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Organised crime and FTO exposure

Know which of your Latin American partners carry FTO exposure

Exposure can sit with a supplier, a warehouse, a union representative or a customs broker. Get a sourced, defensible view of which of your relationships carry risk, and what to do about each one.

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Toned street scene in northern Mexico
The situation

Where the risk actually sits

The company on your contract is rarely where the exposure shows up. It sits in the customs post, the security contractor, the unionized worker driving the truck that moves cargo to port, and the warehouse whose real owner may not be the one on file.

Since the 2025 FTO designations, those are the relationships your counsel will ask about.

What's at stake

The penalties are severe

Providing material support to a designated foreign terrorist organisation is a US federal crime, carrying prison terms of up to 20 years. Companies can also face civil claims from victims seeking triple damages.

In 2022, Lafarge became the first company to plead guilty to providing material support to designated terrorist groups, and agreed to pay around $778 million. Its Syrian subsidiary had paid armed groups, including ISIS, to keep a cement plant operating through the conflict. These were payments to protect operations, the same pattern companies face with extortion in parts of Latin America today.

The exposure doesn't end with a criminal case. In 2024, a US jury found Chiquita liable to victims' families over payments it made to a designated group in Colombia two decades earlier.

How we help

A risk-tiered view of every relationship that matters

Ownership checked against the registry.

Claimed owners and operating relationships compared with actual corporate filings.

Relationships checked against organised crime and FTO data.

Your suppliers and service providers cross-referenced with our data on designated criminal groups and the businesses around them.

Insight from the ground.

Discreet inquiries with people who know the people, ports, warehouses and routes your operation uses.

The security picture, assessed.

What authorities have put in place, and where gaps remain at the facility level.

How peers are managing it.

A benchmark of how similar companies handle the same exposure.

A clear tier for every relationship.

Continue, apply enhanced due diligence, or avoid, with alternative routes or counterparties where needed.

Case study

See how this works in practice

Aerial view of an open-pit mine
Mining company, Mexico

Restructuring artisanal supply to manage organised crime risk

28
artisanal miners brought into one consortium

The question

Where and how has organised crime reached our relationships with the local artisanal mining community?

What we found

A few of the miners were directly connected to an FTO-designated organised crime group. Most of the others were local entrepreneurs trying to make a living.

What happened next

The client formed a consortium of 28 artisanal miners with shared pricing, monthly quotas and rules. Two were later removed for breaking them.

FAQ

Frequently asked questions

Does an FTO designation matter if none of our counterparties are sanctioned?

It can. Sanctions screening only catches names already listed, while liability for support that reaches a designated group can arise indirectly. Your counsel can advise on your exposure, and we give them the evidence to work from.

What if the risk is spread across a whole port or region?

Then the question becomes which facilities and providers carry more exposure than the baseline. We rank them against each other so you can decide where to operate, not only whether to.

Can you assess a location before we start operating there?

Yes. Many engagements are commissioned ahead of a go or no-go decision on a port, route or market.

Is it safe to investigate companies with suspected links to organised crime?

Inquiries are discreet and handled by investigators who know the local environment. Your company is not identified to the people we speak with.

Can we share the findings with our counterparties?

Yes. The risk-tiered memo is written so your compliance team can hand it to a counterparty's legal or compliance team where relevant.

Start with the port, route or partner that concerns you

Tell us where you operate or plan to. We'll outline what we would assess and what the engagement would involve.