Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates

DOJ Reinforces Focus on Cartels and Transnational Criminal Organizations

Skadden Publication / White Collar Defense and Investigations

Alessio D. Evangelista Eytan J. Fisch Ryan D. Junck Bora P. Rawcliffe Ondrej Chvosta Alyssa R. Domino Zaneta Wykowska

In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of cartels and transnational criminal organizations (TCOs) as a top administration priority (see our client alerts from May 14, 2025, and March 25, 2025). This DOJ memorandum follows four recent administration measures focused on cartels and TCOs:

  1.  Attorney General Pamela Bondi’s February 5, 2025, memorandum calling for a “fundamental change in mindset and approach” to “pursue total elimination” of cartels and TCOs;
  2. The designation of a number cartels and TCOs as foreign terrorist organizations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC);
  3. Treasury’s Financial Crimes Enforcement Network’s (FinCEN’s) March 2025 geographic targeting order requiring money services businesses located in 30 ZIP codes near the southwest border of the U.S. to file currency transaction reports with FinCEN in connection with certain cash transactions; and
  4. Actions by both OFAC and FinCEN targeting cartel oil smuggling schemes.

According to the May Memorandum, international money laundering organizations enable sanctions evasion by hostile state and private actors and, more broadly, the activities of cartels and TCOs. Therefore, the Criminal Division plans to focus on dismantling these networks, while at the same time attempting to avoid “overbroad and unchecked corporate and white-collar enforcement burdens on U.S. companies.”

As relevant to TCOs and cartels, the Criminal Division will prioritize investigating and prosecuting white collar crimes in the following areas:

  1. Threats to U.S. national security, including threats to the U.S. financial system by gatekeepers, such as financial institutions and their insiders that commit sanctions violations or enable transactions by cartels, TCOs, hostile nation states or foreign terrorist organizations;
  2. Material support by corporations to foreign terrorist organizations, including designated cartels and TCOs; and
  3. Digital asset-related cases involving cartels, TCOs or terrorist groups, or the facilitation of drug money laundering or sanctions evasion.

The May Memorandum states that the Criminal Division will focus efforts on identifying and seizing assets that are the proceeds of, or involved in, such offenses and use forfeited assets to compensate victims.

The memorandum also requires certain changes to the Criminal Division’s Corporate Whistleblower Awards Pilot Program, which the Criminal Division launched in August 2024 to offer awards to whistleblowers providing information about corporate misconduct. The proposed changes to the pilot program reflect specified areas of focus, including violations by corporations related to international cartels, violations by corporations involving material support of terrorism and sanctions offenses by corporations. Additional whistleblower incentives and protections related to violations of anti-money laundering and sanctions laws were included as part of the Anti-Money Laundering Act of 2020 and the AML Whistleblower Improvement Act (see our February 2023 article on AML and sanctions whistleblower programs).

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1 The memorandum was issued by Matthew R. Galeotti, head of the DOJ’s Criminal Division.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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