On February 5, 2025, Pamela Bondi, the newly sworn-in Attorney General under President Trump, initiated a significant overhaul of the Department of Justice's (DOJ) enforcement priorities and procedures. Her first day in office was marked by the issuance of multiple memoranda that outlined substantial changes in various areas of DOJ operations.
One of the key directives is the new focus on combating cartels and transnational criminal organizations (TCOs). Under the memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations,” Bondi instructed DOJ employees to prioritize investigations related to foreign bribery that facilitates the criminal operations of these groups. This means shifting focus away from FCPA (Foreign Corrupt Practices Act) and FEPA (Foreign Extortion Prevention Act) investigations that do not involve such connections. For instance, bribery of foreign officials to facilitate human smuggling, narcotics trafficking, and firearms trafficking will now be given higher priority[1][2][4].
To streamline these efforts, Bondi relaxed internal procedures, allowing local U.S. Attorney Offices greater autonomy to initiate and charge FCPA cases associated with cartels and TCOs. Previously, these cases required authorization and conduct by the Fraud Section of the DOJ’s Criminal Division in Washington, D.C. Now, local offices need only provide 24 hours’ notice to Main Justice before seeking charges[1][2][4].
Another significant change involves the elimination of several specialized task forces and initiatives. The KleptoCapture Task Force and the Kleptocracy Asset Recovery Initiative (KARI) have been disbanded. These moves are part of a broader strategy to redirect resources towards combating cartels, human trafficking, and other transnational crimes. Joint Task Force Vulcan will be reconstituted to target cartels and TCOs, while Joint Task Force Alpha will be elevated to focus on human trafficking investigations in Central and South America[2][5].
The new policies also impact enforcement under the Foreign Agents Registration Act (FARA). Bondi’s directives limit the use of criminal charges under FARA to instances of traditional espionage by foreign government actors. The National Security Division’s FARA Unit will now focus on civil enforcement, regulatory initiatives, and public guidance, marking a significant shift from the more aggressive FARA enforcement seen in recent years[4][5].
Additionally, the Department of Justice will intensify its efforts against immigration enforcement, human trafficking, and protecting law enforcement personnel. The Money Laundering and Asset Forfeiture Section (MLARS) will prioritize investigations and asset forfeiture actions targeting the activities of cartels and TCOs[5].
These changes reflect a broader alignment with President Trump’s January 20, 2025, Executive Order, which designated certain cartels and organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The new policies underscore the administration’s commitment to addressing what it sees as historic threats from illegal immigration, cartels, gangs, human trafficking, and drug smuggling[2][5].
Overall, Attorney General Bondi’s swift and comprehensive reforms signal a significant reorientation of DOJ’s enforcement priorities, emphasizing the fight against transnational crime and cartel activities.
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