[2] and prosecuted 96 individuals, resulting in criminal fines in excess of US$10 billion, for bribe conduct centered in Latin America.[3] These numbers account for 41% (corporate prosecutions), 61% (individual prosecutions), and 48% (criminal fines) of all FCPA matters brought by the DOJ over that same time period.[4] Compare that to the fact that Latin America only accounts for 7.3% of the global economy, it is clear that the region plays an outsized role in corporate criminal prosecutions by US prosecutors.[5] In terms of matters that the DOJ has brought since the FCPA’s inception in 1977, Brazil, with 34, and Mexico, with 26, rank number two and three on the corporate enforcement list, only trailing China, with 75—whose economy is almost three times the size of Mexico’s and Brazil’s combined.[6]

Sophisticated companies doing business in the region are well aware of this reality and have spent years building out robust compliance programs to ensure that they stay well outside of the DOJ’s crosshairs. But now that the Trump administration has made it loud and clear that corporate criminal enforcement is not a priority, and enforcement of the FCPA is paused with an uncertain future, companies and their compliance officers are reassessing the risk landscape. And while FCPA risk under the Attorney General Pam Bondi (AG Bondi) might be falling, for companies doing work in Latin America, the Trump administration’s laser focus on cartels and transnational criminal organizations (TCOs) in the region has given rise to a new risk with significant, indeed potentially more severe, consequences.

Indeed, it may be time for chief compliance officers (CCOs) and general counsels (GCs) to swap out Transparency International’s Global Corruption Perceptions Index (CPI)[7] for the Global Organized Crime Index (GOCI),[8] for a better understanding of regulatory risk in the region.

The FCPA Enforcement Landscape Has and Will Continue to Shift Significantly

Since inauguration day, the second Trump administration has issued executive orders and memoranda narrowing the DOJ’s enforcement and investigation priorities, removing or restructuring long-standing DOJ units, and reducing resources and personnel in the DOJ’s Fraud Section. Broadly speaking, the executive orders and memoranda require the DOJ and US Attorneys’ Offices (USAOs) to prioritize violent crime, with a particular focus on cartels and TCOs, with a decreased focus on corporate enforcement actions. This is in stark contrast to prior administrations’ prioritization of combatting white collar crime, with a particular focus on increasing FCPA actions.

These priority shifts began on 20 January 2025, when President Donald Trump issued an executive order designating cartels and other TCOs as “foreign terrorist organizations” (FTOs) and “specially designated global terrorists” (SDGTs) and tasking his administration’s leadership with the “total elimination” of these organizations.[9] Designation of an organization as an FTO or SDGT has significant implications, not the least of which is the threat of steep financial and incarceratory penalties for any individual or company with connections to such designated entities.  Additionally, the designations impose requirements on financial institutions who discover they may be in the possession of funds tied to FTO’s or SDGT’s to block or freeze such funds, report those suspicious transactions to the U.S. government, and possibly turn them over to the authorities.

On 5 February 2025, AG Bondi issued the “Total Elimination of Cartels and Transnational Criminal Organizations” memorandum instructing the DOJ to focus on investigations involving “bribery of foreign officials to facilitate human smuggling and the trafficking of narcotics and firearms.”[10] Notably, the memorandum directed the DOJ’s FCPA Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of Cartels and [TCOs], and shift focus away from investigations and cases that do not involve such a connection.”[11] The memorandum also granted USAOs around the country the ability to unilaterally bring forth FCPA cases in situations where those matters involved cartels or TCOs.[12] Finally, the memorandum directs the Money Laundering and Asset Recovery Section (MLARS), another one of the elite white collar corporate enforcement units of the DOJ, to also “prioritize investigations, prosecutions, and asset forfeiture actions” that target cartels and TCOs.

