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.

                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.

               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.

                 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.

                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.

              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]

              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

                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.

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.

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.