Since day one, the second Trump administration has focused on the "total elimination" of cartels and transnational criminal organizations (TCOs). One of the most notable parts of this strategy has been the designation of various cartels and TCOs as Foreign Terrorist Organizations (FTOs). 

Over the past 10 months, Secretary of State Marco Rubio has designated 13 cartels and TCOs operating throughout Latin America as FTOs. This trend will likely continue with additional designations of cartels active in the region. 

As of September 2025, the following cartels and TCOs operating in Latin America have been designated as FTOs by the Department of State:

We have updated our maps showing where these cartels and TCOs operate within Latin America.¹

As discussed here and here, the designation of cartels and TCOs as FTOs significantly increases the legal and compliance risks for companies operating in Latin America. These designations mean that companies can be criminally and civilly liable for providing "material support" to FTOs. Material support is broadly defined and can include payments, services, transportation, or resources. U.S. companies may face liability for providing material support, even if the relevant transaction occurs entirely outside the U.S. or the transaction occurs in local currency. 

Businesses operating in Latin America should assess and continually monitor their risk, especially risks associated with potential links to FTOs. This effort is particularly important as new cartels and TCOs, operating in different parts of Latin America, are designated, giving rise to new or heightened risks. Companies should also review their risk mitigation strategies, ensure that their due diligence procedures are robust and tailored to FTO-related exposure, and implement additional controls to avoid unwanted interactions with cartels and TCOs. 

Click the maps to see them at full size.

For more information, please contact:

Matteson Ellis, mellis@milchev.com, 202-626-1477

Maria Elena Lapetina, mlapetina@milchev.com, 202-626-1586

James G. Tillen, jtillen@milchev.com, 202-626-6068

Facundo Galeano, fgaleano@milchev.com, 202-626-5961

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¹These maps are based on data provided by insightcrime.org and other global and local sources. 

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