By Bruce Zagaris
We at the IELR send you best wishes for the new year. 2025 was momentous for the international enforcement community, and we are grateful to have had you following along with our coverage during our 40th year of discussing international enforcement developments.
We are grateful for the continuing long partnership with Professor Michael Plachta and contributions from practitioners and professors, including Aljohrh Al Abdulsalam, Ore Adedeji, the Basel Institute on Governance (Monica Guy and Kateryna Boguslavska), Dr. Ted Bromund, Lucy Carroll, Dan Fisher-Owens, Christina Gotsis, Frederick T. Davis, Jason Gottlieb, Sandra Grossman, Emily Hong, Paul Gully-Hart, Aiymgul Kachyke, Dimitris Konstantopoulos, Rodrigo Labardini, Marco Stewart Lopez, Charlie Magri, Luz E. Nagle, Konstantinos Magliveras, Jason McClurg, Gino Naldi, Yuriy L. Nemets, Simran Pandey, Michelle Roberts, Adriana Sanford, Katherine Scher, Luiz Fabricio Vergueiro, Alienor Vogeleer, and Konstantina Zivla. Since April 2024, Austin Wahl, a second-year law student at Washington College of Law, American Univ., has produced the IELR. Since May, Chloe Fontenelle has served as assistant editor.
We are also grateful for our partnerships with LexisNexis, WestLaw, EBSCO, and William Hein & Co. in distributing the IELR.
The following is a highlight of some of the articles we covered. In many cases, there are overlapping categories into which the articles fall, so we had to choose in which category to discuss the articles.
The Recovery and Return of Stolen Cultural Property
Fontenelle discussed a NYC judge’s ruling that an art institute must restitute Nazi-looted artwork to the heirs. Zagaris wrote about Argentina’s charges against the daughter of a Nazi officer relating to her concealment of a stolen painting. Carroll covered a stolen Egyptian artifact, returned by the Dutch government.
Money Laundering, Bank Secrecy, and Entity Transparency
The Basel Institute highlighted the gradual improvement in national AML systems as part of the results of the 13th public edition of the Basel AML Index. Zagaris covered the series of lawsuits challenging the constitutionality of the Corporate Transparency Act and FinCEN’s decision not to enforce beneficial ownership information reporting for United States (U.S.) persons and domestic entities. Zagaris discussed the Canadian government’s intelligence sharing on the laundering of fentanyl trafficking, as well as FinCEN’s designation of the Cambodia-based Huione Group as a primary money laundering concern. Kachyke wrote about new guides on international cooperation in AML/CFT: promise and limits.
Atrocity Crimes, Genocide, Crimes against Humanity, and War Crimes
Plachta discussed the United Nations’ (U.N.) adoption of a resolution on further work on the Convention on Crimes against Humanity. Zagaris wrote about Israeli soldiers facing criminal investigations abroad. Tinubu covered the violence against journalists in the Israel-Gaza war. Plachta covered the decision of European institutions to establish a special tribunal over aggression against Ukraine, as well as the Council of Europe’s (CoE) adoption of a resolution on the Special Tribunal and Register of Damage for Ukraine. He also reported on the U.N. Commission of Inquiry’s finding that the enforced disappearances committed by Russian authorities amount to crimes against humanity. Tinubu highlighted the sexual violence against children amidst the conflict in the Democratic Republic of the Congo. Zagaris discussed the U.S. notification of its withdrawal from the International Center to Prosecute Aggression against Ukraine, and the end of its support for the database on accountability for war crimes. Wahl wrote about a Finnish court finding a Russian mercenary guilty of war crimes. Hong covered the alarming accusations of reproductive violence and gender-based atrocity in Gaza against Israel. Zagaris discussed the U.S. indictment of a beekeeper for concealing genocidal participation in Rwanda. Manfield covered the Sudan v. UAE genocide case before the International Court of Justice (ICJ). Fontenelle wrote about the former member of a Gambian death squad’s conviction for torture in the U.S., as well as a German court’s decision to give a Syrian doctor a life sentence for war crimes and crimes against humanity. Adedeji discussed immigration, genocide, and the ethics of obtaining U.S. citizenship. Plachta covered the European Court of Human Rights’ (ECHR) rules against Russia in the case of Ukraine and the Netherlands v. Russia. Plachta covered U.N. investigators reveal systematic torture and other crimes in Myanmar, as well as the U.N. Commission’s allegations that Israel is committing genocide in Gaza. Konstantopoulos discussed the French arrest warrant for Bashar al-Assad and the power of in absentia judicial proceedings. Zagaris wrote about a U.S. jury’s awarding of $20 million to three Sudanese refugees against BNP Paribas. Fontenelle discussed Bangladesh’s international crimes tribunal sentences former Prime Minister to death for crimes against humanity.
