Executive Briefing — Risks to Latin American Banks From Recent U.S. Sanctions Actions, Including Terrorist Designations of Cartels

Is your institution prepared for the regulatory, enforcement, and operational risks emerging from the United States’ expanding use of counterterrorism and other sanctions authorities in Latin America?

Following the U.S. Department of State’s announcement of its intent to designate the Cartel de los Soles as a Foreign Terrorist Organization (FTO) — effective November 24, 2025 — banks across the region face an urgent need to reassess exposure. This and other U.S. sanctions designations represent a significant escalation in U.S. national security policy, with profound implications for correspondent banking, sanctions liability, AML/CFT expectations, and reputational risk.

Our executive briefing will provide a high-level discussion of:

• Key risks to Latin American banks arising from FTO/SDGT and other U.S. designations
• Correspondent banking vulnerabilities and potential loss of U.S. access
• Criminal, civil, and sanctions-based liabilities for inadvertent exposure
• Heightened AML/CFT expectations from U.S. regulators and counterparties
• Guidance regarding sanctions provisions in loan and other contractual documentation
• Strategic steps institutions should take now to mitigate risk and strengthen compliance posture