Consistent with President Trump’s early executive orders, his administration has shifted law enforcement resources to focus on cartels, transnational criminal organizations, and terrorist groups. In this environment, businesses should reassess their Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) programs, particularly if they operate in high-risk regions.
Shortly after her confirmation, U.S. Attorney General Pamela Bondi issued a series of memorandum to Department of Justice (DOJ) employees, outlining the administration’s investigative and charging priorities, and suspending a number of internal DOJ policies and procedures to allow for the aggressive prosecution of those cases. For example, to expedite the filing of certain charges against members of cartels and transnational criminal organizations, some internal DOJ approval and staffing requirements have been temporarily suspended. Likewise, the Joint Task Force October 7—tasked with prosecuting perpetrators of the October 7, 2023 attack in Israel, seeking the arrest and extradition of the leaders of Hamas, and investigating and prosecuting those who provide funding for Hamas—has been empowered to issue administrative subpoenas seeking records from foreign banks with correspondent accounts in the U.S., suspending internal DOJ approval requirements.
The U.S. Department of State and Department of the Treasury have taken actions that support DOJ’s new investigative priorities. On February 20, 2025, the U.S. Department of State designated 8 cartels and transnational organizations as Foreign Terrorist Organizations (FTOs). These designations are of critical importance, as knowingly providing material support or resources to FTOs may result in criminal charges in the United States. In this context, material support includes a myriad of products and services, including financial services, lodging, transportation, training, personnel, communications equipment, false documentation, and weapons.
Furthermore, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, has taken several actions under the Bank Secrecy Act (BSA) that will result in the collection of more information about individuals doing business in the United States, particularly non-U.S. persons. On March 11, 2025, FinCEN issued a Geographic Targeting Order affecting money services businesses operating in 30 zip codes in Texas and California. Citing “efforts to combat illicit finance by drug cartels and other illicit actors along the southwest border[,]” FinCEN reduced the threshold for filing a Currency Transaction Report in connection with cash transactions from $10,000 to $200. This will result in the collection of a significant amount of information—including identification and account information—from individuals along the U.S. border with Mexico, including customers of money services businesses that provide check cashing, currency exchange, money order, prepaid access, and money transmission services. While this Order is currently the subject of a legal challenge, absent judicial action, the requirement will go into effect on April 15, 2025 for 180 days (subject to renewal).
Furthermore, on March 21, 2025, FinCEN adopted an interim final rule exempting owners of U.S. companies from a reporting requirement under the BSA, while maintaining the requirement for certain owners of non-U.S. companies registered to do business in the United States. Noting that non-U.S. companies “present heightened national security and illicit finance risks[,]” FinCEN specifically cited the risks associated with “foreign illicit actors[,]” including narcotics traffickers. Under this interim final rule, non-U.S. persons who are owners of these “foreign reporting companies” must file or update beneficial ownership information reports within 30 days, or risk significant civil and criminal penalties.
The new administration’s rapid shift from long-standing enforcement priorities underscores the need for flexible AML/CTF compliance programs. Companies should assess their policies, procedures, and controls—particularly related to customer due diligence and transaction monitoring—to ensure that they are adequately managing the risk associated with their current customers and products.
Reese Alutto-Schmidt is a Partner in PLG’s Washington, DC office. She is a Certified Anti-Money Laundering Specialist with broad experience assisting clients with internal investigations, government enforcement matters, employee misconduct investigations, and responses to government subpoenas. Having previously served in government and as in-house counsel, Reese brings a wealth of experience to help her clients manage the risk associated with allegations of fraud and misconduct.