International Criminal Court
Plachta discussed the International Criminal Court (ICC) Assembly of States Parties’ action on outstanding arrest warrants and how Italy has frustrated the ICC arrest warrant for a Libyan warlord accused of war crimes. He also covered ICC prosecutor requests for arrest warrants for Taliban leaders accused of gender-based crimes. Fontenelle wrote about the ICC’s conviction of a Sudanese militia commander for war crimes and crimes against humanity. Plachta discussed President Trump’s renewed sanctions against the ICC as well as the legal and political ramifications of the arrest of Duterte by the ICC. Plachta covered the ICC Assembly of States Parties’ failure to amend the Rome Statute on aggression. Manfield discussed the ICC warrants for Taliban leaders for crimes against women and LGBTQ individuals. Plachta covered the withdrawal of Mali, Niger, and Burkina Faso from the ICC.
Extradition, Its Alternatives, and Human Rights
Zagaris discussed the Bangladesh extradition request for the former P.M. from India, and the Montenegrin extradition of a South Korean crypto entrepreneur to the U.S. Wahl highlighted the exotic use of Samuel Landi and his dream of seasteading to avoid criminal prosecution in Italy, as well as Thailand’s approval of the extradition of an illegal online gambling kingpin. Tinubu covered the extradition by France to the U.S. of a man accused of sexual assault. Vergueiro discussed how the international role of the Federal Attorney General’s Office in Brazil has expanded to assist in the extradition of a Brazilian criminal defendant abroad. Labardini covered Mexico’s transport of twenty-nine Mexican nationals charged with drug-trafficking to the U.S. Zagaris wrote about Romania’s capture of a French fugitive nine months after a deadly prison escape. Hong discussed Germany’s Constitutional Court’s overturning of the extradition of a non-binary citizen to Hungary. Plachta wrote about the U.K. High Court halting extradition to India on human rights grounds. Zagaris discussed a Spanish court’s finding that the former director of UNOPS is extraditable to the U.S. for corruption. Wahl discussed the arrest and extradition of cartel broker and fentanyl kingpin ‘Brother Zhang’ to Cuba.
Economic Integration: The European Union
Plachta discussed Bosnia and Herzegovina’s agreements with Eurojust, Europol, and the European Public Prosecutor’s Office on cooperation in criminal matters. Plachta covered Europol’s release of its report on serious and organized crime threat assessment, as well as the EU’s conclusion of its agreement with Brazil to fight organized crime and terrorism. Plachta wrote about the decision by the CJEU on extradition by member states to third countries.
International Asset Forfeiture
Zagaris discussed the sharing by the U.S. of $50m million in forfeited assets with Estonia in exchange for financial enforcement activities, as well as the U.S. agreement to share $52.8 million in forfeited corruption proceeds with Nigeria. Zagaris covered Malysia requesting the extradition of Leissner and the pursuit of asset recovery. Fontenelle discussed Equatorial Guinea’s requests to the ICJ to stop the sale of the confiscated French mansion, as well as the DOJ’s seizure of millions of assets laundered by ransomware operations.
