Cartels Thrive on Corruption, Not Just Drug Trafficking

On his inauguration day, President Trump signed Executive Order 14157, designating drug cartels and other criminal groups as foreign terrorist organizations. This order paved the way for more permissive targeted bombings against cartel members abroad.[1] Pursuant to this executive order, then-Attorney General Pam Bondi issued a Department of Justice memorandum in February 2025 on “the total elimination of cartels and transnational criminal organizations,” setting directives to end the flow of fentanyl into the United States.[2]

The Trump administration’s strategy to eliminate drug cartels has, since then, predominantly revolved around military action. In March 2025, Secretary of Defense Pete Hegseth circulated an interim guidance document instructing the US military to adopt a more assertive role in combating drug trafficking.[3] Then, in July 2025, President Trump reportedly signed a directive to the Pentagon providing an official basis for direct military operations against cartels at sea and on foreign soil.[4]

Following Trump’s unprecedented order, the US government launched military strikes on alleged drug-smuggling boats in the Caribbean and the eastern Pacific,[5] which have continued ever since. President Trump claimed that the strikes stymie fentanyl trafficking,[6] even though illicit fentanyl comes via Mexico, not on boats through the Caribbean.[7] In March 2026, the US military conducted a joint operation with Ecuadorian forces in Ecuador against cartels labeled as terrorist organizations, marking the first US ground military operation against such groups in the region.[8]

That same month, the Trump administration unveiled its flagship initiative for the region, the Shield of the Americas, framed as a multinational coalition against drug cartels. Countries such as Mexico, Colombia, and Brazil were conspicuously absent from the initiative, despite their indispensability to counternarcotics efforts. Even more significantly, the Shield of the Americas frames anti-trafficking exclusively in military terms.[9] President Trump argued that “the only way to defeat these enemies is by unleashing the power of our militaries,” drawing a comparison with the war against the Islamic State.[10] However, unlike terrorist groups, drug cartels are deeply entrenched in financial systems, the broader political economy, and even within state institutions.

Military strikes against drug cartels provide an effective spectacle for the political base and give the impression that decisive actions are being taken against the drug epidemic. However, they do little to address the structural causes that sustain the cartels, such as institutional weakness, systemic corruption, and impunity. Moreover, not only can military strikes not single-handedly solve the drug crisis, but they are often even counterproductive.

Why militarization fails to dismantle drug cartels?

The White House favors the kingpin strategy, which aims to remove those at the top of the drug cartel hierarchy in an effort to dismantle criminal organizations. The strategy was pursued in Colombia and praised for its role in dismantling the Medellín and Cali cartels. Nevertheless, it has not made a dent in cocaine trafficking, which has continued to increase to record highs since Pablo Escobar was killed in 1993.[11] Plan Colombia, the leading US-backed military deployment in the Americas to combat Colombian drug cartels, has failed to eradicate the country’s drug trafficking networks.[12] Furthermore, the kingpin strategy is linked to the emergence of smaller groups, more decentralization, and, by extension, a more complex conflict.[13] The fragmentation of Colombia’s criminal landscape has notably made President Gustavo Petro’s “total peace” plan impracticable, requiring him to negotiate with myriad criminal groups operating in the country.[14]

Criminal group fragmentation resulting from the kingpin strategy is particularly clear in Mexico. The Guadalajara Cartel, which established itself as the first large-scale drug trafficking organization in the country in the 1980s, splintered into the Sinaloa, Sonora, Tijuana, and Juárez Cartels once its leader, Miguel Ángel Félix Gallardo, was arrested in 1989.[15] The widespread violence stemming from this more fractured criminal landscape pushed President Felipe Calderón to declare war on drug cartels after assuming office in 2006, with US backing under the Mérida Initiative. Many top cartel leaders were arrested or killed, exacerbating the breakup of cartels into smaller factions. As a result, several new criminal organizations emerged, along with a more complex web of conflict and an increasing number of violence hotspots. These new groups are heterogeneous and localized, which makes any uniform strategy to combat them unrealistic. Additionally, they have become deeply entrenched within local governments and institutions, more so than the criminal organizations from which they originated.[16]

