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.

Transnational Repression: A Growing Global Threat to Human Rights and Sovereignty

Monday, March 17, 2025
Author: 
Emily Hong
Volume: 
41
Issue: 
4
Abstract: 

Transnational repression––the practice of authoritarian regimes targeting dissidents beyond their borders—has become an increasingly urgent issue, threatening not only individual freedoms but also the integrity of host nations that provide refuge to exiles. A new report from Freedom House covering a decade of data highlights the extent of this phenomenon, detailing 1,219 incidents perpetrated by 48 governments in 103 countries. As democracies work to counter these tactics, the issue remains fraught with challenges, including a lack of a uniform definition, legal gaps in protection mechanisms, and concerns over the misuse of Interpol red notices to justify politically motivated extraditions.[1]



 

 

Pakistan Arrests and Extradites to the U.S. ISIS-K Attack Planner for Role in Terrorism at Abbey Gate, Afghanistan

Monday, March 17, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
4
Abstract: 

On March 2, 2025, the United States charged Mohammad Sharifullah, also known as “Jafar,” a member of the terrorist organization the Islamic State of Iraq and ash-Sham-Khorasan Province (ISIS-K), with furnishing and conspiring to provide material support and resources to a designated foreign terrorist organization resulting in death, contravening 18 U.S.C. § 2339B.[1]  


 

 

OKX Pleads Guilty to Money Laundering Violations and Will Pay $500 Million in Penalties

Friday, March 7, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
4
Abstract: 

On February 24, 2025, the Acting United States Attorney for the Southern District of New York announced that Aux Cayes Fintech Co. Ltd, d/b/a “OkEx,” d/b/a “OKX”, a Seychelles-based entity that since 2017 has operated one of the largest cryptocurrency exchanges in the world, pled guilty to one count of operating an unlicensed money transmitting business.[1] OKX agreed to pay monetary penalties of more than $504 million.[2]

 

Sexual Violence Against Children is on the Rise Amidst the Ongoing Conflict in the Democratic Republic of Congo

Friday, March 7, 2025
Author: 
Morinsola Tinubu
Volume: 
41
Issue: 
3
Abstract: 

Over the last month, the United Nations International Children’s Emergency Fund (UNICEF) has issued multiple reports expressing concern over the alarming rate of sexual violence against minors occurring in the Democratic Republic of Congo. There have always been concerning rates of sexual violence in the DRC but since M23 has taken control of the eastern region of the country, these numbers have skyrocketed. According to UNICEF, since January 24, 2025, “the cases of sexual violence have risen by more than two and a half times. Abductions have increased sixfold, killing and maiming is up sevenfold, and attacks on schools and hospitals have multiplied by 12.”[1]


 

 

FinCEN Decides Not Enforce BOI Reporting Penalties for U.S. Persons and Domestic Entities

Friday, March 7, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
3
Abstract: 

The saga of the Corporate Transparency Act (CTA) continues to take many twists and turns. On February 17, 2025, in Smith et al v. U.S. Department of Treasury, et al,[1] the U.S. District Court for the Eastern District issued an order staying the preliminary injunction. As a result, FinCEN issued a notice that it is generally extending the deadline by 30 calendar days from February 19, 2025 (until March 21) for most companies because it realizes that reporting companies may need more time to comply with their Beneficial Ownership Information (BOI) reporting obligations. The deadline will apply to the bulk of reporting companies to file an initial, updated, and/or corrected BOI report.



[1]  Smith et al v. U.S. Department of Treasury, et al,  (E.D. Tex) 6:24-cv-00336 (E.D. Tex) (filed Sept. 12, 2024)

 

Mexico sends 29 Mexican nationals charged with drug-trafficking to the United States

Friday, March 7, 2025
Author: 
Rodrigo Labardini
Volume: 
41
Issue: 
3
Abstract: 

On February 27, 2025, Mexico released and handed over to U.S. custody 29 Mexican nationals charged with several criminal offenses[1] sought after by U.S. authorities.[2] The transfer took place in parallel to a high-level Mexican delegation arriving in Washington[3] to meet with senior U.S. officials on a security agreement at a moment of bilateral tensions. Due to the number, but —most importantly— because Rafael Caro Quintero was included in the group,[4] it has been hailed in American law enforcement circles as a major victory. It is being considered as a clear signal that Mexico’s president plans to cooperate with Pres. Trump’s  administration —in the aftermath of designating drug trafficking cartels as terrorists[5] and in the midst of threatened U.S. tariffs for Mexican products.[6]



[1] Al Jazeera, Why has Mexico handed over drug cartel leaders to US? Who are they?, Feb. 28, 2025, https://www.aljazeera.com/news/2025/2/28/why-has-mexico-handed-over-drug....

[2] Matthew Cullen, Mexico Released Dozens of Cartel Figures Into U.S. Custody, The New York Times, Feb. 27, 2025.

