Overview
Agenda
Speakers
Foreign Terrorist Organizations (FTOs) and Cartels:
Trump Administration Focus Creates Risks for Companies
Tue., April 1
2-3 pm EDT
Webinar
On his first day in office, President Trump signed an executive order (E.O.) directing the Secretary of State to designate several cartels as Foreign Terrorist Organizations (FTOs). In response, on February 19, 2025, the Secretary of State designated eight cartels operating throughout Mexico, Colombia, Honduras, Guatemala, Venezuela, and El Salvador as FTOs. On February 5, 2025, AG Pam Bondi issued a memorandum to U.S. Department of Justice personnel entitled “Total Elimination of Cartels and Transnational Criminal Organizations.” As with the E.O., the Memorandum highlights the use of terrorism charges to prosecute members and associates of cartels and TCOs. However, the Memorandum also identifies other laws to use in addressing cartel activity. In particular, it directs the DOJ Criminal Division’s Foreign Corrupt Practices Act (FCPA) Unit to “prioritize investigations related to foreign bribery that facilitates the criminal operations of Cartels and TCOs, and shift focus away from investigations and cases that do not involve such a connection.” The Memorandum also directs the DOJ Criminal Division’s Money Laundering and Asset Recovery Section to “prioritize investigations, prosecutions, and asset forfeiture actions that target activities of Cartels and TCOs.”
Given the extent of cartel-activity in Latin America, a wide range of industries now face new and heightened enforcement risks. For example, companies that operate in remote or conflict-affected areas (for example, in the security, extractives, agriculture, and telecommunications sectors) may come into contact with cartels that have infiltrated local economies, communities, and governments. In addition, cartels may attempt to use logistics, transportation, or air travel providers to transport narcotics, weapons, and people in connection with their criminal activities. Cartels may also seek to do business with manufacturers of weapons, chemicals that could be used in the manufacture of narcotics, and agricultural products used in the growing or harvesting of drugs.
This webinar will focus on the following topics:
- Potential for criminal and civil liability for companies providing “material support” to FTOs under the U.S.’s Anti-Terrorism Act (ATA)
- Use of FCPA and anti-money laundering laws to prosecute cartel activity
- Risk areas for companies operating in regions where cartels are active, including real-life example
- Strategies for mitigating risk
Register using the red button on the upper right corner to receive the Zoom link.
This event is exclusively for ISOA members.
Speakers
James G. Tillen
Co-Practice Lead – FCPA & International Anti-Corruption, Miller & Chevalier
Michael K. Atkinson has led some of the most significant criminal fraud, public corruption, and national security cases in the United States and offers clients a rare combination of extensive knowledge of both criminal white collar defense and corporate compliance. Michael is the former presidentially appointed and Senate-confirmed Inspector General of the U.S. Intelligence Community in the Office of the Director of National Intelligence, and he previously served in senior Department of Justice roles spanning two decades in the National Security Division, the Criminal Division, and the U.S. Attorney’s Office for the District of Columbia, where he headed the Fraud and Public Corruption Section. Michael has been publicly described as “unflappable,” “meticulous,” one you “trust with investigations,” and a lawyer who handles himself with “class,” “intelligence,” “sensitivity,” and “strength.” He co-leads the firm’s National Security Practice Group.
Jessica Tillipman
Associate Dean for Government Procurement Law Studies; Government Contracts Advisory Council Distinguished Professorial Lecturer in Government Contracts Law, Practice & Policy, GW Law
Jessica Tillipman is the Associate Dean for Government Procurement Law Studies and Government Contracts Advisory Council Distinguished Professorial Lecturer in Government Contracts Law, Practice & Policy. She is an internationally recognized expert specializing in integrity, compliance and emerging technology issues in government procurement law.
Michael K. Atkinson
Partner, Crowell & Moring
Michael K. Atkinson has led some of the most significant criminal fraud, public corruption, and national security cases in the United States and offers clients a rare combination of extensive knowledge of both criminal white collar defense and corporate compliance. Michael is the former presidentially appointed and Senate-confirmed Inspector General of the U.S. Intelligence Community in the Office of the Director of National Intelligence, and he previously served in senior Department of Justice roles spanning two decades in the National Security Division, the Criminal Division, and the U.S. Attorney’s Office for the District of Columbia, where he headed the Fraud and Public Corruption Section. Michael has been publicly described as “unflappable,” “meticulous,” one you “trust with investigations,” and a lawyer who handles himself with “class,” “intelligence,” “sensitivity,” and “strength.” He co-leads the firm’s National Security Practice Group.