Calderón’s successor, President Enrique Peña Nieto, did not reverse this militarized approach, contrary to expectations. President Andrés Manuel López Obrador also did not meaningfully move away from the militarization of public security, despite his promise to do so.[17] Consequently, in the space of ten years, the homicide rate in Mexico has more than tripled, and the number of criminal groups has more than doubled to over 200, while drug trafficking has only intensified.[18] Furthermore, the cartels have acquired an arsenal comparable to that of armed forces.[19] Tellingly, nearly 80% of the weapons seized originate from the United States, meaning that the country is indirectly arming the cartels it seeks to combat.[20]

Regardless of the obvious shortcomings of the military-centered strategy, the Trump administration has pressured President Claudia Sheinbaum to take on cartels head-on.[21] Mexico eventually caved to Washington’s demands and carried out an operation in February 2026 against the Cártel Jalisco Nueva Generación (CJNG). The CJNG emerged in 2010 as an offshoot of the Sinaloa cartel following the elimination of key cartel leaders by Mexico[22] and has come to dominate the illicit fentanyl market.[23] The operation led to the killing of CJNG leader Nemesio Oseguera Cervantes, known as “El Mencho.” The group retaliated by unleashing a wave of indiscriminate violence across 20 Mexican states for several weeks.[24]

Two months later, Mexican authorities arrested El Mencho’s designated successor, Audias Flores Silva, nicknamed “El Jardinero,” signaling a return to the kingpin strategy as Mexico’s security policy.[25] Yet, neither of these operations has meaningfully disrupted CJNG’s operations, and the cartel has continued to expand.[26] Signs of internal tensions related to succession, as well as risks of fragmentation, have also begun to appear within the CJNG.[27]

Why anti-corruption is essential, and yet overlooked?

Bombing drug cartels will not bring about their total elimination, let alone resolve the drug epidemic. In reality, the fentanyl epidemic in the United States is a three-tiered problem: sourcing and supply (e.g., China); fabrication, shipment, and distribution (e.g., cartels); and consumption (i.e., domestic demand).[28] Targeting the middle node, thus, misses the forest for the trees. A more effective approach would be to address what connects these nodes: corruption.

Corruption is present at every stage of illicit supply chains. It enables the acquisition, transport, laundering, and sale of illicit goods. Transnational criminal organizations, therefore, need corrupt accomplices, both in the public and private sectors, to carry out their activities.[29] In fact, an unintended consequence of the war against drug trafficking is that corruption has become even more critical for the operation of criminal organizations.[30] This is particularly true as modern criminal organizations are more decentralized and rely on vast networks to pursue criminal objectives.[31]

Since corruption is essential to maintaining the flow of illicit drug shipments, criminal organizations are constantly trying to corrupt officials at all levels responsible for enforcing drug laws. Accordingly, the mechanisms and initiatives created to combat the drug trade tend to be sabotaged by corruption.[32]

Local civil servants often face the “plata o plomo”—”silver or lead”— dilemma, which induces them to become complicit with bribes for fear of violent reprisals. This tactic of intimidation has perpetuated corruption within Mexican authorities and hampered operational coordination between the United States and Mexico.[33] In sum, policies that do not simultaneously address corruption and organized crime end up being ineffective or even generate unintended adverse effects.[34]

However, anti-corruption has been largely sidelined by the Trump administration. Shortly after taking office, Trump issued Executive Order 14209 freezing investigations and enforcement actions under the Foreign Corrupt Practices Act, the United States’ signature anti-bribery law, pending updated guidelines that would “prioritize American interests.”[35] In the supporting fact sheet, the White House claimed that the FCPA law harms American businesses. Yet, nine of the ten largest fines imposed under the FCPA were levied against non-US companies.[36]

Furthermore, the FCPA has improved business practices for both US and foreign companies. It inspired the OECD Anti-Bribery Convention, which cemented the criminalization of foreign corrupt payments as an international legal requirement.[37] As a result, several major Latin American economies, including Brazil, Colombia, and Mexico, strengthened their anti-corruption laws and corporate compliance requirements.[38] Enhancing legal frameworks yielded visible achievements, as seen with the Lava Jato anti-corruption probe in Brazil, which led to more than 200 convictions for crimes ranging from money laundering to drug trafficking.[39] FCPA enforcement has gained significant traction in the Americas to a degree unmatched elsewhere.[40]

In June 2025, DOJ issued new FCPA guidelines ordering investigations to prioritize US national security and economic interests, with a particular focus on criminal cases involving cartels or transnational criminal organizations, and to “shift focus away from cases that do not involve such a connection.”[41] Since Trump’s pause, the FCPA unit within the Securities and Exchange Commission (SEC) has been disbanded, and the one within DOJ has been reduced by a third.[42] The narrowing of FCPA enforcement measures and the closure of nearly half of active FCPA investigations resulted in only 6 FCPA enforcement actions in 2025. This was a sharp reduction from the 22 cases filed in 2024 and the lowest number since 2006.[43]

