Editor’s notes

‘The tariff issue is a controversial one, but for Puerto Rico, it’s a great opportunity.’

So said Puerto Rico Governor Jenniffer González-Colón in May of 2025, of the Trump administration’s various announcements of ‘reciprocal tariffs’ on all countries not subject to other sanctions, including an increase of tariffs on steel and aluminium imports from 25% to 50%.

Despite the continued residual fallout from the devastation of Hurricane Fiona (which struck in September 2022) and the IMF’s projection for 2025 placing GDP growth at -0.8%, in addition to ongoing power outages, recent developments continue to suggest potential for a more optimistic direction for Puerto Rico’s economic future.

In March 2022, the nation formally exited bankruptcy, following what was reported to be the largest public debt restructuring in US history. Stepping out of the shadow of over $70bn in debt, the country was finally free to repay bondholders, settle approximately $1bn-worth of claims by residents and local businesses, issue over $10bn in bonds and reimburse the public pension system up to $1.3bn.

In March 2023, former Governor Pedro Pierluisi, addressing repeated power outages and rising energy costs, announced the approval by the US Federal Emergency Management Agency of microgrid projects to supply the entirety of the power to the island municipalities of Vieques and Culebra, both popular tourist destinations, in addition to an infusion of $100m in federal funds to create a voucher programme to cover up to 30% of the costs of installing battery-backed solar systems in the homes of residents. In October 2024, the US Environmental Protection Agency announced Puerto Rico would receive $67m in funding to bolster its drinking water and wastewater infrastructure.

Such steps, combined with the unveiling of a new fiscal plan for a complete overhaul of Puerto Rico’s education, tax and infrastructure sectors by the federal control board that oversees the nation’s finances (in April 2023), and a boom in manufacturing and a drive in the wake of US global tariffs to encourage multinational companies to move their manufacturing facilities to the island (where they would be tariff-exempt), indicate the potential for an upward economic trend (though one accompanied by a share of uncertainty), as reflected by the legal market.

In the corporate, commercial and banking space, respondent firms described a soft market for M&A deals, with clients expressing concerns regarding the effects of US tariffs on their international supply chains. Firms interviewed also noted a trend by international clients toward consolidation, particularly in the real estate sector. In the dispute resolution arena, firms described a steady commercial litigation landscape, with an uptick in consumer class action law suits and tax litigation. In labour and employment, firms describe their anticipation of the impact of the Fundamental Right to Religious Freedom in Puerto Rico Act (a measure relating in part to vaccination and pandemic-related policy) which states that the Government ‘may provide reasonable accommodation to any employee who requests it promptly based on religious beliefs’. Other firms cite the policies of the Trump administration in relation to their effect on DEI programmes. In real estate, respondent firms describe a slowdown in deals in the residential sphere. In tax, teams point to the positive effects of tax incentives on a booming market for advising high-net-worth individuals on estate planning.

In the legal market, full-service firms McConnell Valdés LLC, O'Neill & Borges and Pietrantoni Méndez & Alvarez LLP continue to dominate in most practice areas, although other prominent domestic firms include Ferraiuoli LLC (a key force in the market in the IP space, along with Sifre Group), Littler Mendelson, P.C. (a leader in labour and employment), Estrella LLC, Marini Pietrantoni Muñiz, LLC, and Toro Colón Mullet, P.S.C. (a leader in matters relating to energy, natural resources and the environment). International firms DLA Piper Puerto Rico and ECIJA SBGB also have a strong foothold in the market.

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US sanctions two Mexican Cartels and key individuals

Written by: Nereida Melendez-Rivera, Sonia Torres Pabón, Antonio Cardenas Arriola, Isabel Lecompte The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced significant new sanctions targeting two major Mexican criminal organizations – Carteles Unidos and Los Viagras – along with seven affiliated individuals. These actions are part of a broader US government effort to disrupt the operations of cartels responsible for violence, drug trafficking, terrorism, and widespread extortion, particularly in Mexico’s agricultural sector. In this alert, we highlight the designated entities and individuals targeted by the sanctions. In addition, we discuss legal and compliance implications and set out key takeaways for companies that may be exposed to risk from the sanctions. Background on the sanctioned organizations Carteles Unidos Carteles Unidos originated in Michoacán, México as a defensive alliance against the Jalisco Nueva Generación Cartel (CJNG). It has since evolved into a major criminal enterprise. Its activities include large-scale drug production and trafficking, extortion, arms smuggling, and violent confrontations with both rival organizations and authorities. The group is primarily active in central and western Mexico, but its influence is expanding transnationally. The US government has designated Carteles Unidos as a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT), and it is subject to extensive US sanctions due to its involvement in illicit activities. Los Viagras Los Viagras is a Michoacán-based criminal organization involved in trafficking methamphetamine and cocaine. In its conflict for control of Michoacán, Los Viagras has recently allied with CJNG, one of the two Mexican cartels primarily responsible for the supply of illicit fentanyl into the US. Furthermore, Los Viagras has extorted avocado and citrus growers, cattle ranchers, and entire towns to generate revenue. Los Viagras has also conducted kidnappings and attacked Mexican security forces. Sanctioned individuals The following individuals have been sanctioned for their affiliation with the above-mentioned organizations: Juan Jose Farías Álvarez (“El Abuelo”) Luis Enrique Barragán Chavez (“Wicho”) Alfonso Fernández Magallón (“Poncho”) Edgar Valeriano Orozco Cabadas (“El Kamoni”) Nicolás Sierra Santana (“El Gordo”) Heladio Cisneros Flores (“La Sirena”) César Alejandro Sepúlveda Arellano (“El Botox”) Legal and compliance implications As a result of the sanctions, all property and interests in property of the designated entities and individuals within the US or in the possession or control of US persons are now blocked and must be reported to OFAC. US persons are generally prohibited from engaging in transactions involving these blocked persons or their property. Entities that are owned 50 percent or more, directly or indirectly, by one or more blocked persons are also subject to these restrictions. Violations of these sanctions can result in significant civil or criminal penalties. OFAC may impose civil penalties on a strict liability basis, which means that a violation can result in penalties even if there was no intent to violate the sanctions. Financial institutions and other parties may also face secondary sanctions for facilitating significant transactions with designated persons. Key considerations In response to potential violation of these sanctions, entities may consider the following actions: Reviewing all third-party relationships to identify potential exposure or risks related to the newly sanctioned organizations and persons Conducting enhanced due diligence on business relationships and transactions involving México, especially in regions or industries known to be affected by cartel activity Updating and strengthening compliance protocols, particularly for operations and transactions involving Latin America and México Monitoring for additional designations and regulatory changes, as the enforcement landscape is evolving rapidly and new sanctions may be announced at any time In addition, foreign financial institutions should be aware of the risk of secondary sanctions for knowingly facilitating significant transactions for or on behalf of designated entities or persons. For guidance on risk mitigation and compliance strategies, please contact the authors. Leer este artículo en español.
DLA Piper - September 4 2025