US DOJ’s 2026 Q1 Latin America enforcement agenda: the convergence of enforcement, national security and foreign policy

Ildefonso P Mas
Akerman, Miami and Washington DC
ildefonso.mas@akerman.com

Sergio E Acosta
Akerman, Chicago
sergio.acosta@akerman.com

In May 2025, the United States Department of Justice (DOJ) issued a memorandum detailing its white collar crime enforcement priorities, which included, among other goals, eliminating cartels and transnational criminal organisations (TCOs), prosecuting threats to US national security and targeting bribery and money laundering that harm US national interests.[1] The DOJ also zeroed in on financial gatekeepers, namely financial institutions and their employees enabling sanctions evasion or money transfers tied to cartels or TCOs. These goals were repeated in other DOJ memoranda detailing the enforcement priorities related to specific criminal statutes, such as the Foreign Corrupt Practices Act (FCPA), 15 USC Sections 78dd-1, et seq.[2]

In the first quarter of 2026, those themes have converged, and Latin America has emerged as a focal point. The region’s concentration of designated TCOs, combined with its geographic proximity to the US and President Donald Trump administration's National Security Strategy’s focus on the Western Hemisphere,[3] have given rise to significant DOJ enforcement activity implicating the region. The government has coordinated sanctions enforcement, criminal enforcement and forfeiture laws to target cartels, TCOs and other national security threats operating in the Western Hemisphere.

On 5 January 2026, the government, following a military operation in Venezuela, brought former Venezuelan leader Nicolás Maduro before the US District Court for the Southern District of New York to respond to criminal charges set out in a 3 January 2026 superseding indictment alleging his involvement in narco-terrorism conspiracy, cocaine importation conspiracy, illegal weapon possession charges and conspiracy to possess illegal weapons.[4] This was followed by the DOJ’s seizure and filing of a civil forfeiture complaint in the US District Court for the District of Columbia seeking forfeiture in rem of an oil tanker and 1.8 million barrels of crude oil supplied by Venezuela’s state-owned oil company.[5] The government alleged in the forfeiture complaint that this crude oil was to benefit and generate revenue for the Islamic Revolutionary Guard Corps of Iran.[6]

The DOJ’s enforcement priorities targeting financial gatekeepers have also resulted in financial institutions with ties to Latin America experiencing significant enforcement activity, including criminal prosecutions for money laundering and sanctions evasion. In January, the DOJ secured a guilty plea against a former employee of a large international bank who was charged with money laundering conspiracy and bribery for facilitating the laundering of millions of dollars in drug money to Colombia in exchange for bribes.[7] In March, the DOJ secured a guilty plea against the former CEO of a Puerto Rican bank for facilitating the evasion of US Department of Treasury sanctions against Venezuela.[8] These examples are in line with the DOJ’s stated goals of holding financial gatekeepers responsible for facilitating and enabling cartels or TCOs.

The government has also actively pursued FCPA prosecutions implicating foreign officials in Latin America. It charged a Texas businessman for allegedly bribing officials working for Mexico’s state-owned oil corporation, PEMEX.[9]

Taken together, the enforcement activity in the first quarter of 2026 reveals the DOJ’s ability to use white collar enforcement as an instrument of asserting pressure and furthering national security goals in the region. Its coordinated use of criminal charges, sanctions enforcement and asset forfeiture demonstrates a strategy aimed not only at prosecuting misconduct, but also at disrupting the financial and operational infrastructure of cartels and TCOs. Latin America has emerged as a central arena for using this approach, where these tools are being deployed in tandem and, at times, alongside broader geopolitical measures, as illustrated by the apprehension and prosecution of Nicolás Maduro.

The implications are significant, and the takeaway is apparent: Latin America is a priority for the DOJ. Companies with Latin American business interests should reassess their compliance programmes, sharpen their internal controls and be prepared for heightened scrutiny across anti-corruption, sanctions and anti-money laundering fronts.