Cybercrime
Wahl covered the FBI’s novel sting operation in a cryptocurrency fraud case. Zagaris reviewed the onset of French prosecutors’ criminal investigations against Binance. Zagaris discussed the freeing of thousands of enslaved online scam workers from Myanmar. Wahl considered the plea by two Estonian nationals to $577 million cryptocurrency fraud, as well as the DOJ’s charging of ten Chinese hackers and others with stealing data and suppressing free speech. Gotsis and Gottlieb discussed the U.S. crypto enforcement overhaul. Konstantopoulos examined the DOJ indictment of the leader of a Russian malware scheme and global ransomware conspiracy, as well as the case of a multinational crypto scammer who faces justice after an international pursuit. Manfield discussed the U.N. Convention on Cybercrime. Wahl covered two OmegaPro executives charged with running a $650 million cybercrime operation. Kachyke discussed the U.S. State Department reward offer for alleged cybercriminals. Fontenelle reviewed a transnational cyberscamming crackdown, as well as a Chinese court’s sentencing of eleven crime syndicate members to death.
INTERPOL
Zivla covered INTERPOL and international parental child abduction. Bromund and Magri discussed Interpol’s updates of rules and guidance and the start of a silver notice. Wahl covered an Interpol-led operation targeting scams in Africa. Manfield discussed China, Interpol Red Notices, and GONGOs– their legal risks and international challenges.
Migration Enforcement
Zagaris wrote about Trump’s executive order on foreign terrorists and migration enforcement, and Latin American governments’ adverse response to the Trump administration’s deportations. Tinubu covered the Trump administration’s transfer of detained immigrants in Guantanamo to Venezuela. Zagaris wrote about the U.S. agreement with El Salvador to accept deportees, as well as U.S. transfers of thirteen Mexican detainees with drug convictions and a former governor to Mexico. Hong covered hostage diplomacy and U.S.-Russia prisoner swaps. Zagaris discussed the U.S. Supreme Court’s order to the Trump administration not to remove aliens under the Alien Enemies Act without due process. Fontenelle covered Lithuania’s landmark migrant smuggling case against Belarus before the ICJ. Manfield discussed domestic immigration raids through an international enforcement lens. Wahl covered the U.S. deportees suing the Ghanaian government over breach of human rights.
International Prisoner Transfers and Swaps
Pandey covered the U.S.-China prisoner swap. Zagaris discussed Venezuela’s release of U.S. prisoners and its agreement to accept Venezuelan deportees from El Salvador. Carroll examined Afghanistan’s release of a U.S. prisoner and what it signals for U.S.-Taliban relations.
Economic Integration: The Council of Europe
Plachta discussed the CoE’s call for comprehensive regulations of mercenaries, private militaries, and security companies, as well as the CoE’s effort to open a new Convention on the Protection of the Environment through Criminal Law. Magliveras wrote about the CoE’s action addressing Russia’s aggression against Ukraine and impunity. Plachta covered the CoE’s adoption of a protocol amending the Convention on the Prevention of Terrorism, as well as the treaty between the CoE and Ukraine to establish a special tribunal. Plachta wrote about the CoE’s opening for signature of the 3rd additional protocol to the CoE MLAT Convention.
International Tax Enforcement
Zagaris highlighted the issuance by the IRS of “John Does” summonses relating to entities doing business with Trident Trust Group. He covered the cum-ex dividend fraud cases in Denmark, Germany, and the U.S. Zagaris discussed Barrick Mining’s bringing of an ICSID case in a criminal tax dispute with Mali. He also considered a former U.S. defense contractor’s guilty plea in one of the largest U.S. tax evasion prosecutions, as well as Credit Suisse Services AG’s guilty plea to tax crimes concerning its conduct in Singapore. Zagaris covered the OECD report on designing a tax crime investigation manual, as well as the U.S. court’s granting of the government’s motion to compel Apple to give information in a Swiss tax investigation. He also examined U.S. requests for the extradition of prominent Guyanese for tax evasion and gold smuggling. Zagaris wrote about a Danish tax agency’s loss in a cum-ex dividend trial, and their plan to appeal the British court’s ruling. He reviewed UBS’s agreement to pay $985.6 million to settle a criminal tax case, and the U.S. court holding that the FBAR penalty assessment violated taxpayers’ 7th Amendment rights.
