by Joon Kim, Lisa Vicens, Rahul Mukhi, David Last, Samuel Chang, Katherine Lynch, and Jordan McMeans
Top left to right: Joon Kim, Lisa Vicens, Rahul Mukhi and David Last. Bottom left to right: Samuel Chang, Katherine Lynch, and Jordan McMeans (Photos courtesy of Cleary Gottlieb Steen & Hamilton LLP).
A recent Executive Order from President Donald Trump and subsequent memoranda from the Department of Justice (“DOJ”) signal an anticipated crackdown on international cartels, transnational criminal organizations (“TCOs”), and those who provide material support to such entities. This development exposes companies and individuals with foreign business operations and activities, particularly in Latin America, to potential increased risks in this area, while suggesting a shift in focus away from investigations and cases that do not involve such a connection. Since these cartels and TCOs are not formal entities with clear memberships, businesses operating in countries where these groups operate will likely face substantial challenges with respect to compliance and risk management.