On July 15, 2026, the U.S. Department of State designated the Juárez Cartel and Los Viagras as Foreign Terrorist Organizations (FTO) and as Specially Designated Global Terrorists, in addition to maintaining previously imposed sanctions for narcotics trafficking activities.

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According to U.S. authorities, both groups engage in terrorist activities or pose a significant risk of doing so, in addition to their involvement in organized crime. These designations follow those made in February 2025 with respect to six other Mexican cartels and constitute the second expansion of the list of Mexican cartels classified as FTOs.

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In legal terms, these designations expand the prohibitions on providing material support to these organizations and expose those who do so to civil and criminal sanctions under U.S. law.

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Beyond these legal implications, FTO designations are particularly relevant from a compliance perspective. It is worth recalling that the concept of "material support" under U.S. law is broad: it is not limited to money transfers, but also encompasses services, goods, transportation, personnel, and even technical advice.

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This breadth takes on a particularly relevant dimension considering that numerous companies operate in areas where these organizations exercise varying levels of territorial control or influence over logistics chains, transportation, informal security, local suppliers, or economic activities. While many interactions may occur under contexts of coercion or extortion, the new designations make it necessary for organizations to carefully consider these scenarios from a compliance perspective, as certain conduct could be analyzed by U.S. authorities under the framework of prohibitions relating to material support for terrorist organizations.

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In this context, with each new designation, the universe of organizations with respect to which any form of material support may generate liability expands. Therefore, it is appropriate for organizations to evaluate whether their third-party due diligence controls, their sanctions monitoring processes, and their anti-money laundering and counter-terrorist financing programs remain adequate to manage the risks that may arise in their operations and business relationships.

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At Mijares, we have a specialized compliance team that assists organizations in evaluating and updating their compliance programs, strengthening their due diligence processes, and designing and implementing effective controls to manage the risks arising from a constantly evolving regulatory environment. Our team is available to help you analyze the impact these designations may have on your operations and to support you in designing and implementing compliance solutions tailored to your organization's needs.