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Abstract: 

On Inauguration Day, the second Trump Administration issued an Executive Order making the “total elimination of cartels” an executive policy, signaling the start of an aggressive enforcement posture towards these transnational groups and corporations that may have interactions with them. The following article assesses the laws identified by the U.S. government as key to its total elimination strategy, such as the Anti-Terrorism Act, sanctions programs administered by the Office of Foreign Asset Control, the Money Laundering Control Act, and the anti-bribery provisions of the FCPA. It also explains how the FCPA accounting provisions, which require public companies to maintain accurate books and records and effective internal controls, may be the law best equipped to prosecute corporations with potential cartel interactions.

Keywords: Executive Order (“E.O.”) 14157; Anti-Terrorism Act (“ATA”): International Emergency Economic Powers Act (“IEEPA”); Money Laundering Control Act (“MLCA”)

Affiliations:  1: Miller & Chevalier Chartered; 2: Miller & Chevalier.