While any dealings with transnational criminal organizations (TCOs) were always risky for a multinational company (doing business with criminal organizations is usually bad for business in the long run), the U.S. Department of State’s designation of many TCOs as foreign terrorist organizations (FTOs) triggers additional laws that can have serious consequences. The Anti-Corruption Report recently spoke with Rebecca (Becky) Rohr, who most recently served as CCO and head of investigations at Telefonaktiebolaget LM Ericsson, a multinational telecommunications company headquartered in Stockholm, Sweden. This article highlights Rohr’s insights on how companies can adjust their compliance programs to address these emerging areas of risk, based on her in-house experience as well as her time as a leader and prosecutor in the DOJ’s Criminal Fraud Section. See “The Importance of Human Intelligence in Mexico to Combat FTO Risk” (Jul. 15, 2026).