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.
In February 2025, the Trump Administration designated six of Mexico’s most notorious drug cartels as foreign terrorist organizations (FTOs), declared that “international cartels constitute a national-security threat beyond that posed by traditional organized crime” and directed federal agencies to implement the terrorism designation against such international criminal organizations. This designation of cartels as FTOs is unprecedented, as historically the FTO designation has been reserved for organizations that use violence for political causes rather than economic gain.
Click here to view the full article