In this article, Brian Fleming* and Alejandra Montenegro Almonte discuss the growing U.S. sanctions risks for Latin American and Caribbean companies. Fleming and Almonte explain that U.S. sanctions are proliferating rapidly and are being deployed more aggressively in the region, which could put a strain on companies' relationships with sanctions-averse financial institutions and signal an increase in government investigations and enforcement activity that will more closely resemble current enforcement of the Foreign Corrupt Practices Act (FCPA). "Now, armed with sanctions tools focused on human rights abusers and corrupt government officials, the Trump administration may be poised to take a more aggressive approach to sanctions enforcement in the region. Companies with significant cross-border business should be particularly vigilant," they wrote.

*Former Miller & Chevalier attorney