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Sanctions in the Age of Trump 2.0: How OFAC is Pivoting Towards Latin America

 

Under the current Trump administration, the use of economic sanctions as a foreign policy tool is becoming more unilateral, targeted, and strategically aggressive and Latin America is emerging as a key pressure point. In the latest podcast episode of Integro Talks, Alberto de la Portilla, CEO of Integro Advisers, hosted sanctions expert Saskia Rietbroek, Executive Director of the Association of Certified Sanctions Specialists (ACSS), to discuss how U.S. foreign policy initiatives are evolving in Trump’s second term and their implications for Latin America. 

A Region in Focus

Latin America has moved to the core of Washington’s foreign policy radar, driven not only by regional issues such as narcotrafficking and immigration, but also by global dynamics. These include the growing influence of China in the region and the threat of tariffs aimed at improving U.S. trade leverage.

A chief focus of the Trump administration is the increasing concern over China’s commercial expansion in Latin America. From the development of a deep-water port in Peru to widespread involvement in the logistics and operations around the Panama Canal, Chinese state-owned or sponsored entities have gained a significant foothold in the region, particularly in mining, agriculture, and infrastructure. 

At a recent U.S. security conference, a top Commerce Department official remarked,  “70% of the labels on containers in the Panama Canal are Chinese,” expressing deep concern over China’s influence in such a vital trade artery. Rietbroek, who attended the event, described the tone as emotional and nationalistic, with clear discomfort about China’s role in infrastructure that the U.S. once controlled.

Additionally, China continues to seek new markets for its products in the wake of President Trump’s tariffs. Consumers in Brazil, Argentina, Peru, Chile and Colombia represent good options for Chinese exporters. However, the relationship between Mexico and China dominates the foreign policy conversation in new and pressing ways.

Cartels, Fentanyl, and the Shift Away from One Global Power to Another

Since the war in Ukraine, Russia has been the focal point of aggressive sanctions by the U.S. and the E.U. If President Trump is serious about ending the war, sanctions remain an effective tool at his disposal. “We may see more U.S. sanctions on Russia, not for punishment, but as negotiation leverage,” said Rietbroek.

However, one of the clearest pivots in 2025 is the Trump administration’s renewed focus on Mexican drug cartels and fentanyl trafficking. U.S. financial institutions were recently summoned to Washington, D.C., to meet with regulators about their compliance efforts related to Mexican cartel activity and illicit financing. According to Rietbroek, Russia wasn’t even mentioned.

While Mexico draws attention for criminal enforcement, China presents a different kind of challenge: a strategic and systemic rival whose economic footprint across Latin America continues to expand. China is also a focus of the opioid addiction crisis that has affected many families in the United States. Chinese companies manufacture and produce the primary chemicals used in fentanyl, and drug cartels in Mexico have sourced the product to produce opioids and smuggle it across the U.S. – Mexico border. 

Rietbroek expects aggressive actions against entities and organizations tied to this activity. “You’ll probably see some organizations involved in that trade — whether Mexican or Chinese — being sanctioned,” she noted.

A Fractured Multilateral Order

Unlike the global sanctions response to Russia’s invasion of Ukraine, 2025 has marked a return to unilateralism. Rietbroek believes this aligns with the new global sanctions regime. “Sanctions are now a structural part of how governments protect their economies. Nations see sanctions as a way to get economic security.” 

President Trump’s administration is doubling down on this strategy. Compared to his first term, the second administration shows a shift in both volume and intent. In the first four months of the first administration (2017), OFAC issued  24 updates to its sanctions list and reported three enforcement actions. For the same period in 2025, there have been 36 updates and zero enforcement actions.

The message is clear: the use of sanctions is less about penalizing and more about applying pressure. The current sanctions regime functions as a negotiating tool, used strategically to influence economic outcomes rather than to enforce violations.

De la Portilla noted a growing divergence between historical allies. With recent news that the EU imposed new sanctions against Russia  and the U.K. against Israeli ministers, the U.S. has either stayed on the sidelines or expressed disapproval with these actions. For Latin America, this fragmentation introduces not just uncertainty and additional burdens, but also the risk of becoming a collateral actor in global rivalries.

What It Means for Risk and Compliance Teams

For institutions with exposure to Latin America — banks, logistics providers, and manufacturers — the current environment demands more dynamic, politically-informed compliance strategies.

Risk assessments, traditionally updated every 12 to 18 months, must become more flexible and frequent. As Rietbroek noted, sanctions can change overnight, often driven by political shifts rather than legal standards. This makes sanctions risk fundamentally different from anti-money laundering (AML). “Sanctions officers are now being pulled into board meetings. Just like AML after 9/11, sanctions are now a board-level issue,” said Rietbroek.

Organizations are responding by creating dedicated sanctions roles, investing in professional certifications, and reinforcing internal education to avoid being blindsided by rapidly changing risk profiles that factor in the unpredictability, uncertainty and the fluid nature of sanctions.

Economic sanctions are no longer guardrails; they are strategic weapons in a global contest over influence, trade, and control. For businesses, governments, and risk compliance professionals alike, navigating this new landscape demands more than technical know-how; it requires a combination of strategic forecasting and adaptation, geopolitical instinct, and above all, patience. 

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