By Javier Coronado Diaz.
On January 20, 2025, Donald Trump took significant actions related to the economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Through a series of Executive Orders and other actions, the new administration has signaled its intent to reshape OFAC Sanctions programs, particularly in relation to countries, organizations, and activities central to the new administration’s policy goals.This commentary provides an overview of these key actions, highlighting the importance for businesses to closely monitor these developments and update their policies and procedures accordingly.
Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists
One of the first actions taken by President Trump was the signing of an Executive Order that grants the U.S. Government the authority to designate certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). While the body of the EO specifically targets cartels operating in Mexico, as well as criminal organizations like Tren de Aragua and La Mara Salvatrucha, it effectively expands the U.S. Government’s authority to add individuals and entities to the Specially Designated Nationals (SDN) List. Being placed on the SDN List means that U.S. persons are prohibited from engaging in transactions with these individuals or entities. Additionally, any assets they hold within U.S. jurisdiction are subject to blocking.
