Two recent pronouncements indicate that enforcement risks around dealing with criminal narcotics trafficking organizations in Latin America continue to increase. We expect the Trump Administration to continue to focus on designating such organizations as Foreign Terrorist Organizations (“FTOs”), sanctioning their supporters, and enforcing the measures already in place. We also expect countries across Latin America to align more with the United States and impose their own sanctions against these organizations. First, on September 15, President…
On August 20, 2026, the White House released the National Security Science and Technology Strategy (“NSSTS”), which establishes the Trump administration’s framework for maintaining US technological leadership and protecting critical and emerging technologies. The NSSTS is organized around four pillars: (1) focusing techno-strategic competition, (2) building technological resilience, (3) accelerating innovation, and (4) protecting national security science and technology. For sanctions, export controls, investment screening, and data security practitioners, Pillar 4(Protect National Security S&T) is…
On July 1, 2026, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department imposed sanctions on several parties due to links to Brazil-based Primeiro Comando da Capital (i.e., First Capital Command, or “PCC”). This was the first round of sanctions against parties connected to PCC since the US Government’s actions in the spring designating PCC as both a Foreign Terrorist Organization (“FTO”) and a Specially Designated Global Terrorist (“SDGT”). We refer to…
Since issuing its Frequently Asked Questions (“FAQ”) 1249 on April 28, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has updated its position with respect to “toll” payments to Iran for safe passage through the Strait of Hormuz. At the time of its publication, FAQ 1249 made it clear that payments to Iran for “safe passage” through the Strait of Hormuz are prohibited for U.S. persons. However, to further maximize…