Trends in investigations: cartels and transnational criminal organizations, cryptocurrency, trade, healthcare and AI

US regulators have moved from setting out enforcement priorities to putting them into practice. National security, the protection of US economic interests and public welfare remain at the center of the Administration’s agenda, with existing statutes and regulations being applied across a wide range of conduct. For organizations operating across borders, the implications extend from supply chains and financial transactions to the technologies they use and the third parties they engage with.

The past year has also highlighted the connections between these enforcement priorities. Cartel and TCO activity raises considerations around sanctions, anti-money laundering and illicit finance; cryptocurrency investigations are more closely tied to national security concerns; and the False Claims Act remains a key enforcement mechanism for both trade and healthcare fraud. Alongside these developments, the adoption of AI is introducing new fraud risks and investigative questions as organizations incorporate the technology into their operations.

In this article for GIR’s Americas Investigations Review 2027, FRA experts examine developments across cartels and TCOs, cryptocurrency, trade and customs fraud, healthcare fraud and AI, alongside the methodologies and practical considerations for investigating potential misconduct in these areas.

National security takes a wider role in enforcement

Cartels and TCOs remain a significant focus for US authorities, with recent actions linking their activities to national security, financial integrity and cross-border crime. For organizations operating in cartel-influenced parts of Latin America, potential exposure can extend through supply chains, third parties and other business relationships, bringing sanctions, anti-money laundering and FCPA considerations into investigations.

Cryptocurrency investigations are also taking on a greater national security dimension. While US policy remains supportive of digital asset innovation, enforcement has focused on cryptocurrency used in sanctions evasion, terrorist financing, organized crime and state-sponsored cyber activity. Blockchain analytics, due diligence and asset tracing can help practitioners identify connections and follow financial flows across digital asset networks.

Trade and healthcare fraud draw FCA attention

Trade enforcement remains a significant US priority following changes to the tariff regime. Authorities continue to pursue allegations involving tariff evasion, misclassification, undervaluation and illegal transshipment, with the False Claims Act (FCA) providing an important avenue for enforcement. Recent developments include the creation of a joint DOJ and Department of Homeland Security Trade Fraud Task Force and a record US$549.5 million customs fraud settlement under the FCA.

Healthcare fraud represents another major area of FCA activity. The sector accounted for approximately US$5.7 billion, or 84 percent, of FCA judgments and settlements in fiscal year 2025. With investigations often involving large volumes of claims and transactional data, analytics can help identify unusual billing activity, financial relationships and other patterns that warrant further examination.

AI creates new questions for investigators

The wider adoption of AI is introducing new forms of potential misconduct, from synthetic identities and AI-enabled fraud to misleading claims about the technology’s capabilities. Regulators across the Americas are largely addressing these risks through existing frameworks covering fraud, privacy, consumer protection, cybersecurity and disclosures.

For investigations practitioners, this means looking beyond how AI is presented to understand how systems operate in practice. Technical assessments, governance structures, documentation and audit trails can help establish whether an organization’s representations align with how its technology is designed, deployed and monitored.

Read the full chapter in GIR’s Americas Investigations Review 2027 here.