International Cartels Designated as Foreign Terrorist Organizations and Specially Designated Global Terrorists

Date issued: Mar. 18 2025

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TURBOFAC Commentary (100 words)

Notes:

1) This alert does not break new legal ground, including with respect to the difficult question of what OFAC’s diligence expectations are as it relates to the question of whether a designated cartel has an “interest” in a transaction. Instead, it appears aimed at highlighting that, now that many drug cartels are designated as FTOs, dealings with them are subject to EO 13224-based secondary sanctions as well as the “material support” criminal provision of the Antiterrorism and Effective Death Penalty Act of 1996. See e.g.ENF 1057949 ("Regulatory Question") for and example of a dealing involving a designated cartel.