Greenberg Traurig Shareholders Benjamin Greenberg and Kyle Freeny are leading a discussion on the far-reaching global sanctions that the United States and other Western Allies have imposed in response to Russia's invasion of Ukraine. When President Biden took office in January 2021, the prevailing view was that his administration would step up regulatory and criminal enforcement efforts in Latin America, including through the use of existing resources, such as the FBI’s Miami International Corruption Squad, and recently enacted legislation, like the so-called Engel’s list, which the U.S. intended as a foreign policy tool to target corruption in Central America.
Given the Biden administration’s existing enforcement posture and more recent concerns about Russia, including the extent of Russian influence in Latin America, it is expected that U.S. sanctions and related civil and criminal enforcement efforts will have even greater implications for companies doing business in Latin America.