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.

France Asserts Passive Personality Jurisdiction in Investigation of Alleged Israeli Abuse of Flotilla Activists

Friday, June 26, 2026
Author: 
Abigail Lee
Volume: 
42
Issue: 
7
Abstract: 

                On June 5, 2026, the French National Antiterrorism Prosecutor’s Office (PNAT) announced a preliminary investigation into the treatment of French activists by Israeli authorities during a maritime interception in May 2026.  The PNAT initiated this inquiry following a formal referral from the French Foreign Ministry, representing a significant shift in the use of domestic judicial mechanisms to address alleged violations of international law by a state partner.  The investigation focuses on allegations of torture, war crimes, and sexual violence arising from the interception of the Global Sumud Flotilla en route to the Gaza Strip.   This operation led to the detention of over 400 international activists, including French, Italian, Spanish, and Australian nationals.  The flotilla, intercepted in international waters, aimed to deliver humanitarian aid to address the ongoing crisis in the enclave.

U.S. Supreme Court Ends Alien Tort Claims

Friday, June 26, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
7
Abstract: 

              On June 23, 2026, the U.S. Supreme Court in Cisco Systems, Inc. v. Doe effectively ended the ability to bring actions under the 1789 Alien Tort Statute (ATS). [1]  The opinion by Justice Amy Coney Barrett for a six-member majority held that federal courts cannot adjudicate human rights claims under the ATS.  Although not expressly, the decision de facto overrules the Court’s decision in Sosa v. Alvarez-Machain, 542 U.S. 692 (2004). The opinion explained that “courts may not create new causes of action for violations of international norms.[2]

DOJ’s Arrest of Iranian-American Jamshid Ghomi

Friday, June 26, 2026
Author: 
Jaccaranda Woldemariam
Volume: 
42
Issue: 
7
Abstract: 

              On June 3, 2026, dual Iranian-American citizen Jamshid Ghomi was arrested and charged with conspiracy to violate the International Emergency Economic Powers Act (IEEPA), in accordance with the federal criminal complaint filed against him.  In his court appearance on the day of his arrest, Ghomi entered no plea. The following day, he was denied bail and ordered to be held without release by Judge Douglas McCormick in federal court despite his attorney, Greg Bernstein, arguing that Ghomi has local ties to Newport Coast due to his wife and two sons being there as well as his heart health issues preventing flight to another country

NGO Brings War Crimes Complaint against Sudan’s Paramilitary Forces in Kenya

Thursday, June 18, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
7
Abstract: 

                A non-governmental organization has brought the first complaint to prosecute members of the Rapid Support Forces (RSF), for war crimes in Sudan.  The RSF is the paramilitary group fighting against the Sudanese military for over three years.  The complaint -- on behalf of victims of alleged atrocities resulting from the conflict -- asks prosecutors in Kenya to investigate allegations of torture and sexual violence by members of the RSF.

U.S. Unseals Charges against Raul Castro and Others for 1996 Shoot Down of Brothers to the Rescue Aircraft

Thursday, June 18, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
7
Abstract: 

On May 20, 2026, the United States Department of Justice (DOJ) announced the unsealing of a superseding indictment charging Raul Modesto Castro Ruz, along with Lorenzo Alberto Perez-Perez; Emilio José Palacio Blanco; José Fidel Gual Barzaga; Raul Simanca Cardenas; and Luis Raul Gonzalez-Pardo Rodrigue, for their alleged roles in the February 24, 1996 shoot-down of two unarmed U.S. civilian aircraft operated by Brothers to the Rescue (BTTR), also known as Hermanos al Rescate, over international waters.

 

 

U.S. Advisory on SARs on On-Work Authorized Persons and Their Employers

Thursday, June 18, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
7
Abstract: 

On June 5, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN),  jointly with the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and National Credit Union Administration (collectively, the Agencies), issued an advisory in coordination with the International Revenue Service (IRS) to advise financial institutions, especially banks, to be vigilant against fraud schemes and other suspicious or potentially criminal activities concerning the unlawful employment of illegal aliens.

 

 

The United States Designates Two Infamous Brazilian Gangs as Foreign Terrorist Organizations

Thursday, June 18, 2026
Author: 
Dimitris Konstantopoulos
Volume: 
42
Issue: 
7
Abstract: 

On May 28, 2026, the United States Department of State formally designated two Brazilian gangs, Comando Vermelho (CV) and Primeiro Comando da Capital (PCC), as specially designated global terrorists (SDGT) and Foreign Terrorist Organizations (FTO). The Trump administration is justifying its designation by claiming that both the PCC and the CV launched attacks against police and military targets across Brazil, traffic drugs throughout Brazil and the rest of the Americas, and maintain worldwide criminal networks

 

 

U.S. Unseals Charges against Raul Castro and Others for 1996 Shoot Down of Brothers to the Rescue Aircraft

Friday, June 12, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
7
Abstract: 

               On May 20, 2026, the United States Department of Justice (DOJ) announced the unsealing of a superseding indictment charging Raul Modesto Castro Ruz, along with Lorenzo Alberto Perez-Perez; Emilio José Palacio Blanco; José Fidel Gual Barzaga; Raul Simanca Cardenas; and Luis Raul Gonzalez-Pardo Rodrigue, for their alleged roles in the February 24, 1996 shoot-down of two unarmed U.S. civilian aircraft operated by Brothers to the Rescue (BTTR), also known as Hermanos al Rescate, over international waters

When Compliance Becomes Dangerous, Part I: High-Risk Foreign Assignments and the Enforcement Gap

Friday, June 12, 2026
Author: 
Adriana Sanford
Volume: 
42
Issue: 
7
Abstract: 

              International criminal enforcement often begins long before a prosecutor files an indictment or a regulator announces a settlement. It may begin inside a multinational enterprise, when a lawyer questions a suspicious payment, an auditor identifies irregular transactions, a compliance officer refuses to approve a deficient review, or a finance professional detects signs of corruption, forced labor, trafficking, sanctions evasion, counterfeiting, money laundering, or organized criminal influence. At that moment, corporate compliance ceases to be an internal procedure alone. It becomes part of the broader enforcement ecosystem.

Guyana signs MOU for Targeted Financial Sanctions

Friday, June 12, 2026
Author: 
Gavin Neff
Volume: 
42
Issue: 
7
Abstract: 

                Guyana recently signed the Multilateral Memorandum of Understanding (MOU) Among Targeted Financial Sanctions Competent Authorities Within the Caribbean Financial Action Task Force (CFATF).  The Caribbean Financial Action Task force is an organization of 24 member states dedicated to implementing measures against money laundering.  Guyana is one of the first countries within the CFATF to sign the MOU.  The agreement was signed on behalf of Guyana by Hon. Attorney General and Minister for Legal Affairs, Mohabir Anil Nandlall SC MP.

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