The corporate enforcement landscape changed dramatically on 10 February 2025, when President Trump issued an executive order pausing all FCPA investigations and enforcement actions for 180 days, with limited exceptions that required AG Bondi’s approval.[13] The executive order also directed AG Bondi to conduct comprehensive reviews of existing and historical FCPA investigations and resolutions to “determine whether additional actions, including remedial measures with respect to inappropriate past FCPA investigations and enforcement actions, are warranted and shall take any such appropriate actions or, if Presidential action is required, recommend such actions to the President.” Finally, the executive order instructed AG Bondi to promulgate new guidelines on FCPA enforcement that will promote and prioritize US interests, US economic competitiveness with respect to other nations, and the efficient use of federal law enforcement resources.

The administration’s shift away from traditional FCPA investigations and enforcement actions will likely not end there. On 25 March 2025, Deputy AG Todd Blanche issued an internal memorandum to DOJ heads proposing sweeping changes to Main Justice and USAOs, including eliminating “duplicative litigation units” including “reducing the number of attorneys assigned to … CRM’s Fraud section focused on FCPA matters[.]”[14]

As a result, current investigations are paused, FCPA Unit attorneys are focusing on other DOJ case priorities, existing and prior FCPA actions are being examined, and federal district courts are questioning how DOJ intends to handle previously indicted FCPA cases.[15]

A Historical Focus on Latin America

The existing investigation and enforcement pause, proposed department and personnel changes, and 180-day timeline for AG Bondi to issue new FCPA guidance have left many questioning what FCPA enforcement will be during the remainder of the Trump administration. However, the administration’s recent actions demonstrate that the FCPA Unit and MLARS will shift towards cartels and TCOs, and includes explicit instructions to USAOs to focus resources on prosecuting these entities, and organizations and individuals who facilitate, support, or do business with the same. Further, the countries and regions facing significant challenges with cartels, TCOs, and corruption are well known by DOJ.

Historically, Latin America has been a major focus of FCPA enforcement, and there are many reasons for this, including: (1) perception that bribes are a part of doing business because of alleged government and law enforcement corruption;[16] (2) financial ties to the United States and the use of the US financial system and public markets; (3) presence of US companies with subsidiaries, joint venture partners, and operations in the region; and (4) close ties between US and Latin American law enforcement authorities including Mexico and Brazil, among others.[17] For example, between 2016 and 2025, four of the top eight countries with improper payments resulting in FCPA investigations and enforcement action were located in Latin America as illustrated in Table 1.[18]

Table 1. FCPA Actions: 2016–2025.

This is not a recent trend, as Latin American countries top the list of all FCPA-related enforcement actions since the statute’s enactment in 1997.[19] This is particularly significant given the size of Latin American countries’ aggregate gross domestic product (GDP) in comparison to countries like China and India as illustrated in table 2.[20]

Table 2. Comparison of FCPA  Actions and Global GDP Rank.

Notably, since the 180-day pause of the FCPA, there have only been two FCPA matters that the DOJ has indicated publicly that it will continue to prosecute—and one of those involves bribe conduct in Latin America (Honduras).[21]

Corruption Prosecutions Being Replaced by Cartels and TCOs

Assessing business opportunities and relationships in foreign countries is not new for CCOs and GCs. This analysis has traditionally focused on a foreign country’s level of corruption, and the first stop for CCOs and GCs to identify that risk was often Transparency International’s CPI.[22] While corruption is still a vitally important consideration, under the new prosecutorial priorities described above, perhaps the new first stop for in-house counsel and business leaders alike should be the “Global Organized Crime Index”[23] (GOCI) when assessing the risk of operating in Latin America.

Notably, according to the GOCI, three of the top 10 countries with the highest levels of organized crime are in Latin America including Colombia at two, Mexico at three, and Paraguay at four. When expanded to the top 20 countries, Latin America makes up six of the countries with the addition of Ecuador at 11, Honduras at 13, and Panama at 17. When expanded to the top 30, Latin American makes up nine of the countries with the addition of Brazil at 22, Venezuela at 24, and Guatemala at 26.  In other words, while Latin America only accounts for less than 8% of global GDP,[24] its countries account for 30% of the organized crime leaderboard.

