President Donald Trump signed an executive order Friday directing a sweeping review of federal efforts to combat transnational criminal organizations (TCOs) engaged in cybercrime and fraud, with a particular focus on schemes targeting American consumers and businesses.
The order calls for the attorney general to prioritize prosecutions of cyberfraud and scam offenses, emphasizing “the most serious, provable offenses,” and to explore establishing a fund to reimburse victims using assets seized from perpetrators. It also directs the Department of Homeland Security to enhance training and technical assistance for state and local law enforcement agencies dealing with cyber threats.
A key component of the order threatens potential consequences for countries that “tolerate these predatory schemes,” including sanctions, visa restrictions, limitations on foreign assistance, and the potential expulsion of officials deemed complicit. The White House stated that ransomware attacks, phishing campaigns, financial fraud, sextortion, and impersonation scams are frequently coordinated by sophisticated TCOs.
The executive order follows a January 20, 2025 directive from President Trump to revise national security and counter-narcotics strategies to pursue the “total elimination” of cartels and TCOs, according to a memorandum released by the Justice Department. Attorney General Pam Bondi circulated a similar memorandum on February 5, 2025, to all Department of Justice employees, outlining the administration’s goal of eliminating these organizations.
The White House estimates that U.S. Consumers lost more than $12.5 billion to cyber-enabled fraud, with senior citizens disproportionately affected. Recent research from PYMNTS Intelligence and Block indicates that nearly 20% of American adults have experienced at least one scam in the last five years, though the White House claims a significantly higher figure of 73% without specifying a timeframe.
The order arrives as the Justice Department is signaling a renewed focus on white-collar enforcement, particularly concerning foreign bribery that facilitates the operations of cartels and TCOs. A recent memo from Attorney General Bondi, issued February 5, 2025, indicated a shift in enforcement of the Foreign Corrupt Practices Act (FCPA) to prioritize such cases. The administration also intends to designate cartels as Foreign Terrorist Organizations (FTOs), a move that could expose any financial transactions linked to them – even those occurring outside the U.S. – to charges of providing material support to terrorism.
Mayer Brown legal analysts noted that the designation of cartels as FTOs increases the risk of criminal fines and other penalties for businesses and individuals with connections to these organizations. Latin American businesses and their subsidiaries are being urged to strengthen internal compliance programs to prevent any interaction with cartels or TCOs.
Last week, banking executives testified before the House Financial Services Committee, warning of the escalating fraud-related threats facing the industry. Joseph Schuster, a partner at Ballard Spahr, described the current fraud landscape as “increasingly industrialized, technology-enabled, cross-channel and scalable.”
The executive order does not specify a timeline for the completion of the review or the implementation of the proposed measures. The Department of Justice has not yet responded to requests for comment on specific enforcement strategies related to the order.