[3] The Mexican delegation were the Secretaries of Foreign Affairs, Juan Ramón de la Fuente; of Security and Citizen Protection, Omar García Harfuch; of National Defense, Gen. Ricardo Trevilla; of the Navy, Adm. Raymundo Pedro Morales; Prosecutor General, Alejandro Gertz Manero; Mexican Ambassador to the U.S.A., Esteban Moctezuma; and Marcela Figueroa, Executive Secretary for the National Public System; and the Head of Unit (equivalent to Deputy Secretary) for North America, Roberto Velasco. They met Secretary of State Marco Rubio; Defense Secretary Pete Hegseth; Attorney General Pam Bondi; Senior Advisor to the Secretary, U.S. Department of Homeland Security Troy Edgar; Senior Bureau Official Bureau Of Western Hemisphere Affairs Department of State (WHA-DOS) Amb. Michael Kozak; Deputy Assistant Secretary For Mexico And Canada WHA-DOS Katherine Dueholm; State Department's Special Envoy for Latin America Mauricio Claver-Carone; Chargé d’Affaires, U.S. Embassy in Mexico Mark Johnson; and Senior Advisor WHA-DOS Ricardo Pita. Secretaría de Relaciones Exteriores (SRE), El Gobierno de México avanza en la colaboración binacional en materia de seguridad, Comunicado No. 030, Feb. 27, 2025, https://www.gob.mx/sre/prensa/el-gobierno-de-mexico-avanza-en-la-colaboracion-binacional-en-materia-de-seguridad-391672?idiom=es.

[4] Caro Quintero ordered the 1985 torture and killing of DEA Special Agent Enrique “Kiki”, which caused U.S. authorities to carry out the U.S. transborder abduction from Mexican soil of Mexican Dr. Humberto Álvarez Macháin —charged with prolonging Camarena’s life in order to torture him. The transborder abduction was validated with U.S. v. Alvarez-Machain, 504 US 655 (1992). See Rodrigo Labardini, La Magia del Intérprete. Extradición en la Suprema Corte de Justicia de Estados Unidos: El Caso Álvarez Macháin, Editorial Porrúa, México, D.F., 2000, 231 pp. This led Mexico to suspend all cooperation with DEA. Secretaría de Relaciones Exteriores, Press Bulletin B-1122, June 15, 1992.  This in turn led to Mexico and U.S. signing a bilateral treaty to prohibit transborder abductions, Treaty to Prohibit Transborder Abductions, Nov. 23, 1994, United States-Mexico, in Michael Abbell and Bruno Ristau, 5 International Judicial Assistance (Criminal) Extradition A-676.3 (Supp. 1995). See Rodrigo Labardini, El Tratado entre México y Estados Unidos para Prohibir los Secuestros Transfronterizos, I(5) Revista Mexicana de Procuración de Justicia 79-94 (June 1997).

[5] Department of State (DOS), Terrorist Designation of International Cartels, Press Statement, Marco Rubio, Secretary of State, Feb. 20, 2025.

[6] Al Jazeera, Trump tariffs of 25% on Canada, Mexico set to kick in March 4, Feb. 27, 2025, https://www.aljazeera.com/economy/2025/2/27/trump-tariffs-of-25-on-canad....

 

FinCEN Sets March 21 Deadline for CTA Reporting as a Result of Court Decision

Friday, February 28, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
3
Abstract: 

The saga of the Corporate Transparency Act (CTA) continues to take many twists and turns. On February 17, 2025, in Smith et al v. U.S. Department of Treasury, et al,[1] the U.S. District Court for the Eastern District issued an order staying the preliminary injunction. As a result, FinCEN issued a notice that it is generally extending the deadline by 30 calendar days from February 19, 2025 (until March 21) for most companies because it realizes that reporting companies may need more time to comply with their Beneficial Ownership Information (BOI) reporting obligations. The deadline will apply to the bulk of reporting companies to file an initial, updated, and/or corrected BOI report.

 

 

Mexico Extradites Barrio Azteca Gang Leader and One Other to the U.S. for the 2010 U.S. Consulate Murders in Juarez

Friday, February 28, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
3
Abstract: 

On February 20, 2025, Mexico extradited two alleged members of the Barrio Azteca (BA), a transnational criminal organization, associated with the Juarez Cartel, to face criminal charges concerning the March 2010 murders of U.S. Consulate employees in Juarez, Mexico. Eduardo Ravelo, also known as Tablas, Tablero, and T-Blas, and Enrique Guajardo Lopez, also known as Kiki, made their initial appearances on February 24 in the Western District of Texas. In March 2011, U.S. law enforcement unsealed a 12-count third superseding indictment[1] against both defendants. Ravelo is a former FBI Top 10 Most Wanted Fugitive.[2]

 

 

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