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.

Jamaica and U.S. Conclude MOU on Third Country Deportees

Thursday, July 2, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
8
Abstract: 

                On June 17, 2026, Dr. Horace Chang, the Security Minister and Deputy Prime Minister of Jamaica, said in a press conference Jamaica and the United States have concluded a Memorandum of Understanding for Jamaica to receive third-country deportees.  According to Chang, the U.S. and Jamaica still need to determine “operational procedures” before Jamaica starts accepting migrants.  Dr. Chang stated that the individuals who may be transferred will only transit through Jamaica to a third country, including return to their home countries.  Jamaica may receive up to 25 deportees every two weeks.

 

When Compliance Becomes Dangerous, Part II: Retaliatory Deployment, Forced Criminality, and the Governance Failures Behind High-Risk Compliance Work

Thursday, July 2, 2026
Author: 
Adriana Sanford
Volume: 
42
Issue: 
8
Abstract: 

               Part I of this analysis examined the foundational enforcement gap arising when multinational enterprises deploy legal, audit, compliance, finance, security, and investigative personnel into high-risk jurisdictions without an integrated framework connecting corporate duty of care, travel-risk governance, trafficking prevention, occupational safety, human rights due diligence, and transnational criminal enforcement.

               Part II turns from legal architecture to governance failure. Anti-corruption investigations, forced criminality, cyber-enabled trafficking, whistleblower retaliation, organized crime, human rights due diligence, evidence preservation, and legal ethics increasingly overlap. The compliance professional sent abroad may  be a potential witness, internal investigator, custodian of evidence, protected reporter, or target of intimidation.  The question is whether the company has a governance system capable of protecting the people whose independence, judgment, documentation, and professional courage make enforcement possible.

               The more difficult question is whether foreseeable danger, inadequate mitigation, or retaliatory deployment may later become evidence of deficient internal controls, weak compliance culture, negligent supervision, obstruction, or failure to preserve evidence. In that sense, high-risk deployment is not only an operational concern. It may become part of the record in a cross-border investigation, shareholder dispute, employment claim, whistleblower proceeding, anti-corruption matter, or human rights due diligence review.

When AI Fails: Europe’s Expanding Liability Architecture

Thursday, July 2, 2026
Author: 
Adriana Sanford
Volume: 
42
Issue: 
8
Abstract: 

                Artificial intelligence failures rarely remain confined to their technical origin. In the European Union (EU), an AI-related malfunction, cybersecurity vulnerability, platform-amplification risk, product-safety concern, or post-market monitoring deficiency may quickly move beyond internal remediation into regulatory reporting, supervisory review, market surveillance, contractual dispute, and civil liability. For multinational enterprises, this downstream dimension of European AI enforcement is especially consequential. An AI system may satisfy AI-specific requirements and nevertheless create legal exposure once deployed within a broader commercial, technological, and regulatory environment. Under the European model, what begins as a technical defect, operational disruption, or post-deployment failure may become a multi-forum enforcement matter involving regulators, courts, contractual counterparties, and internal governance bodies.

U.S. and Nigeria Collaborate against ISIS

Thursday, July 2, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
8
Abstract: 

            On June 22, 2026, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and six entities across Europe, the Middle East, and West Africa for facilitating financial transactions on behalf of the Islamic State of Iraq and Syria (ISIS).  The action is directed at key facilitators who enable ISIS to move funds among its regional affiliates and helps protect the rights of religious minorities whom ISIS and ISIS-inspired violence has targeted.

Niger Is 3rd Country to Withdraw from the ICC

Thursday, July 2, 2026
Author: 
Bruce Zagaris
Volume: 
42
Issue: 
8
Abstract: 

                 On June 23, 2026, the International Criminal Court (ICC) said it had received on June 18 an “instrument of withdrawal” from Niger.  Nine months before, Niger, Mali and Burkina Faso, Sahelian countries ruled by hardline military governments that took power in coups between 2020 and 2023, announced jointly their intentional to withdraw from the ICC.  The ICC said the request will take effect on June 18, 2027, one year after notification.  In the meantime, Niger must fulfill its obligations to the court.  The ICC said, “while joining or withdrawing from a treaty is a sovereign right of states under international law, we regret any decision to depart from the collective effort to end impunity for the most serious crimes.”

Huione Group’s Cloud Computing Account Seized as Part of Coordinated Interagency and International Efforts to Curb Scams

Thursday, July 2, 2026
Author: 
Jaccaranda Woldemariam
Volume: 
42
Issue: 
8
Abstract: 

               On June 23, 2026, the Justice Department seized a cloud computing account that hosted the backend structure for subsidiaries of the Huione Group.  The subsidiaries are alleged to have assisted transfer of funds from “cryptocurrency investment frauds, cyber scams, and other criminal activities on cryptocurrency blockchains” and enabling the “conversion of the proceeds of these schemes to the legitimate banking sector undetected.”

11th Circuit Returns FBAR Penalty Case to Trial Court on Cruel & Unusual Punishment issue

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

               On June 4, 2026, the United States (U.S.) Court of Appeals for the Eleventh Circuit returned to the trial court a $2.3 million Foreign Bank Account Report penalty to reconsider its legality with the cruel and unusual punishment provisions of the Eighth Amendment of the U.S. Constitution.  The trial court rule, pre-Schwarzbaum, that the excessive finds clause did not apply to the case.

The Assassination of a Venezuelan Gang Leader Signals a Shifting Paradigm in Regional Cooperation and International Law

Friday, June 26, 2026
Author: 
Dimitris Konstantopoulos
Volume: 
42
Issue: 
7
Abstract: 

                In June 2026, the United States government coordinated with the Venezuelan government to launch airstrikes against a compound for the notorious gang Tren de Aragua (TdA); the strike was successful and killed the gang’s infamous leader, Hector Rusthenford Guerrero Flores.  The United States Department of Justice (DOJ) indicted Guerrero Flores in late 2025, alleging that he conspired with others to run TdA and expand its criminal empire across Latin America, the United States, and Europe. Prosecutors also accuse Guerrero Flores of ordering murders and kidnappings; directing an extensive sex, drug, and weapons trafficking operation; and running TdA’s vast money laundering network.

European Parliament Adopts Resolution the Recruitment of Children by Organized Crime

Friday, June 26, 2026
Author: 
Michael Plachta
Volume: 
42
Issue: 
7
Abstract: 

               On June 18, 2026, the European Parliament adopted a resolution on the recruitment of children by organized crime. The European Parliament is calling for stronger measures against the recruitment of children by organized criminal and terrorist groups, at a time when minors are increasingly used for illegal activities, including through online contacts. In a resolution adopted by show of hands, Members of European Parliament (MEPs) call for prevention, stronger enforcement of digital laws, joint investigations against recruiters, and special support for vulnerable children.

Évian G7 Summit Provides Guidance on International Enforcement Priorities

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

                 On Jun 17, 2026, the conclusion of the Évian G7 Summit issued declarations containing priorities for several international enforcement issues.  Among them are: a safer digital space for minors; combating migrant smuggling; combating drug trafficking; and strengthening sanctions on Russia in support of Ukraine in the latter’s conflict with Russia.

Pages

Subscribe to International Enforcement Law Reporter RSS