On April 8, Ritch Mueller along with Davis Polk, Gowling WLG, and Control Risks, co-hosted the webinar "Designation of Drug Cartels as Terrorist Organizations by the U.S. and Canada: Legal and Operational Risks for Businesses".

Our partner, Ricardo Calderón, served as moderator in a timely discussion with William Hochul, Jr. (Counsel, Davis Polk), Robin McKechney (Partner, Gowling WLG), and Daniel Linsker (Partner, Control Risks), focusing on the legal, regulatory, and operational implications of the recent designation of several Mexican cartels and transnational criminal organizations as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs) by the U.S. government, as well as their listing under Canada’s Criminal Code. 

The panel addressed the risks these measures represent for businesses, including compliance obligations, legal exposure, and reputational impact.

Here are the key takeaways: 

  • The U.S. government has officially designated several Mexican cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, while Canada has also designated certain cartels as terrorist entities under its Criminal Code. These classifications trigger broad legal and compliance consequences for businesses operating in or with Mexico. Companies face increased exposure to enforcement actions, civil liability, contractual disruption, and reputational damage, especially under anti-terrorism and anti-money laundering statutes. 
  • Businesses must prepare for cross-border investigations where authorities may rely on intelligence sharing, MLATs, and subpoenas — often without the company’s immediate knowledge. 
  • In the face of these developments, companies should act proactively:
  • Conduct internal risk assessments and forensic reviews. 
    • Update due diligence and third-party vetting protocols. 
    • Preserve legal privilege and prepare internal response plans. 
    • Seek legal counsel early when facing scrutiny in the U.S., Canada, or Mexico.
If you have any questions regarding this topic, please contact our partner Ricardo Calderón (see details below), head of the Compliance, Anti-corruption and Investigations practice area.