Introduction
With the imminent designation of Mexican drug cartels as terrorist organizations by the current administration of the United States, Mexican companies and individuals operating in risk zones or directly or indirectly exposed to them may be subject to strict Office of Foreign Assets Control (OFAC) regulations, as well as economic penalties and criminal consequences for acts related to terrorist activities or groups, in addition to the rules specifically applicable against organizations related to drug trafficking. These regulations prohibit any financial or commercial interaction with sanctioned actors; such interactions may include extortion (e.g., “protection fees,” passage fees, or illegal tolls), threats or transactions with suspicious clients, intermediaries, or counterparties in sensitive areas. Failure to comply with these provisions can result in severe legal, financial, and reputational sanctions.