Alejandro Gomez-Strozzi Examines Expanded US Enforcement Risk for Mexican Companies
鶹ֱ & Lardner LLP partner Alejandro Gomez-Strozzi assessed how the U.S. government’s expanded sanctions scope and extraterritorial enforcement regime have created a heightened regulatory environment for Mexican companies dependent on international trade in his El Universal article, “.”
Gomez-Strozzi explores how the U.S. designation of certain Mexico‑based criminal groups as Foreign Terrorist Organizations (FTO) and Specially Designated Global Terrorists (SDGT) is expanding legal and compliance risks for businesses operating in Mexico. He highlights how broad liability standards, including “nexus” connections, are exposing companies to heightened scrutiny across complex supply chains and redefining expectations for due diligence in cross‑border operations.
“Mexico now faces a silent dilemma: maintaining economic integration with the United States inevitably implies internalizing the regulatory risks that accompany that relationship,” he writes. “Ignoring those risks does not eliminate them; it simply moves them to the most vulnerable point in the system, and that point, more and more frequently, is the company that does not know that it is exposed.”
Gomez-Strozzi explains that risk is no longer confined to direct counterparties, as complex, multi‑tiered supply chains can expose companies through indirect financial, logistical, or commercial links. He notes that this evolving landscape is rendering traditional compliance approaches insufficient and raising expectations for deeper visibility into business networks and operational relationships.
“Today, the cost of doing business with the United States is no longer measured solely in tariffs or contractual obligations, but in a company’s ability to demonstrate that there is no direct or indirect connection to designated foreign terrorist actors, as well as to understand the complex web of legal and regulatory powers available to the U.S. government to generate immediate risk exposure to any company with operating business ties to the United States,” Gomez-Strozzi concludes.
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