It is no accident that the ten cartels and gangs that have been designated as “FTOs” and “SDGTs” since the 20 January 2025, executive order are all based in the Americas, with eight scattered throughout Latin America and two located in Haiti.[25]

At a recent conference, the head of the DOJ’s Criminal Division provided support for the Department’s shift in focus to TCOs, saying: “The deadly activities of cartels and TCOs are enabled by international money laundering organizations and other financial facilitators. Illicit financial and logistical networks undermine our national security by facilitating sanctions evasion by hostile nation-states and terror regimes.” [26]

Given the changes in prosecutorial priorities and the refocus on cartels and TCOs, companies’ prior practices to identify and limit involvement with corrupt individuals and entities are likely insufficient. GC’s and CCO’s must now invest resources to identify whether their foreign partners are associated with a cartel, FTO or TCO, and they need to build out more comprehensive compliance safeguards when operating in markets where the existence of these criminal organizations is more prevalent.

Increased Civil and Criminal Liability Under Terrorism Statutes

Beyond shifting priorities, classifying cartels as FTOs also expands the available statutes and corresponding criminal and civil penalties when investigating and prosecuting companies.  Some of these statutes allow US regulators to bring claims against entities with no formal ties to the United States, to seek significant prison sentences for culpable individuals, and provide additional avenues to seize assets from those providing material support in the United States and abroad—in other words, prosecutors now have more powerful weapons with longer ranges at their disposal.[27]

On February 5, 2025, AG Bondi issued a memorandum titled, “General Policy Regarding Charging, Plea Negotiations, and Sentencing.”[27] This memorandum instructs all DOJ personnel to prioritize the “most serious, readily provable offense[s]” that are “punishable by death where applicable, and offenses with the most significant mandatory minimum sentences … and the most substantial recommendation under the Sentencing Guidelines.” These memoranda instruct US prosecutors to (1) investigate and prosecute cartels and those supporting cartels, and (2) to seek the highest possible penalties under the sentencing guidelines for those matters. The DOJ’s Criminal Division has interpreted this statement as a mandate to work “relentlessly to eliminate cartels and [TCOs], dismantle human smuggling operations, curb the flow of fentanyl and other dangerous drugs, and neutralize child predators and violent criminals, including by securing significant charges and prison sentences against the worst criminal actors.” [26]

Most relevant to the new focus on investigating and prosecuting links to cartels and FTO’s is 18 U.S.C. § 2339(A) and (B). Under this statute, DOJ may pursue companies criminally and civilly for providing “material support” to an FTO. 18 U.S.C. § 2339(A) provides criminal liability for providing material support or resources in support of an act of terrorism. 18 U.S.C. § 2339(B) provides criminal liability for providing material support or resources to an FTO.  Material support is broadly defined as providing an FTO with any property (tangible or intangible) or services, including currency, financial services, lodging, personnel, or transportation.[29] This means that a company, and its personnel, could be held criminally or civilly liable for unknowingly interacting with or supporting a cartel or TCO through simple transactions with, or providing services for, foreign individuals or companies who are associated with an FTO; companies with hidden cartel or TCO beneficial ownership; or entities engaged in paying cartels for operating safely in their regions.

Critically, material support for a cartel or TCO, even if inadvertent, could result in staggering criminal and civil penalties under both statutes. Under 18 U.S.C. 2339(A), defendants can receive significant monetary penalties and even larger individual prison sentences—a maximum of 15 years for general material support and life imprisonment in the event of death. Under 18 U.S.C. 2339(B), defendants could be forced to pay treble damages as well as attorneys’ fees and costs, and face individual prison sentences—a maximum of 20 yearsfor general material support and life imprisonment in the event of an act that results in death. Comparatively, under the FCPA, while defendants can receive significant monetary penalties, the maximum individual prison sentence is capped at five years.[30]

