U.S. Heightens Scrutiny for Companies with Mexico Ties

Attorneys Margarita Ríos-Farjat, Erik Siebert and Ambassador Nathan Sales wrote an article published by Latinvex examining the United States' expanded enforcement focus on commercial relationships with Mexican criminal organizations. The attorneys first review U.S. government enforcement actions in this area, including President Donald Trump's executive order designating certain criminal entities as Foreign Terrorist Organizations (FTOs) and the U.S. Department of the Treasury's Office of Foreign Assets Control's (OFAC) imposition of sanctions on individuals and entities connected to the newly designated organizations. The article then goes on to describe the broad swath of affected industries, from tequila to gas stations to private security, and breaks down the high civil, criminal and financial stakes of compliance – along with why merely following Mexico's anti-money laundering (AML) and related regulations may not be enough to avoid OFAC penalties. The authors list potential areas of risk and conclude with detailed recommended measures for companies: mapping where business operations implicate U.S. law, vetting sanctions policies and procedures, updating contracts and internal controls, and establishing clear response and documentation protocols, among other steps.

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