The Engel List Foreshadows U.S. Enforcement in Central America

The United States-Northern Triangle Enhanced Engagement Act, passed by Congress in December 2020, provides for “targeted sanctions to fight corruption in El Salvador, Guatemala, and Honduras,” and requires a report identifying individuals in the Northern Triangle who, according to the State Department, engaged in corruption or undermined democracy. Then, in July 2021, the State Department published what has come to be called the “Engel List,” which named 55 purportedly “corrupt and undemocratic actors for Guatemala, Honduras, and El Salvador.” In a guest article, Martin De Luca, Wade Weems and Scott Nielson of Kobre & Kim look at how the Engel List and the Biden administration’s strong focus on corruption in the Northern Triangle could lead to increased enforcement of the FCPA and money laundering statutes. Additionally, they discuss how these changes might provide political or business rivals in the region an additional U.S. forum to file complaints, and how U.S. counsel can assist listed individuals in seeking recourse. See “Latin American Corruption in the Crosshairs of the Biden Administration” (Apr. 14, 2021).

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