Moreover, at the bottom of the February 2025 DOJ memorandum was the announcement of the dissolution of the Kleptocracy Team and the transfer of its resources to the elimination of cartels and transnational criminal organizations. The Kleptocracy Team was launched in 2010 to investigate the laundering of corruption proceeds through the United States by foreign officials and to support other countries’  corruption investigations with a link to the US financial system. It had uncovered cases of grand corruption involving hundreds of millions of dollars and ensured that the proceeds of foreign corruption were not laundered through the US financial system.[44]

The Kleptocracy Team developed institutional expertise in prosecuting such crimes over its 15 years of existence, which cannot be easily reinstated.[45] More broadly, DOJ has retreated from investigations into money laundering, foreign bribery, and public corruption.[46] The Public Integrity Unit, responsible for combating political corruption, has likewise been gutted.[47] At the same time, DOJ’s prosecution capabilities have been redirected from international financial crimes to cartel and immigration-related crimes. Tellingly, during President Trump’s first six months in office, DOJ closed more than 23,000 criminal cases, using its resources to prosecute immigration cases while drug offenses and corruption crimes received less attention.[48]

Why anti-corruption cannot be limited to cartels?

In light of the new law enforcement guidelines, the Trump administration could argue that anti-corruption efforts have not been abandoned but only narrowed to target drug cartels specifically. In this sense, the administration would be combating the drivers of drug trafficking even more actively. Yet, this argument reflects a misreading of corruption dynamics.

In the Americas, pervasive institutional fragility and corruption contribute to organized crime. Structural corruption has become so entrenched that criminal networks operate with relative impunity. Organized crime groups operate beyond traditional illicit markets, embedding their criminal activities into legitimate financial and political systems.[49] As such, they thrive within and through the state’s institutional failures.[50]

In this context, corruption is often perceived as a consequence of organized crime. However, research suggests that it is more often a cause. It constitutes the primary enabler of criminal activities, thereby making the functioning of criminal enterprises dependent on it.[51] Therefore, without strong social norms against corruption, policies aimed at combating organized crime are useless. The root of the problem lies in the widespread “culture of corruption” in society, which creates an environment conducive to criminal collusion. For this reason, the emphasis should be placed on uprooting systemic corruption in society as a means to unravel the corrupt networks on which drug cartels thrive.[52]

With this policy implication in mind, it becomes clear that the Trump administration has acted to its own detriment in fighting drug cartels by hollowing out US anti-corruption frameworks. The administration has shown a lack of interest in combating corruption taking place abroad. The newly established Anti-Corruption Center within USAID, for instance, did not survive the sweeping dismantling of the agency.[53] Sustaining this momentum, the White House disbanded the office at the State Department in charge of implementing the first US Strategy on Countering Corruption, adopted in 2021.[54] Likewise, the sections dedicated to corruption in foreign governments were removed from the State Department’s annual human rights report.[55]

In early 2025, the Treasury Department suspended the enforcement of the Corporate Transparency Act, designed to combat money laundering through shell companies.[56] This decision appeared to contradict the administration’s policy of total elimination of drug cartels, given that numerous Florida-registered companies had been identified as having ties to transnational criminal organizations such as Brazil’s Primeiro Comando da Capital.[57]

Perhaps more strikingly, the administration dissolved DOJ’s National Cryptocurrency Enforcement Team and closed investigations into fraud cases unrelated to cartel financing. The SEC has dropped numerous high-profile pending cases against cryptocurrency entities.[58] On the whole, the administration’s easing of crypto sector regulations opens the door to illicit finance and money laundering by cartels.[59] The increasing accessibility and liquidity of cryptocurrencies have contributed to an estimated $82 billion in illicit proceeds being laundered in 2025.[60] Drug cartels have integrated cryptocurrencies into their laundering operations to purchase precursor chemicals from Chinese suppliers, thereby circumventing traditional financial scrutiny.[61]

At the strategic level, the administration’s National Security Strategy makes no mention of curbing corruption in the Western Hemisphere.[62] Combating corruption and money laundering is also conspicuously absent from the priorities of the recently released Counterterrorism Strategy, which focuses on eliminating drug cartels in the Western Hemisphere.[63]

