How Designating TCOs As Terrorist Organizations Creates Risks for Financial Institutions and Beyond

President Donald Trump recently signed an executive order (TCO EO) authorizing the designation of international narcotics cartels and other transnational criminal organizations (TCOs) as Foreign Terrorist Organizations. While U.S. law enforcement has long targeted cartels and TCOs for illegal narcotics sales and jeopardizing safety in the United States, the TCO EO has opened a new front in this fight, and one that is likely to escalate pressure on businesses, financial institutions, and cryptocurrency exchanges and issuers. In a guest article, Boies Schiller partners Dan Boyle and John Kucera explain how this change is expected to alter the landscape of seizure and forfeiture not only for cartels and TCOs themselves, but for businesses and financial institutions across the Latin American region. See “Reference Guide to 2025 Executive Orders for Compliance Professionals” (Apr. 9, 2025).

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