Trends in investigations: cartels and transnational criminal organisations, crypto, AI and tariffs

The past 12 months have seen a convergence of political shifts and technological evolution that have brought new challenges for investigations, requiring practitioners to recalibrate. The change of US Administration combined with continuing technological advancements in cryptocurrency and AI call for strategic and practical responses. For investigations practitioners across the Americas, this convergence demands the agility to adapt investigative methodologies in real-time as regulatory frameworks, criminal tactics and enforcement priorities continue to shift at an unprecedented pace.

In this article for GIR Americas Investigations Review 2026, we explore the impact of key changes in US enforcement priorities on the Americas and how practitioners’ approach to investigations should consider the evolving business landscape and compliance risks.

International impact of changes in US enforcement priorities

Guided in no small part by a desire to establish US dominance in the global economy, the new administration’s enforcement priorities will impact cross-border business operations. Various statements from top officials in the Trump administration, some of which we will refer to throughout this review, speak to the desire for dominance in innovation, trade and security. For example, championing Environmental, Social and Governance (ESG) was a key regulatory focus of the Biden administration, even though some opposing US lawmakers argued ESG regulations would restrict corporations and hurt the American economy. Unsurprisingly, the new administration reversed ESG regulations even while other jurisdictions (particularly Europe) held fast to their commitments, throwing multinational compliance and investigations teams into a new world of uncertainty. In the same vein, we focus this chapter on areas in which changes in US priorities could impact compliance and investigations practitioners doing business beyond US borders.

The new US administration spared no time in announcing its priorities after the presidential inauguration, with a series of memoranda from top officials clarifying enforcement areas with clear links to the larger strategic focus on perceived national security threats.

• On 5 February 2025, AG Bondi issued memoranda on the elimination of cartels and TCOs (General Policy Regarding Charging, Plea Negotiations, and Sentencing and Total Elimination of Cartels and Transnational Criminal Organizations).
• On 12 May, the DOJ Criminal Division expanded on the AG’s messaging with its own memo Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime. It emphasised the Department’s focus on prosecuting certain white collar crimes involving healthcare fraud, procurement fraud, trade and customs fraud and tariff evasion, supporting cartels and TCOs, among others.

The administration’s pro-innovation stance has also been made clear in statements from agency leads. SEC Chairman Paul Atkins has signalled that under his leadership, rules and regulations will be cryptocurrency-friendly to promote crypto advancement. The appointment of a White House AI ‘czar’ was a similar indication of the administration’s strategic pivot toward accelerating domestic AI innovation and infrastructure.

In the following sections, we will discuss four areas in which these strategic US priorities are shaping the regulatory and enforcement landscape, and related considerations for investigations: cartels and TCOs, cryptocurrencies, tariff and customs fraud and AI.

Read the full chapter here.

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