Furthermore, President Trump has exercised his pardon and sanctions relief powers in a manner that sends the wrong signal about his administration’s tough stance on crime. Upon taking office, President Trump pardoned Ross Ulbricht, who was convicted of running an online drug marketplace.[64] In October 2025, he pardoned Changpeng Zhao, the former CEO of Binance, who was indicted for deliberately failing to implement an effective anti-money laundering program on the cryptocurrency exchange platform.[65] Then, in December 2025, President Trump granted clemency to former Honduran President Juan Orlando Hernández, who was extradited to the United States in 2022 and sentenced to 45 years in prison for state-sponsored drug trafficking.[66] The Treasury Department also lifted sanctions from former Paraguayan President Horacio Cartes in October 2025.[67] Cartes was sanctioned in 2023 for corruption during his administration and was suspected of having ties to Hezbollah, designated as a terrorist organization by Washington.[68] By and large, the Trump administration has scaled back corruption-related sanctions and increasingly lifted existing measures.[69]

The path forward

Anti-corruption cannot be limited to drug cartels. It needs to encompass the entire society in which drug cartels arise. Corruption is, in and of itself, a cause of organized crime. Therefore, corruption linked to organized crime cannot be dealt with in isolation. Systemic corruption is the problem. As such, Washington must address corruption systematically to effectively stifle cartels. The rampant culture of corruption across the Americas is the oxygen that sustains criminal organizations.

This policy lesson implies that reinstating anti-corruption as a cornerstone of US foreign policy will make America safer. A counternarcotics strategy solely grounded in a militarized response privileges short-term, dramatic actions at the expense of long-term success. Such an approach will not only fail to curb drug trafficking but also contribute to a more fragmented and complex criminal landscape. The United States should instead focus on promoting strong social norms against corruption in the region.

Recently, the Trump administration has taken some positive steps to bring the drug–politics nexus back into the spotlight by signaling an upcoming anti-corruption campaign targeting corrupt Mexican officials.[70] The White House has notably accused ten officials from the state of Sinaloa, including the governor and member of the ruling MORENA party, Rubén Rocha, of colluding with drug cartels.[71] It is noteworthy because drug cartels have operated with total impunity for decades largely thanks to the corruption and collusion of Mexican police, judges, and politicians.[72]

Holding foreign leaders and officials accountable for corruption can be a first step toward combating the systemic corruption that has allowed cartels to flourish. However, this effort must not become a partisan undertaking. Furthermore, it must be accompanied by a reinvigorated commitment to financial oversight and investigative enforcement to ensure that the US financial system is not used to launder illicit funds and that corruption does not proliferate unchecked abroad.

Endnotes

[1] “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The White House, Presidential Actions. 20 January 2025, https://www.whitehouse.gov/presidential-actions/2025/01/designating-cartels-and-other-organizations-as-foreign-terrorist-organizations-and-specially-designated-global-terrorists/.

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

[3] Alex Horton and Hannah Natanson, “Secret Pentagon Memo on China, Homeland Has Heritage Fingerprints.” Washington Post. 29 March 2025, https://www.washingtonpost.com/national-security/2025/03/29/secret-pentagon-memo-hegseth-heritage-foundation-china/.

[4] Helene Cooper, Maggie Haberman, Charlie Savage, and Eric Schmitt, “Trump Directs Military to Target Foreign Drug Cartels.” New York Times. 8 August 2025, https://www.nytimes.com/2025/08/08/us/trump-military-drug-cartels.html.

[5] By Jeremy Chin, Margaret Lin, Aidan Arasasingham and Marie Miller “Timeline of Boat Strikes and Related Actions.” Just Security. 28 May 2026, https://www.justsecurity.org/124002/timeline-vessel-strikes-related-actions/.

[6] Maria Ramirez Uribe, “Fact-Checking Trump’s Claim That Each Boat Strike off Venezuela’s Coast Saves 25,000 Lives.” PBS NewsHour. 19 October 2025, https://www.pbs.org/newshour/politics/fact-checking-trumps-claim-that-each-boat-strike-off-venezuelas-coast-saves-25000-lives.

[7] Steven Dudley, Victoria Dittmar, Sara Garcia, Jaime López-Aranda, Annie Pforzheimer, and Ben Westhoff, et al., “The Flow of Precursor Chemicals for Synthetic Drug Production in Mexico.” InSight Crime. May 2023, https://insightcrime.org/investigations/chemical-precursors-mexico-synthetic-drug-meth-fentanyl/.