Two historical cases brought by DOJ may provide a road map of what such a prosecution may look like. In 2007, Chiquita Brands International Inc. plead guilty to engaging in transactions with an FTO after the company paid protection payments to Autodefensas Unidas de Colombia over a six-year period. Despite Chiquita voluntarily disclosing these payments, the company received a US$25 million criminal fine, was required to implement and maintain effective compliance and ethics programs, and was placed on five years’ corporate probation.[31] More recently, in United States v. Lafarge, the DOJ charged Lafarge, the world’s largest cement manufacturer based in France, and its Syrian subsidiary for paying nearly US$6 million in protection fees to Islamic State of Iraq and al-Sham (better known as ISIS), and the al-Nusrah Front between 2013 and 2014.[32] As a result, Lafarge was placed on probation and subjected to criminal fines and forfeiture totaling US$778.78 million. Beyond the DOJ prosecution, Lafarge and a number of its former executives who were directly involved in the FTO payments are under criminal investigation and prosecution in France.[33]

For companies with operations in Latin America, or looking to expand into the region, this analysis has become even more complex because the priority FTO cartels described above have significant control over local business and government operations and are engaged in the type of rampant organized criminal behavior that 18 U.S.C. § 2339(A) and (B) are intended to address.[34] Notably, a 2024 survey by the American Chamber of Commerce in Mexico found that 43% of businesses in Mexico reported that organized crime is a significant operational risk in Mexico, and 12% said they had ceded partial control of their sales, distribution or pricing to organized criminal groups.[35] If companies attempt to scrutinize the vendors and customers with whom they contract in Latin America, they may face backlash from FTOs and TCOs that endanger their employees.[36] But if they acquiesce or fail to properly investigate, they could be criminally liable. This challenging set of circumstances requires companies operating in Latin America to develop a new focus within their compliance programs.

Considerations for Entities Currently Operating in or Considering Expanding into Latin America

Cartel and TCO-Focused Due Diligence on Third Parties and Merger Targets Is Necessary

All companies must view themselves as a potential priority under these new enforcement priorities of the Trump administration and the Bondi DOJ if operating in Latin America. Recognizing this increased focus on cartels and TCOs, companies should significantly step up due diligence efforts with respect to both new and current relationships. Any business operating in Latin America needs to scrutinize employees, vendors, agents, customers, and even local governments where the cartels may be so embedded that licensing payments are essentially bribes to the regional cell. When entering into a new business relationship, companies should: (1) conduct background checks and check government-maintained lists from US regulators (Office of Foreign Assets Control, Treasury Department, Bureau of Industry and Security), and any lists published by the national or local government; (2) conduct planned and unplanned site visits to meet with personnel and see day-to-day business operations; (3) and seek out corporate and leadership references from trusted industry participants and regulators.

Draft New, and Assess Existing, Third-Party Agreements in Known Cartel or TCO Territories

Next, companies must drastically rethink the content of new or existing agreements with third parties. Beyond the obvious anti-bribery and anti-corruption clauses, these agreements should include: (1) clear descriptions of services to be provided; (2) requirements to investigate potential cartel or TCO associations uncovered in background checks; (3) robust audit clauses to aid in potential future investigations; (4) notification requirements for any changes to beneficial ownership and structure and ability to revise or terminate agreements if these changes are problematic; and (5) notification requirements if third parties are solicited or otherwise approached by a cartel or TCO.

Implement Robust Internal Policies, Procedures, and Training to Prevent, Detect, and Respond

Finally, companies must implement robust policies, procedures, and training to proactively prevent, detect, and respond to any conduct that may be considered material support of a cartel or TCO. First, companies should codify the due diligence policies and procedures described above. Second, companies must train their employees to act upon these policies and procedures, with a particular focus on identifying red flags, escalating internally, and safe refusal to comply with or engage in coercive practices, as there are real physical safety concerns implicated when cartels and TCOs are involved, beyond the norm for anti-corruption spaces. Third, companies should identify and train a few key personnel to assess internal reports or concerns about potential encounters with a cartel or TCO and determine if external reporting is necessary.[37] Fourth, companies should expand awareness of what types of direct and indirect conduct constitutes “material support”—including hiring associated individuals, payments to local charitable organizations, providing information, allowing use of company vehicles or trade routes, and failing to recognize signs of human trafficking. Fifth, companies should implement physical and technological barriers to protect their employees and business operations—including financial controls requiring the purpose of payments to be contemporaneously and clearly documented and reviewed, as well as expectations for where and when to engage with third parties. Sixth, companies should proactively prepare for increased investigative inquiries by running tabletop exercises to stress test their policies, procedures, and crisis management systems.

