Davis Polk AML/CFT head Dan Stipano was quoted in Lexology discussing enforcement trends to expect in 2026. 

Dan noted, “Enforcement areas most likely to face closer scrutiny will include the facilitation of cartel activity, fentanyl trafficking, terrorist financing, fraud in government programs, tariff evasion, and immigration violations.”

As a result, other enforcement areas drop down the list of priorities unless they “implicate one or more of the administration’s policy goals,” he added.

Speaking about the current administration’s crypto-friendly approach, Dan said, “Unlike the previous administration, the Trump administration has taken a much more welcoming approach to crypto. This is not lost on criminals and criminal organizations that are attracted to crypto, especially permissionless platforms that can be accessed without verification of identity and due diligence.”

“US financial crime enforcement in 2026: predictions for in-house teams,” Lexology (January 22, 2026) (subscription required)

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