Transnational Corruption and Transparency
The settlement of a bribery investigation by McKinsey & Co. in South Africa was covered by Zagaris. He also covered the charges against former Florida Representative Rivera for FARA and money laundering, and the Trump administration’s executive order pausing enforcement of the Foreign Corrupt Practices Act. Zagaris wrote about the DOJ issuance of guidelines for FCPA enforcement, as well as the U.S. Court of Appeals’ overturn of a trial court acquittal on commercial bribery abroad.
Export Control and Sanctions Enforcement
Zagaris covered Trump’s imposition of tariffs on China after threatening sanctions and tariffs on Canada and Mexico for drug trafficking and other transnational crimes. Tinubu wrote about Trump’s invocation of the Alien Enemies Act to deport Venezuelan immigrants to El Salvador. Konstantopoulos discussed U.S. sanctions on the ICC as a shift in U.S. foreign policy, as well as how new sanctions against the family of Brazilian Supreme Court Justice signal a diplomatic rift between the Americas’ two most populous nations. Manfield focused on tariffs, emergencies, and the limits of power: a new chapter in IEEPA jurisprudence. Roberts wrote about the OFAC issues, maximum penalty in enforcement against a venture capital firm for Russia sanctions violations. Sanford discussed higher education at the intersection of export control, accessibility, and federal funding. Zagaris covered the U.S. indictment of the Haitian gang leader “Barbecue” for sanctions violations, as well as the U.S. Appellate Court’s affirmation of the decision that Trump’s tariffs are illegal, a case which the U.S. Supreme Court will hear on an expedited basis. Roberts, McClurg, and Fisher-Owens discussed the U.S. Department of Commerce BIS’s adoption of the “50 Percent Rule.”
Transnational Repression
Tinubu discussed the abduction in Kenya of Tanzanian and Ugandan opposition leaders. Hong discussed a new report by Freedom House on transnational repression. Scher covered the U.S. sanctions against Chinese and Hong Kong officials for transnational repression acts. Vogeleer discussed the French application against Iran in the ICJ regarding the detention of two French nationals. Labardini, who covered Mexico, is credited with frustrating an Iranian plot to kill an Israeli Ambassador.
Transnational Organized Crime
Zagaris discussed Europol’s disruption of criminal organizations’ smuggling of hazardous salvage cars from the U.S; he also reviewed the U.S. and U.K.’s sanctioning of the head of the Cambodian Prince Group, as the U.S. unseals an indictment. Tinubu covered how Irish and Spanish authorities, with the help of Europol, arrested twelve members of “The Family,” an Irish criminal network. Konstantopoulos discussed how the case of Carlos Martinez reveals the tentacles of corruption, violence, and organized crime in America’s borderlands, as well as how the Rio police raid unveils the complexities of combating multinational gangs and extensive corruption in Brazilian financial institutions. Zagaris wrote about how CARICOM heads prioritize combating transnational organized crime and the strengthening of regional security. Fontenelle covered Ecuador’s extradition of a notorious gang leader to the U.S. Konstantopoulos discussed how the arrest of a fugitive Ecuadorian drug lord in Spain reveals the extent of corruption and organized crime in the small Andean country.
International Environmental Enforcement
Plachta wrote about the Council of Europe’s convention against ecocide. Wahl discussed the Environmental Investigation Agency’s uncovering of a massive illegal mercury trade in gold mining. Konstantopoulos covered the Rio police bust of a major wildlife trafficking network.
Immunity of Heads of State and Diplomatic Premises
Plachta covered the fact that some U.K. politicians hinted at a withdrawal from the ECHR.