While companies that choose to operate in Latin American now must bear the cost of compliance, the initial expense of setting up adequate measures and continued efforts spent on monitoring and maintenance are far outweighed by the benefits of doing business in booming economies in Latin American states. Now that the U.S. government has shined a light on cartels, companies have the opportunity to create robust compliance programs that will yield great rewards in the future.

Knowledge Is Power

Despite ongoing uncertainty about how the DOJ is going to approach corporate criminal enforcement, and whether the FCPA will be a significant tool used by the DOJ over the next few years, one priority is crystal-clear: investigating and prosecuting cases that involve cartels and TCOs, particularly those with ties to Latin America.  Indeed, the classification of certain cartels as FTO’s by the US government means companies operating in Latin American will be under the microscope.

Companies should be concerned about this increased scrutiny because DOJ’s tools to combat alleged support of terrorism under 18 U.S.C § 2339 are hefty and could result in crippling criminal fines and decades-long prison sentences. Further, while many things are changing, the DOJ will continue its prior practice of not being forgiving of companies who claim ignorance of the enforcement landscape.

In response, companies can and should proactively examine their foreign partnerships, revise existing anti-corruption and compliance policies, and implement robust zero-tolerance policies for engagement with cartels and TCOs, including educating their employees on these new expectations, and establishing clear internal channels for reporting concerning conduct.  Put simply, companies operating in foreign jurisdictions with cartels and TCOs, particularly in Latin American where certain organizations are formally designated as FTOs (e.g., Mara Salvatrucha – MS-13 and Tren de Aragua – TdA), need to prioritize new policies and procedures that position their business operations to succeed while avoiding any conduct that would result in DOJ cartel and TCO investigations and enforcement actions.

 Endnotes

[1] The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (“FCPA”), was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business.

[2] The Stanford Law School Foreign Corrupt Practices Act Clearinghouse annually reports every FCPA enforcement action. These numbers are an aggregation of the individual FCPA enforcement data reported here: Stanford Law School Foreign Corrupt Practices Act Clearinghouse, https://fcpa.stanford.edu/enforcement-actions.html. This number includes criminal charges, and alternative dispute resolutions such as deferred prosecution agreements and non-prosecution agreements.

[3] Ibid.

[4] From 2015 to 2025, 35 of 86 corporate actions, 96 of 157 individual actions, and $10,224,560,160 of $21,444,454,570 in criminal fines involved Latin America. United Nations Economic Commission for Latin America and the Caribbean (ECLAC). 30 May 2024, https://www.cepal.org/en/news/latin-america-and-caribbean-represent-73-global-gdp.

[5] “Latin America and the Caribbean represent 7.3% of global GDP.” Ibid.

[6] “GDP based on PPP, share of world.” International Monetary Fund. 2025, https://www.imf.org/external/datamapper/PPPSH@WEO/EU/CHN/USA (showing that the People’s Republic of China makes up for 19.29% of GDP, while Mexico is 1.67% and Brazil is 2.39% of GDP).

[7] “Corruption Perceptions Index,” Transparency International. 2024, https://www.transparency.org/en/cpi/2024.

[8] “Global Organized Crime Index, 2023.” Global Initiative on Transnational Organized Crime (GI-TOC). 2023, https://ocindex.net/.

[9] Exec. Order No. 14157, 90 Fed. Reg. 8439. 20 January 2025, https://www.federalregister.gov/documents/2025/01/29/2025-02004/designating-cartels-and-other-organizations-as-foreign-terrorist-organizations-and-specially.

[10] “Total Elimination of Cartels and Transnational Criminal Organizations.” US Department of Justice. 5 February 2025, https://www.justice.gov/ag/media/1388546/dl?inline.

