In high-risk markets, extortion has long been treated as an unavoidable cost of doing business. That calculation has changed. With the expansion of Foreign Terrorist Organization and Specially Designated Global Terrorist designations to major criminal organizations, corporate responses to coercive pressure now carry far greater legal, financial, and reputational consequences. Payments, third-party arrangements, and even indirect support can expose companies to enforcement ris

Involving law enforcement or criminal prosecutors (collectively, “LE”) during a parallel asset tracing investigation is generally not a...