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.

U.S. Department of Justice Issues Guidelines for FCPA Enforcement

Friday, June 13, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
7
Abstract: 

 On June 9, 2025, Deputy Attorney General Todd Blanche issued guidelines for investigations and enforcement of the Foreign Corrupt Practices Act (FCPA)[1] which helps clarify the Executive Order of President Donald J. Trump on February 10 (hereafter referred to as the Trump FCPA E.O.)[2] and the memorandum by Attorney General (A.G.) Pam Bondi on February 5, 2025. [3] This article discusses the guidelines and some of their implications.

U.S. Supreme Court Unanimously Rules against Mexico in Suit Against U.S. Gun Industry

Friday, June 13, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
7
Abstract: 

On June 5, 2025, the United States Supreme Court ruled in favor of the U.S. gun industry and against the effort by the Mexican government to hold the industry responsible for violence inflicted in Mexico by the drug cartels who purchase U.S. arms.

U.S. Treasury Sanctions Alleged Cyber Scam Company and its Administrator

Friday, June 13, 2025
Author: 
Bruce Zagaris
Volume: 
41
Issue: 
7
Abstract: 

On May 29, 2025, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Funnull Technology Inc., a Philippines-based company that furnishes computer infrastructure for hundreds of thousands of websites participating in virtual currency investment scams, commonly known as “pig butchering” and its administrator, Liu Lizhi.

Tariffs, Emergencies, and the Limits of Power: A New Chapter in IEEPA Jurisprudence

Friday, June 13, 2025
Author: 
Alexandra Manfield
Volume: 
41
Issue: 
7
Abstract: 

On May 28, 2025, in V.O.S. Selections, Inc. v. United States,[1] a three-judge panel of the United States Court of International Trade struck down sweeping tariff programs, holding that the President exceeded his authority under the International Emergency Economic Powers Act[2] (IEEPA).[3] The case arose from a group of small businesses and a coalition of state governments that challenged tariffs imposed by President Trump under a series of 2025 executive orders.

The Real Government Fraud: An Examination of Foreign Actors’ Role in Defrauding the Federal Government

Friday, June 6, 2025
Author: 
Dimitris Konstantopoulos
Volume: 
41
Issue: 
7
Abstract: 

The United States federal government is riddled with fraud. This fraud is not the same as the “fraud” that is demonized by the second Trump administration, Elon Musk, and conservative talking heads; foreign criminal organizations are using complex schemes to defraud the federal government, while hurting vulnerable Americans in the process. 

Canadian Government Starts Intelligence Sharing on Laundering of Fentanyl Trafficking

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

On February 19, 2025, the Canadian government held the first working meeting of the new Integrated Money Laundering Intelligence Partnership (IMLIP) to facilitate the sharing of money laundering and organized crime intelligence between law enforcement and Canada’s large banks. Kevin Brosseau, Canada’s Commissioner of the Fight Against Fentanyl, opened the initial meeting.[1]

Barrick Mining Brings ICSID Case in Criminal Tax Dispute with Mali

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

On May 14, 2025, Barrick Mining requested provisional measures against the Government of Mali to subvert their effort to put the Loulo-Gounkoto gold mine under government control. This request marks the latest escalation in this dispute, following a move on January 10 in which Barrick Mining brought an action in the International Court for the Settlement of Investment Disputes (ICSID) against the Government of Mali.[1]

Leader of Russian Malware Scheme and Global Ransomware Conspiracy Indicted by Department of Justice

Friday, June 6, 2025
Author: 
Dimitris Konstantopoulos
Volume: 
41
Issue: 
6
Abstract: 

On May 22, 2025, the United States Department of Justice (DOJ) unveiled an indictment of Rustam Rafailevich Gallyamov for his role in the Qakbot malware scheme.[1] The DOJ accuses Gallyamov, a Russian national, of developing Qakbot – a malicious ransomware that hijacks the unsuspecting user’s computer system – and assisting in its distribution to a variety of criminal gangs and networks.[2]

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