Sanctions Evasion and the Growing Threat of Transnational Criminal Organizations

As published in Finextra. 

Steve Marshall, Director of Advisory Services at FinScan, explains how the focus on Russian sanctions is now being matched by increasing concern, especially in the US, over transnational criminal organizations (TCOs) such as Latin American cartels now formally designated under Executive Order 14157 as Foreign Terrorist Organizations or Specially Designated Global Terrorists in early 2025. These TCOs leverage complex evasion tactics—from shell companies and opaque ownership structures to shadow financial networks and covert logistics—to move illicit proceeds across borders, complicating AML and sanctions compliance.  

Steve emphasizes that their geographic reach extends well beyond Latin America, with cartels operating globally and exploiting gaps in regulatory oversight. His article underscores how this evolving threat demands financial institutions step up due diligence, enhance ownership transparency, and deploy more sophisticated transaction monitoring—especially as landscape-shifting designations now carry criminal penalties for material support. Without coordinated cross-border intelligence, advanced screening tools, and strengthened governance, institutions risk being outmaneuvered by these multifaceted and fast-moving criminal networks. 

Read the full article