Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists

January 20, 2025
Presidential Actions

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Action Summary:

  • Purpose: Designate international cartels and organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists to address national security threats posed by their violent activities.
  • Threat Assessment: Cartels engage in terrorism, violence, and drug trafficking, destabilizing the Western Hemisphere and threatening U.S. safety and security.
  • Declared Emergency: A national emergency under IEEPA is declared to tackle threats from cartels and similar transnational organizations like TdA and MS-13.
  • Policy Goal: Eliminate the presence and influence of these organizations within the U.S. to protect national territory and safety.
  • Implementation Plan: Within 14 days, the Secretary of State will recommend designations; Attorney General and Homeland Security will prepare for potential removals under the Alien Enemies Act.
  • General Provisions: The order maintains existing legal authorities and does not create enforceable rights against the U.S. entities.

Risks and Considerations

  • Legal and Compliance Risks: The designation of cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs) imposes strict legal and financial restrictions on entities that interact with such groups, potentially impacting organizations working in security, law enforcement consulting, or international relations.
  • Operational Disruptions: Increased security actions, including expedited removal processes and potential use of the Alien Enemies Act, could lead to changes in federal agency operations, resulting in disruptions for consulting firms engaged with affected agencies.
  • Client Impact and Engagement Risks: Government clients, especially in the Department of Justice, Homeland Security, and State Department, may shift priorities toward counterterrorism strategies, altering consulting needs and potentially disrupting existing contracts.
  • Reputational and Ethical Considerations: Consulting firms may face reputational risks if involved in advisory roles on policies with high political and human rights implications, particularly concerning immigration enforcement and national security strategies.
  • Geopolitical and Business Uncertainty: Heightened enforcement and foreign policy shifts related to cartel operations could present challenges for private-sector clients with supply chains or partnerships in Latin America, necessitating risk assessments for corporate clients.

Business Implications

The Clearing should monitor changes in federal contracting priorities, particularly in law enforcement and security fields. Additionally, leadership and strategy consulting efforts may need to address internal disruptions in organizations managing policy shifts tied to counterterrorism efforts. Firms engaging in government consulting must ensure alignment with evolving regulations to mitigate compliance and reputational risks.

Relevance Score: 4

Key Actions:

  • Monitor policy shifts related to cartel and transnational organization designations, as these may impact government contracts involving homeland security and law enforcement agencies.
  • Advise clients in affected sectors (defense, immigration services, law enforcement) on strategic adjustments in response to the national security emergency declaration.
  • Assess potential changes in government procurement and security policies that may lead to new consulting opportunities or compliance requirements.
  • Prepare leadership strategies for government agencies undergoing operational changes due to increased focus on cartel-related security threats.

Relevance Score: 4

Average Relevance Score: 4.0

Timeline for Implementation

14-day deadline for action by Secretary of State, Attorney General, and Secretary of Homeland Security, starting January 20, 2025.

Relevance Score: 5

Impacted Government Organizations:

  • Department of State (DOS)
  • Department of the Treasury (DOT)
  • Department of Justice (DOJ)
  • Department of Homeland Security (DHS)
  • Office of the Director of National Intelligence (ODNI)

Relevance Score: 2

Responsible Officials

  • Secretary of State – Leading the designation of cartels and organizations as Foreign Terrorist Organizations or Specially Designated Global Terrorists.
  • Secretary of the Treasury – Providing input on financial and economic sanctions against designated entities.
  • Attorney General – Coordinating legal actions and operational preparations for enforcement.
  • Secretary of Homeland Security – Preparing operational responses for enforcement and removals.
  • Director of National Intelligence – Assisting in intelligence assessments related to designated organizations.

Relevance Score: 5 (Impacts multiple Cabinet officials, signaling a highly significant national security policy shift).