Transnational Fraud
Zagaris wrote about IOSCO and the private sector’s work on combating online fraud and platform providers, as well as cooperation between Eurojust and the U.S. to take down global credit card fraud. Konstantopoulos discussed the role of foreign actors in defrauding the federal government.
International Sports Enforcement
Sanford discussed how House v. NCAA and the SCORE Act are reshaping global compliance in college sports, as well as how legal architecture, AI-enabled integrity, and cross-border enforcement converge at FIFA 2026.
International Human Rights Enforcement
Hong wrote about the U.S.’s expanding forced-labor blacklist, and the impact on global trade and human rights enforcement. Mansfield analyzed the rethinking of victim compensation after WhatsApp v NSO Group (re Israeli-based government spyware company). Vogeleer discussed France’s request to Algeria to release a journalist, citing endangerment of freedom of the press.
Human Trafficking
Wahl discussed a German-U.K. Joint Action targeting human smuggling in the English Channel, as well as an ex-Philippine mayor given a life sentence for human trafficking. Zagaris wrote about an EU court’s holding that a Maltese investor citizenship scheme violates EU law. Plachta covered the European Parliament’s amendment to the Europol regulation to effectively combat migrant smuggling and trafficking in human beings.
International Narcotics Enforcement
Hong discussed the Mexican authorities’ record fentanyl seizure and implications for U.S.-Mexico relations. Zagaris discussed international cooperation between the U.S., Europol, and other governments to disrupt dark web narcotics operations. Wahl wrote about the U.S.’s charges against the leaders of the Sinaloa cartel faction with narco-terrorism. Zagaris discussed the U.S. bringing the first charge of material support to a designated foreign terrorist organization, the Cartel de Jalisco Nueva Generacion, as well as the criticisms from the Mexican president over the son of El Chapo’s guilty plea. Carroll analyzed the relationship between war and law enforcement, and the legal challenges of the U.S.’s strike against alleged drug traffickers. Konstantopoulos discussed a kingpin’s guilty plea and the critical role of the Sinaloa cartel in modern American foreign policy. Zagaris wrote about how the U.S.-Colombia dispute hinders international narcotics enforcement; he also reviewed a U.N. Security Council meeting over U.S. military strikes on Venezuelan boats and executions. Fontenelle discussed a Bali court’s sentencing of a Ukrainian national to life for his involvement in an illicit drug operation. Labardini wrote about Operation Oyamel and Mexican cartels’ expansion into Europe.
Counter-Terrorism Enforcement
Plachta covered the Europol 2024 Terrorism Situation and Trend Report. Zagaris wrote about the U.K.’s arrest of an alleged animal rights and ecoterrorist on the U.S. FBI’s most-wanted list, as well as the U.S.’s removal of Cuba from the list of state sponsors of terrorism at the end of the Biden administration. Plachta discussed the U.N. Secretary-General’s report warning of the undiminished threat and adaptability of ISIL/Da’esh, and the U.N. Security Council’s session on the global threat posed by this terrorist organization.
Illicit Firearms Trafficking
Zagaris wrote about the U.S. Supreme Court’s unanimous ruling against Mexico in a suit against the U.S. gun industry.
Jurisdiction and Immunities
Magliveras discussed the French highest court’s rules on the highly contentious issue of the immunity enjoyed (or not) by serving heads of state and state officials.
Sex Trafficking and Child Pornography
Nagle discussed international joint operations against child sex trafficking resulting in prosecutions and retaliatory lawsuits. Sanford wrote about child protection, AI, and the new architecture of liability on platforms like Meta and Roblox.
Internet Gaming
Zagaris discussed a state attorney general’s pressuring of the U.S. DOJ to crack down on illegal offshore gaming.
Citizen Security
Zagaris wrote about IDB announces $2.5 billion and a rapid response task force for security.
International Evidence Gathering
Davis discussed the High Court of Australia paves the way for the use of “AN0M” evidence – and validates global “outsourcing.