The International Enforcement Law Reporter

The International Enforcement Law Reporter is a monthly print and online journal covering news and trends in international enforcement law.

Since September 1985, the International Enforcement Law Reporter has analyzed the premier developments in both the substantive and procedural aspects of international enforcement law. Read by practitioners, academics, and politicians, the IELR is a valuable guide to the difficult and dynamic field of international law.

US District Court in Texas Blocks Trump Administration’s Use of the Alien Enemies Act

Friday, May 9, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
6
Abstract: 

On April 30, U.S. District Judge Fernando Rodriguez issued a 36-page opinion permanently barring the Trump administration from invoking the Alien Enemies Act (AEA) to deport Venezuelans it has deemed to be criminals from the Southern District of Texas, finding that the White House’s use of the statute was illegal.

U.S. Supreme Court Requires Due Process Before Deportation Under the Alien Enemies Act, as Judge Boasberg Finds Probable Cause for Criminal Contempt

Friday, May 9, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 7, 2025, Justice Roberts, in a per curiam opinion, ruled that the Trump administration could appeal and then vacated the Temporary Restraining Orders issued by Judge Boasberg. The opinion held that the detainees are entitled to notice and opportunity to be heard “appropriate to the nature of the case.” Meanwhile, on April 16, Judge Boasberg issued an order finding probable cause to find the Government in criminal contempt.

US Supreme Court Rules that Wrongly Deported Migrant Must Have Hearing and 4th Circuit Denies Government’s Emergency Stay Request

Friday, May 9, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 10, 2025, in an unsigned order, the U.S. Supreme Court unanimously ordered the government to try to return a Salvadoran national and U.S. permanent resident, Abrego Garcia, whom it had wrongly deported to a terrorist prison in El Salvador. However, the Court also observed that the courts may not have the authority to require the executive branch to return him. After the order, U.S. District Judge Paula Xinis attempted to force the administration to communicate its efforts, or lack thereof, to facilitate Abrego Garcia’s release. Instead, the administration made an emergency appeal and request for a stay, which the Court of Appeals for the Fourth Circuit quickly and unanimously rejected.

Europol Disrupts Criminal Organization Smuggling Hazardous Salvage Cars from the US

Friday, May 9, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 16, 2025, Europol issued a press release discussing a law enforcement action targeting an international organization allegedly engaging in smuggling badly damaged cars from the United States into the European Union and selling them to end customers after superficial repair. The crimes included defrauding the payment of customs duties and the commission of large-scale value-added tax (VAT) fraud, as well as defrauding consumers as to the status of the automobiles.

FinCEN Renews Residential Real Estate Geographic Targeting Orders

Friday, May 9, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 14, 2025, the Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs), mandating U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed acquisitions of residential real estate.

Crypto Enforcement Overhaul: Shift from Policing Platforms to Investor Protection

Monday, May 5, 2025
Author: 
Christina Gotsis and Jason Gottlieb
Volume: 
41
Issue: 
5
Abstract: 

On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Memorandum”) to all Department of Justice (DOJ) employees, announcing a significant shift in the Department’s digital asset enforcement priorities.[1]



[1] Todd Blanche, Deputy Att’y Gen., Dep’t of Justice, Memorandum for all Department Employees, https://www.justice.gov/dag/media/1395781/dl?inline (Accessed April 28, 2025).

 

EU Court Holds Maltese Investor Citizenship Scheme Violates EU Law

Monday, May 5, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 29, 2025, the Court of Justice of the European Union (CJEU) decided that the Maltese investor citizenship scheme violates EU law and that the acquisition of EU citizenship cannot result from a commercial transaction.[1]



[1] European Commission v. Republic of Malta, Case C-181/23, ECLI:EU:C:2025:283, April 29, 205

 

U.S. Indicts Beekeeper for Concealing Genocidal Participation in Rwanda

Monday, May 5, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 22, 2025, a federal grand jury in Central Islip, New York, returned an indictment, which the U.S. Department of Justice unsealed on April 24, charging a man living in Long Island, New York with lying on his applications for permanent residency and citizenship by concealing his past role as a leader and perpetrator of the genocide in Rwanda.[1]



[1]  U.S. Department of Justice, New York Man Charged with Immigration Fraud for Concealing Role as Perpetrator of Rwandan Genocide, April 4, 2025.

 

Trump Administration Proposes to Eliminate Office of Global Criminal Justice

Friday, April 25, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
5
Abstract: 

On April 22, 2025, Secretary of State Marco Rubio proposed a significant reform of the U.S. State Department that would close the Office of Global Criminal Justice (GCJ) and the Bureau of Conflict and Stabilization Operations (CSO). The proposal will also close the office dealing with refugees and migration.[1]

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