[8] Orlando J. Pérez, “The Shield of the Americas Is the Trump Corollary’s Military Edge.” Just Security. 16 March 2026, https://www.justsecurity.org/133705/shield-americas-trump-corollary-military-edge/.

[9] Richard Feinberg, “Trump’s ‘Shield of the Americas’ Leaves Many Outside the Armor.” Stimson Center. 13 March 2026, https://www.stimson.org/2026/trumps-shield-of-the-americas-leaves-many-outside-the-armor/.

[10] Aamer Madhani, Joshua Goodman, and Alanna Durkin Richer, “Trump Encourages Latin American Leaders to Use Military Action to Help the U.S. Fight Cartels.” PBS NewsHour. 7 March 2026, https://www.pbs.org/newshour/world/trump-encourages-latin-american-leaders-to-use-military-action-to-help-the-u-s-fight-cartels.

[11] Sara Garcia, Mike LaSusa, Lara Loaiza ,and Charlotte Newell, “30 Years after Escobar, How the Cocaine Trade Has Changed.” InSight Crime. 1 December 2023, https://insightcrime.org/news/30-years-after-escobar-how-the-cocaine-trade-has-changed/.

[12] Brendon Lee, “Not-So-Grand Strategy: America’s Failed War on Drugs in Colombia.” Harvard International Review. 2020, https://hir.harvard.edu/americas-failed-war-on-drugs-in-colombia/.

[13] Jane Esberg, “Criminal Fragmentation in Mexico.” Political Science Research and Methods. Vol. 14, no. 1. 2026: pp. 213–220, https://doi.org/10.1017/psrm.2025.4.

[14] Gabriel Hetland, “It’s Hard to Be a Leftist Leader in Colombia.” The Nation. 15 August 2024, https://www.thenation.com/article/world/gustavo-petro-colombia/.

[15] Elijah Glantz and Eduardo Giralt Brun, “Language of Violence: Evolution of Mexican Cartels.” Royal United Services Institute (RUSI). 6 December 2022, https://www.rusi.org/networks/shoc/informer/language-violence-evolution-mexican-cartels.

[16] Oscar Contreras Velasco, “Unintended Consequences of State Action: How the Kingpin Strategy Transformed the Structure of Violence in Mexico’s Organized Crime.” Trends in Organized Crime. Vol. 28, no. 3. 2023: pp. 334–358, https://doi.org/10.1007/s12117-023-09498-x.

[17] Ibid.

[18] “Crime in Pieces: The Effects of Mexico’s ‘War on Drugs’, Explained.” International Crisis Group. 2024, https://www.crisisgroup.org/visual-explainers/crime-pieces-effects-mexicos-war-drugs-explained.

[19] Brandon Schingh, “Using Special Operations Forces to Counter Mexican Cartels: An Irregular Analysis.” Small Wars Journal. 26 February 2025, https://smallwarsjournal.com/2025/02/26/using-special-operations-forces-to-counter-mexican-cartels-an-irregular-analysis/.

[20] Andrés Rodríguez, “Nearly 80% of Weapons Seized by Mexico’s Current Administration Come from the US.” El País. 11 February 2026, https://english.elpais.com/international/2026-02-11/nearly-80-of-weapons-seized-by-mexicos-current-administration-come-from-the-us.html.

[21] Maria Abi-Habib Julian E. Barnes, Eric Schmitt, and Tyler Pager, “The U.S. Is Pressing Mexico to Allow U.S. Forces to Fight Cartels.” New York Times. 15 January 2026, https://www.nytimes.com/2026/01/15/world/americas/us-mexico-cartels.html.

[22] Sandra Pellegrini and María Fernanda Arocha, “Actor Profile: The Jalisco New Generation Cartel (CJNG).” ACLED. 14 April 2023, https://acleddata.com/report/actor-profile-jalisco-new-generation-cartel-cjng.

[23] “National Drug Threat Assessment 2024.” US Drug Enforcement Administration, DEA-DCT-DIR-010-24. May 2024, https://www.dea.gov/sites/default/files/2024-05/NDTA_2024.pdf.

[24] Buschschlüter, Vanessa, “Co-Founder of Jalisco New Generation Drug Cartel Pleads Guilty.” BBC News. 8 April 2026, https://www.bbc.com/news/articles/c8ejyjnk9pdo; Sofia Ferreira Santos, “‘Burned and Destroyed’: Locals and Tourists Describe Mexico Unrest.” BBC News. 23 February 2026, https://www.bbc.com/news/articles/c4gqkg87293o.

