🔔 Executive Snapshot
As President Trump’s second term unfolds, sweeping changes in federal enforcement are prompting businesses to revisit risk assumptions. From trade policy and civil rights regulation to anti-corruption enforcement and criminal designations, this Administration’s early actions suggest a new landscape—one requiring agility, awareness, and global coordination.
This month’s newsletter highlights four key areas where compliance strategies must adapt quickly.
📦 Trade and Tariffs: The New Uncertainty
The Administration has re-energized its tariff agenda—targeting imports from China, Mexico, Canada, and more. The stated goals? Curtail illegal activity, reinvigorate U.S. manufacturing, and strengthen the domestic economy.
What to Watch:
- Ongoing amendments and suspensions create uncertainty for multinationals.
- Global supply chains may be disrupted by retaliatory tariffs and sudden regulatory pivots.
- European and Asian trade partners have signaled readiness to counter U.S. measures.
Compliance Action:
Reinforce supply chain vetting and ensure your due diligence processes capture tariff evasion risks and shifts in sourcing strategy.
đź‘ĄÂ DEI Scrutiny: From Policy to Lawsuit
Diversity, Equity & Inclusion (DEI) efforts are under new scrutiny, with federal orders eliminating programs in government and state attorneys general targeting private companies for alleged overreach or shareholder misrepresentation.
Recent Events:
- 11 state AGs requested DEI data from major financial institutions.
- Active lawsuits filed in Missouri and Florida allege race- and sex-based discrimination and securities fraud tied to DEI initiatives.
Compliance Action:
Review internal DEI policies and public-facing disclosures to ensure alignment with state and federal expectations, while remaining compliant with global diversity standards.
⚠️ Criminal Organizations Redefined: Terrorism Designations Expand
A dramatic development in February 2025 saw several Latin American drug cartels designated as foreign terrorist organizations (FTOs). This expands the scope of counterterrorism law and may alter how businesses interact—directly or indirectly—with entire regional economies.
Key Implications:
- Risk of liability for providing “material support” to designated FTOs—even unknowingly.
- Increased sanctions compliance burdens for banks and financial intermediaries.
- Civil exposure under the Anti-Terrorism Act for U.S. nationals harmed by cartel-linked activity.
Compliance Action:
Audit vendor relationships, especially in Mexico and Central America. Enhance sanctions screening and flag any indirect ties to designated organizations.
🛑 FCPA Enforcement: A Strategic Pause, Not a Free Pass
Perhaps the most headline-grabbing development: the Trump Administration has paused enforcement of the Foreign Corrupt Practices Act (FCPA) for six months—with a possible extension.
But here’s what hasn’t changed:
- The law remains on the books, and conduct today may be investigated tomorrow.
- The SEC and international regulators (e.g., the UK SFO, French AFA) continue active enforcement.
- DOJ may pivot to foreign targets or strategic competitors under U.S. jurisdiction.
Compliance Action:
Keep anti-corruption programs in place and active. Prioritize risk-based due diligence—particularly for third parties operating in emerging or high-risk markets.
💡 Practical Compliance Moves
In light of these evolving pressures, compliance teams should:
✅ Update risk assessments to reflect new U.S. priorities—especially around international operations, DEI, and third-party relationships.
✅ Review KYC and vendor screening practices with an eye on sanctions, human rights, and new FTO classifications.
✅ Tailor employee training by region or role—aligning global standards with U.S. enforcement posture.
✅ Strengthen internal reporting and whistleblower channels to capture new categories of risk as they emerge.
✉️ Final Thought
The landscape has shifted, and it’s still in motion. From trade policy to anti-corruption enforcement, the regulatory tide is less predictable than ever. The most prepared organizations are those that treat compliance as a dynamic, business-embedded function.
Prepared by:
Daniel G. Castricone, Esq. CRMP
www.DanCastricone.com