Tuesday, April 1
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James Tillen
Practice Co-Lead, FCPA & International Anti-Corruption, Miller & Chevalier Chartered
James Tillen's practice focuses on cross-border investigations and compliance matters involving corruption, fraud, money laundering, business and human rights, workplace conduct, and other areas of international corporate compliance. He works with U.S. and non-U.S. clients to address compliance challenges that arise in a variety of contexts, including compliance program design and implementation, transactional counseling, advisory opinions, internal investigations, enforcement actions by the U.S. Department of Justice (DOJ), Securities and Exchange Commission (SEC), and other enforcement authorities, and FCPA monitorships. Mr. Tillen also has conducted merger and acquisition (M&A) and third-party due diligence reviews, assessed client and third-party compliance programs, developed training programs, and performed training for client operations throughout the world.
Who's Who Legal and Global Investigations Review recognize Mr. Tillen as one of the world's leading investigations lawyers, and one source said he "knows FCPA enforcement better than anyone I've ever come across." The "very business savvy" Tillen is "practical, responsive and has excellent, highly particularized experience," according to clients who were quoted by Chambers USA and Chambers Global.
Jessica Tillipman
Associate Dean for Government Procurement Law Studies; Government Contracts Advisory Council Distinguished Professorial Lecturer in Government Contracts Law, Practice & Policy, GW Law
Jessica Tillipman is the Associate Dean for Government Procurement Law Studies and Government Contracts Advisory Council Distinguished Professorial Lecturer in Government Contracts Law, Practice & Policy. She is an internationally recognized expert specializing in integrity, compliance and emerging technology issues in government procurement law.
She teaches the law school's foundational government procurement law course, Formation of Government Contracts, and Anti-Corruption & Compliance, a course that focuses on anti-corruption, ethics, and compliance issues in government procurement.
Prior to joining GW Law, Dean Tillipman served as a law clerk to the Honorable Lawrence S. Margolis of the U.S. Court of Federal Claims and was an associate at Jenner & Block, where she specialized in Government Contracts and White Collar Criminal Defense.
Dean Tillipman served as Senior Editor of the “The FCPA Blog”—a leading Foreign Corrupt Practices Act resource on the internet. She has also published numerous articles that address legal and policy issues involving anti-corruption, government procurement, white-collar crime, government ethics, and artificial intelligence.
Dean Tillipman is also a Senior Advisor to the American Bar Association, International Anti-Corruption Committee, a Faculty Advisor to the Public Contract Law Journal, a member of the National Contract Management Association Board of Advisors, and an Advisory Board member of The Government Contractor. She frequently organizes and presents at domestic and international government procurement and anti-corruption conferences and colloquia, and her legal commentary has been featured in numerous domestic and international media outlets.
Dean Tillipman is a member of the bars of the United States Court of Federal Claims, the state of Virginia, and the District of Columbia. She graduated cum laude from Miami University (Oxford, OH) in 2000 and obtained her JD, with honors, from the George Washington University Law School in 2003.
Learn more about GW Law's Government Procurement Law Program.
Michael K. Atkinson
Partner, Crowell & Moring
Michael K. Atkinson has led some of the most significant criminal fraud, public corruption, and national security cases in the United States and offers clients a rare combination of extensive knowledge of both criminal white collar defense and corporate compliance. Michael is the former presidentially appointed and Senate-confirmed Inspector General of the U.S. Intelligence Community in the Office of the Director of National Intelligence, and he previously served in senior Department of Justice roles spanning two decades in the National Security Division, the Criminal Division, and the U.S. Attorney’s Office for the District of Columbia, where he headed the Fraud and Public Corruption Section. Michael has been publicly described as “unflappable,” “meticulous,” one you “trust with investigations,” and a lawyer who handles himself with “class,” “intelligence,” “sensitivity,” and “strength.” He co-leads the firm’s National Security Practice Group.
Michael conducts sensitive internal investigations and advises publicly traded and privately held corporations, academic institutions, national laboratories, and individuals across the spectrum of internal and government investigations, including criminal trials, regulatory enforcement actions, and congressional investigations. With a focus on national security, white collar defense, procurement fraud, and public corruption, he draws on his 30 years of experience to conduct internal investigations, negotiate favorable resolutions, lead trial teams, and advise on remedial measures, compliance programs, and training. Michael is valued by his clients as a strategic adviser, an effective trial lawyer, and a trusted counsel.
As the Intelligence Community’s top watchdog, Michael had oversight responsibility for the IC’s initial efforts to adopt and implement ethical principles and increased transparency for programs involving artificial intelligence (AI). At Crowell & Moring, Michael advises organizations on the emerging regulations, laws, enforcement actions, and public policies around AI. He is also a professorial lecturer in law on artificial intelligence law and policy at The George Washington University Law School.
Michael’s recent engagements include representing academic institutions in matters involving alleged violations of government procurement and U.S. export controls and sanctions laws and regulations; representing publicly traded and privately held companies in national security matters, including export controls investigations, Foreign Corrupt Practices Act matters, and other alleged business crimes; representing technology companies and defense contractors in AI legal, regulatory, and compliance strategies; and representing individuals accused of financial fraud and campaign finance violations.