[11] The memorandum provides examples such as “bribery of foreign officials to facilitate human smuggling and the trafficking of narcotics and firearms.” Ibid.

[12] Justice Manual § 9-47.110, US Department of Justice. 2024.

[13] “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” The White House. 10 February 2025, https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/. Previously, any prosecution of the FCPA brought by the DOJ had to be led by the DOJ’s FCPA Unit.  Under the new guidance, USAOs no longer need to involve and seek approval from the DOJ’s FCPA Unit when opening or charging an FCPA case where cartels or TCOs are involved.  The requirement is only that the USAO give the FCPA Unit 24-hours’ notice before bringing forth FCPA charges.

[14] “Soliciting Feedback for Agency Reorganization Plan and RIF.” US Department of Justice. 25 March 2025, https://democrats-judiciary.house.gov/uploadedfiles/doj_memo_1.pdf.

[15] Austin Cope, “Ex-Cognizant execs get dismissal motion from newly sworn-in US attorney.” Global Investigations Review. 2 April 2025, https://globalinvestigationsreview.com/just-anti-corruption/article/ex-cognizant-execs-get-dismissal-motion-newly-sworn-in-us-attorney.

[16] Op. Cit., Transparency International at Note 6.  Many of the more prominent economies in Latin America are ranked poorly in the CPI.  For example, some of the most significant economies in Latin America are ranked in the bottom half of the 180 countries included in the index: Colombia (92), Argentina (99), Brazil (107), Peru (127), and Mexico (140).

[17] “2022 FCPA Year in Review.” Stanford Law School Foreign Corrupt Practices Act Clearinghouse. 2022, https://fcpa.stanford.edu/fcpac-reports/2022-fcpa-year-in-review.pdf.

[18] “Location of Improper Payments, 2016-2025.” Stanford Law School Foreign Corrupt Practices Act Clearinghouse,  https://fcpa.stanford.edu/assets/img/carrousel/01_locations_of_improper_payment_20250331.png.

[19] “Location of Misconduct Alleged in FCPA-Related Enforcement Actions (by FCPA Matter).” Stanford Law School Foreign Corrupt Practices Act Clearinghouse,  https://fcpa.stanford.edu/statistics-analytics.html?tab=8.

[20] “GDP (current US$).” World Bank Group, 2023, https://data.worldbank.org/indicator/NY.GDP.MKTP.CD?most_recent_value_desc=true.

[21] Government’s Notice of Authorization to Proceed (4/11/2025), ECF No. 123, United States v. Zaglin et. al., No. 1:23-CR-20454-JB (S.D. Fla. 2023).

[22] Op. Cit., Transparency International at Note 7.

[23] Op. Cit., Global Organized Crime Index at Note 8.

[24] Op. Cit., ECLAC at Note 4. 

[25] The ten designated organizations are: TdA, MS-13, Cártel de Sinaloa, Cártel de Jalisco Nueva Generación (CJNG), Cártel del Noreste, La Nueva Familia Michoacana, Cártel de Golfo, Cárteles Unidos, Viv Ansanm, and Gran Grif. DOJ’s immediate priority appears to be the TdA, MS-13, Cártel de Sinaloa, and CJNG organizations. TdA “originated in Venezuela with cells in Columbia, Peru, and Chile, with further reports of sporadic presence in Ecuador, Bolivia, and Brazil.” TdA is well known for its criminal extortion businesses, bribing public officials, and other serious criminal activity such as kidnapping, assassinations, and attacking US law enforcement. MS-13 is currently based in Central America, including El Salvador, Honduras, Guatemala, and Mexico. MS-13 is known for using “public displays of violence to intimidate civil populations to obtain and control territory…, manipulat[ing] the electoral process in El Salvador[,]” and conducting “violent attacks, including assassination and the use of IEDs…… and drones” against government officials. Cártel de Sinaloa is located in Sinaloa, Mexico and is “one of the world’s most powerful drug cartels” who uses “violence to murder, kidnap, and intimidate civilians, government officials, and journalists.” CJNG is located in “nearly every part of Mexico” and is involved in drug trafficking, extortion, smuggling, and the weapons trade. CJNG has also coordinated attacks on military and police, and assassinations or attempted assassinations of government officials,  https://www.state.gov/designation-of-international-cartels/.  “Designation of International Cartels.” US Department of State. 20 February 2025, “Designation of Viv Ansanm and Gran Grif.” US Department of State. 2 May 2025, https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/.

