A New Compliance Framework for Companies Operating in Latin America: Heightened Risks of Exposure to Cartel Activity

Margot Laporte, Jeffrey Lehtman, Katie Mills, and Facundo Galeano recently authored an article for the International Bar Association examining new compliance risks for companies operating in Latin America.

They detail how recent foreign terrorist organization designations of major cartels have made the Antiterrorism Act a significant new source of corporate liability, layering onto existing anti-corruption, sanctions and anti-money laundering frameworks. They also highlight recent DOJ, Treasury and FinCEN enforcement actions to show how well-intentioned business activities, from third-party relationships to routine payments, can now expose companies to material support claims. The article concludes with practical guidance for building integrated, risk-based compliance programs suited to this heightened enforcement landscape.

Read the full article here.