[25] See Rhett Alden Price, “2006 or 2026? Will the Sheinbaum Administration Adopt a Calderón-Era Security Doctrine?” Small Wars Journal. 9 June 2026, https://smallwarsjournal.com/2026/06/09/2006-or-2026-will-the-sheinbaum-administration-adopt-a-calderon-era-security-doctrine/ for a discussion of the effectiveness of the kingpin strategy and future response options.

[26] Rafael Croda, “El CJNG mantiene su poder militar y sus rentas criminales tras caída del ‘Mencho’: ACLED.” Proceso. 12 May 2026, https://www.proceso.com.mx/nacional/2026/5/12/el-cjng-mantiene-su-poder-militar-sus-rentas-criminales-tras-caida-del-mencho-acled-371672.html.

[27] Miguel Flores, “El ocaso de la cúpula: Las capturas y muertes que sacuden al Cártel Jalisco Nueva Generación.” Infobae. 3 May 2026, https://www.infobae.com/mexico/2026/05/03/el-ocaso-de-la-cupula-las-capturas-y-muertes-que-sacuden-al-cartel-jalisco-nueva-generacion/.

[28] Magda Long, “From Kingpins to Terrorists: Trump II, Cartels as FTOs, and the Weaponization of Covert Action.” Small Wars & Insurgencies. 11 February 2026: pp. 1–33, https://doi.org/10.1080/09592318.2026.2627487.

[29] Nicole Byrd, Andrea Crosta, Chiara Talerico, and Maggie McGraw, “Money Talks: Ten Years of Firsthand Corruption Reporting from ELI.” Earth League International (ELI). March 2026, https://earthleagueinternational.org/wp-content/uploads/2026/03/ELI-Corruption-Report-March-2026.pdf.

[30] Saba Kassa and Jacopo Costa, “Corruption as a Facilitator of Drug Trafficking in the Port of Rotterdam.” Working Paper 58. Basel Institute on Governance. 11 September 2025,https://baselgovernance.org/publications/wp-58.

[31] Anti-Corruption and Integrity Outlook 2026: Harnessing the Integrity Advantage. Paris: OECD Publishing, 2026, https://doi.org/10.1787/16708b78-en.

[32] “Report of the International Narcotics Control Board for 2010.” United Nations Office on Drugs and Crime (UNODC). 2 March 2011, https://www.unodc.org/documents/lpo-brazil/noticias/2011/03-marco/Jife/INCB_Global_Report_2010_English_pdf.pdf.

[33] Doug Livermore, “To Tackle China-Enabled Drug Cartels in Mexico, Trump Will Need Military Authorization.” Atlantic Council. 3 March 2025, https://www.atlanticcouncil.org/blogs/new-atlanticist/to-tackle-china-enabled-drug-cartels-in-mexico-trump-will-need-military-authorization/.

[34] Edgardo Buscaglia, “The Paradox of Expected Punishment: Legal and Economic Factors Determining Success and Failure in the Fight against Organized Crime.” Review of Law & Economics. Vol. 4, no. 1. 2008: pp. 290–317, https://doi.org/10.2202/1555-5879.1206.

[35] “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” The White House, Presidential Actions. 10 February 2025, https://www.whitehouse.gov/presidential-actions/2025/02/pausing-foreign-corrupt-practices-act-enforcement-to-further-american-economic-and-national-security/.

[36] Noor Hamadeh and David McKean, “Suspension of FCPA Enforcement Is Bad for U.S. and Global Business.” Just Security. 13 March 2025, https://www.justsecurity.org/108830/fcpa-suspension-bad-for-business/.

[37] Bruce Swartz, Sonia Mittal, Inbar Pe’er, and Brady Worthington, “Hard to Kill: The Transnational Survival of the Foreign Corrupt Practices Act.” Just Security. 24 July 2025, https://www.justsecurity.org/117726/transnational-survival-foreign-corrupt-practices/.

[38] Matteson Ellis, “What Trump’s FCPA Pause Means for Latin America.” Americas Quarterly. 20 February 2025, https://americasquarterly.org/article/what-trumps-fcpa-pause-means-for-latin-america/.

