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…
In brief On September 4, 2026, the Argentine Executive Branch issued Executive Order No. 868/2026 (the “Executive Order”), introducing new measures to strengthen the enforcement of Law No. 26,659 regarding hydrocarbon activities on the Argentine Continental Shelf. This law not only prohibits certain hydrocarbon activities carried out without Argentine authorization on the continental shelf, including the area surrounding the Falkland Islands (Islas Malvinas), but also imposes restrictions that may extend to direct, and indirect shareholders,…