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

While U.S. law enforcement has long targeted cartels and transnational criminal organizations (TCOs), a recent executive order (TCO EO) has opened a new front in this fight. The TCO EO authorizes the designation of international narcotics cartels and other TCOs as Foreign Terrorist Organizations, which could escalate pressure on businesses, financial institutions, and cryptocurrency exchanges and issuers to know their customers. In this guest article, Boies Schiller partners Dan Boyle and John Kucera explain how the TCO EO is expected to alter the landscape of seizure and forfeiture not only for cartels and TCOs, 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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