[26] “Head of the Criminal Division, Matthew R. Galeotti Delivers Remarks at SIFMA’s Anti-Money Laundering and Financial Crimes Conference.” US Department of Justice. 12 May, 2025, https://www.justice.gov/opa/speech/head-criminal-division-matthew-r-galeotti-delivers-remarks-sifmas-anti-money-laundering.

[27] 18 U.S.C. § 2339(A) & (B).

[28] “Department Charging and Sentencing Policy Memorandum.” US Department of Justice 10 May 2017, https://www.justice.gov/ag/media/1388541/dl?inline.

[29] 18 U.S.C. § 2339(A)(b).

[30] 15 U.S.C. § 7dd-2(g).

[31] “Chiquita Brands International Pleads guilty to Making Payments to a Designated Terrorist Organization and Agrees to Pay $25 Million Fine.” US Department of Justice. 19 March 2007, https://www.justice.gov/archive/opa/pr/2007/March/07_nsd_161.html.

[32] “In Justice Department’s First Corporate Material Support for Terrorism Prosecution, Lafarge S.A. and its Syrian Subsidiary Admit Revenue-Sharing Agreement with ISIS and Agree to Pay $778 Million in Fines and Forfeiture.” US Department of Justice. 18 October 2022, https://www.justice.gov/archives/opa/pr/lafarge-pleads-guilty-conspiring-provide-material-support-foreign-terrorist-organizations.

[33] Tassilo Hummel, “Lafarge can be charged with ‘complicity in crimes against humanity, French court says.” Reuters. 16 January 2024, https://www.reuters.com/business/lafarge-can-be-charged-with-complicity-crimes-against-humanity-over-syria-plant-2024-01-16/.

[34] See “Mexico Travel Advisory.” US Department of State. 6 September 2024, https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/mexico-travel-advisory.html(explaining that “[v]iolent crime—such as homicide, kidnapping, carjacking, and robbery—is widespread and common in Mexico” as a result of “[t]ransnational criminal organizations” and “gangs”);“Colombia Travel Advisory.” US Department of State. 2 January 2024, https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/colombia-travel-advisory.html (encouraging travelers to “[r]econsider travel due to crime and terrorism”).

[35] “Sondeo de Seguridad Empreserial 2024 [Corporate Security Survey 2024].” American Chamber of Commerce of Mexico. 2024,  https://amcham.org.mx/files/Envios/Eventos24/Sondeo/KitAliados/10o_Sondeo_de_Seguridad_Empresarial_AMCHAM.pdf.

[36] Sam Fry, “Corporate investigators in Mexico face ‘absolutely frightening’ cartel risk.” Global Investigations Review. 4 April 2025, https://globalinvestigationsreview.com/just-sanctions/article/corporate-investigators-in-mexico-face-absolutely-frightening-cartel-risk.

[37] This external reporting could include the DOJ’s Criminal Division general online reporting form or through the DOJ’s Corporate Whistleblower Program. “Criminal Division Corporate Whistleblower Awards Pilot Program.” US Department of Justice. 1 August 2024, https://www.justice.gov/criminal/criminal-division-corporate-whistleblower-awards-pilot-program. The DOJ has directed the language of the pilot program’s documentation to include tips related to “[v]iolations by corporations related to international cartels or transnational criminal organizations, including money laundering, narcotics, Controlled Substances Act, and other violations” in the list of subject areas for which whistleblowers could be rewarded when tips lead to asset forfeiture. DOJ Memorandum, “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime.” US Department of Justice. 12 May 2025, https://www.justice.gov/criminal/media/1400046/dl?inline.