Overview
Iris Bennett, Andrew Adams and Lillian Stevens co-authored an article that appeared in Law360, "How Cos. Can Navigate Risks Of New Cartel Terrorist Labels." The article discusses significant changes in US economic statecraft following the transition from the Biden to Trump administration, particularly regarding sanctions and cartel designations. The White House issued Executive Order 14157, labeling several narcotics cartels as Foreign Terrorist Organizations (FTOs), intensifying enforcement risks for businesses operating across the U.S.-Mexico border. These measures expose companies to heightened liability under statutes like the Antiterrorism Act and the material support statute. Both financial services firms and operating companies face elevated risks of entanglement with cartels through illicit transactions or indirect dealings. The piece includes proactive measures that companies can take to mitigate exposure including employee training, audits, and due diligence.