Dear Clients and Friends:
In July 2026, the United States Government expanded the list of Mexican criminal organizations designated as Foreign Terrorist Organizations (“FTOs”) and Specially Designated Global Terrorists (“SDGTs”), adding the Juárez Cartel and Los Viagras. These organizations join the six Mexican cartels previously designated in February 2025: (i) the Sinaloa Cartel, (ii) the Jalisco New Generation Cartel (CJNG), (iii) the Gulf Cartel, (iv) the Northeast Cartel, (v) La Nueva Familia Michoacana, and (vi) Cárteles Unidos.
Although these designations do not directly alter the Mexican legal framework, they represent a significant development in the compliance and risk management landscape for companies operating in Mexico, particularly those that maintain connections to the United States through shareholders, investors, directors, officers, employees, financial institutions, or supply chains.