Corporate Compliance Insights

A year after the Trump Administration designated six Mexican cartels as foreign terrorist organizations, the compliance implications for multinationals are still coming into focus — and they are severe. Robert Johnston of Lowenstein Sandler and Brian Mich and Ulla Pentinpuro of Control Risks lay out the exposure: material support statutes with extraterritorial reach, FinCEN orders that have already forced three Mexican banks to cease operations and a DOJ that has signaled it will pursue companies from any jurisdiction acting against US interests. Colombia's Chiquita Brands case offers a sobering preview of what enforcement could look like.