Recent developments in U.S. policy giving rise to enforcement action by the U.S. Department of Treasury’s Financial Enforcement Network (FinCEN) sound a cautionary note for U.S. financial institutions. An article we recently posted regarding the U.S. Department of Justice’s updated guidelines regarding the Foreign Corrupt Practices Act, called attention to the Trump administration’s focus to “pursue the total elimination of Cartels and transnational criminal organizations”. This latest FinCEN enforcement action further defines this focus.

On June 9, 2025, the U.S. Department of Justice (“DOJ”) issued updated Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act. The Guidelines comply with President Trump’s February 10, 2025 Executive Order 14209 and follow Attorney General Pam Bondi’s February 5, 2025 Memorandum, both of which focus on prioritizing “American interests, American economic competitiveness with respect to other nations, and the efficient use of Federal law enforcement resources.”