Mitigating Risks of “Interacting” with Cartels and TCOs
We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs). Companies need to understand the laws used to designate cartels and other organizations as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). Under current criminal and sanctions laws, FTOs and SDGTs create criminal and civil risks for...
