Cartels in the Spotlight: The Government's New Enforcement Framework and Industry Best Practices for Detecting Exposure

Wednesday, September 10, 2025 | 1:00 - 2:00 PM ET

U.S. policy designating cartels as Foreign Terrorist Organizations FTOs, “[seeks] the total elimination of these organizations’ presence in the United States…” and reinforces cartels among the top U.S. national security threats. These designations not only boost consequences for those targeted for prosecution, but advance a gloves-off, whole of government approach, bringing various intelligence and defense assets long used against the likes of Al-Qaida and ISIS to the fight against cartels. Eliminating the DTO threat, like any threat where both sanctions and money laundering intersect, requires mutually reinforcing mission effectiveness from both the public and private sectors. 

The Attorney General’s February 2025 memo acknowledges that the “total elimination” policy requires a fundamental change in mindset and approach. The memo’s directives eliminate various Department of Justice pre-indictment reviews and suspend various approval requirements, empowering US Attorneys’ Offices to “lead the charge.” Relying on China and other countries for pill presses and die molds, Mexican cartels press fentanyl into pills that are made to look identical to real prescription pills, such as Adderall or Xanax, where as little as two milligrams can be deadly. Since January 20, 2025, the DEA has seized approximately 44 million fentanyl pills, 4,500 pounds of fentanyl powder, nearly 65,000 pounds of methamphetamine, and made over 2,105 fentanyl-related arrests.

Adjacent to law enforcement efforts, OFAC has ramped up the use of sanctions against cartels, and in late June FinCEN took its first actions under the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, naming three Mexican financial institutions–CIBanco, Intercam, or Vector– as being of primary money laundering concern in connection with illicit opioid trafficking.

Through a combination of brute force, terrorist tactics intended to intimidate the public, and the use of sophisticated deceptive practices, cartels control territory, penetrate governments, create illicit supply chains and distribution systems, manufacture and steal products, and exploit the global financial system to launder illicit revenue. Even in instances where a bank or business did not know of a connection to illicit activity, there is a risk of exposure to investigation, reputational risk, as well as civil litigation.

Join experts from Wilmer Hale and Kharon to discuss the new enforcement framework and the value of intelligence and technology in both powering government operations and guiding industry controls to detect risk.

Speakers:

Greg Gatjanis, Strategic Advisory Board Member at Kharon,

Former Associate Director, OFAC Office of Global Targeting

Greg Gatjanis served 12 years as the Associate Director for Global Targeting at the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), where he led sanctions targeting and financial investigations across dozens of national security programs. In this capacity, he oversaw the targeted designation of more than 10,000 foreign individuals and entities. With over 30 years of experience in government, including senior roles at the White House National Security Council and the DEA, he has shaped U.S. strategy on terrorism finance, transnational crime, and narcotics. Gatjanis was a key architect of the 2011 Strategy to Combat Transnational Organized Crime and is recognized as a leading voice in sanctions and threat finance policy.

Zachary Goldman, Partner, WilmerHale

Zachary Goldman has extensive experience working on complex regulatory and enforcement matters related to OFAC sanctions, anti-money laundering (AML) and financial crime risk management issues. Mr. Goldman serves as a trusted advisor for the financial services and other sectors as they seek to perform risk assessments, evaluate the AML and sanctions risks associated with new commercial activities or transactions, and develop and enhance financial crimes compliance programs. Mr. Goldman has particular expertise advising banks and financial technology companies on AML and sanctions risk management issues, and in conducting internal investigations and responses to government inquiries from regulatory and enforcement authorities around the world for global banks and other financial institutions related to anti-money laundering and sanctions issues.

David Bowker, Partner, WilmerHale

David W. Bowker is the partner-in-charge of the firm’s Washington DC office and chair of the International Litigation practice. He is a nationally renowned litigator with nearly 25 years’ experience representing corporate clients, nonprofits, museums, universities, individuals, international organizations, governments, and government officials in a wide range of high-stakes commercial and governmental disputes before the US Supreme Court, US Courts of Appeals, US District Courts, US state courts, and international tribunals.