[39] Claire Klobucista and Rocio Cara Labrador, “Brazil’s Corruption Fallout.” Council on Foreign Relations. 7 November 2018, https://www.cfr.org/backgrounders/brazils-corruption-fallout. See also, Luis Jorge Garay-Salamanca, Eduardo Salcedo-Albarán, and Guillermo Macías, “Macro-corruption and the Lava-Jato Case: A Criminal Networks Analysis.” Small Wars Journal. 3 June 2018, https://archive.smallwarsjournal.com/jrnl/art/macro-corruption-and-lava-jato-case-criminal-networks-analysis.

[40] Op. Cit., Ellis at Note 38.

[41] “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA).” US Department of Justice. 9 June 2025, https://www.justice.gov/dag/media/1403031/dl.

[42] Alex Demas, “Has the Trump Administration Retreated on White-Collar Crime?” The Dispatch. 16 April 2026, https://thedispatch.com/article/trump-admin-doj-white-collar-crime-prosecutions/.

[43] Ibid.

[44] Alexis Loeb, “Bondi’s Dismantling of the Kleptocracy Team Threatens National Security.” Lawfare. 26 March 2025, https://www.lawfaremedia.org/article/bondi-s-dismantling-of-the-kleptocracy-team-threatens-national-security.

[45] Ibid.

[46] Dave Michaels, Sadies Gurman, and Aruna Viswanatha, “Trump Administration Upends Prosecution of White-Collar Crime.” Wall Street Journal. 31 December 2025, https://www.wsj.com/politics/policy/white-collar-crime-enforcement-trump-5f3ca604.

[47] Jose Pagliery, “The Justice Department Had 36 Lawyers Fighting Corruption Full-Time. Under Trump, It’s Down to Two.” NOTUS. 22 September 2025, https://www.notus.org/courts/doj-public-integrity.

[48] Ken B. Morales and David Armstrong, “Trump’s Justice Department Dropped 23,000 Criminal Investigations in Shift to Immigration.” ProPublica. 31 March 2026, https://www.propublica.org/article/trump-doj-immigration-bondi-declinations-criminal-investigations.

[49] Andres Aponte and María Antonia Cote, “Criminality and Multi-Crime Dynamics: Trends in Latin America.” Global Initiative Against Transnational Organized Crime (GI-TOC). November 2025, https://globalinitiative.net/analysis/criminality-and-multi-crime-dynamics-trends-in-latin-america/. See also, John P. Sullivan, “Corruption as an Enabler in the Hybrid Influence Toolbox.” Small Wars Journal, 10 December 2024, https://smallwarsjournal.com/2024/12/10/corruption-as-an-enabler-in-the-hybrid-influence-toolbox/.

[50] Gonzalo Croci, “The Shifting Landscape of Organised Crime.” International Journal for Crime, Justice and Social Democracy. 12 January 2026, https://doi.org/10.5204/ijcjsd.4024.

[51] Jay S. Albanese, “Corruption as the Cause, Not the Effect, of Organized Crime?” Journal of Economic Criminology. Vol. 7. Mach 2025:   https://doi.org/10.1016/j.jeconc.2025.100137.

[52] Soeren C. Schwuchow, “Organized Crime as a Link between Inequality and Corruption.” European Journal of Law and Economics. Vol. 55, no. 3. 2023: pp. 469–509, https://doi.org/10.1007/s10657-023-09764-x.

[53] Dani Schulkin, Amy Markopoulos, and Maya Nir, “The Anti-Corruption Tracker: Mapping the Erosion of Oversight and Accountability.” Just Security. 14 April 2026, https://www.justsecurity.org/117267/anti-corruption-tracker/.

[54] Ibid.

[55] Nahal Toosi, “Trump Drastically Cutting Back Annual Human Rights Report.” POLITICO. 19 March 2025, https://www.politico.com/news/2025/03/19/trump-human-rights-report-00238581.

[56] “Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act.” US Department of the Treasury. 2 March 2025, https://home.treasury.gov/news/press-releases/sb0038.

[57] Billion-Dollar Blind Spot.” Center for Advanced Defense Studies. 20 November 2025, https://c4ads.org/commentary/billion-dollar-blind-spot/.

[58] Sarah N. Lynch and Chris Prentice, “US Justice Dept Disbands Crypto Enforcement Team, Citing Trump Order.” Reuters. 8 April 2025, https://www.reuters.com/world/us/us-justice-dept-disbands-cryptocurrency-enforcement-unit-2025-04-08/.

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