Cristián Francos

The online Portal is designed to improve the efficiency of the delisting process by prompting petitioners to provide key information at the outset of a matter, rather than through multiple follow-up questionnaires that can delay OFAC’s review.

On May 28, 2026, the U.S. State Department designated Brazilian criminal organizations Primeiro Comando da Capital (PCC) and Comando Vermelho (CV) as Specially Designated Global Terrorists (SDGTs), effective immediately. Both groups will also be designated Foreign Terrorist Organizations (FTOs), effective June 5, 2026.  PCC and CV are now in the same legal category as Hamas and Hezbollah. Banks and multinationals penalized for dealings with those organizations face identical exposure for PCC or CV ties. 

The United States government has dramatically escalated sanctions pressure against Iran since early 2025, culminating in an unprecedented campaign — designated “Economic Fury” — that has produced more than 1,000 designations of Iran-related persons, vessels, and aircraft in approximately fifteen months. This article provides a comprehensive discussion of recent actions taken by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the legal authorities invoked, the categories of actors targeted, and the general licenses issued.

The U.S. Court of Appeals for the Second Circuit issued a significant decision in Petersen Energía Inversora S.A.U. et al. v. Argentine Republic, reversing the $16.1 billion judgment entered by Judge Preska of the Southern District of New York against the Republic of Argentina.

New York County District Attorney Alvin Bragg and New York State Senator Zellnor Myrie recently announced draft legislation that would create additional state criminal exposure for cryptocurrency businesses operating without a valid New York license. The so called "CRYPTO ACT" would make it a criminal offense to engage in a “prohibited virtual currency act” in New York without a New York BitLicense issued by the New York Department of Financial Services.

On December 19, the U.S. Treasury’s Office of Foreign Assets Control announced a further expansion of Venezuela-related sanctions, taking coordinated action that included new Specially Designated Nationals (“SDN”) designations, the issuance of a Venezuela-related general license, and updated compliance guidance. These measures reflect the Trump Administration’s continued focus on applying targeted financial pressure against individuals and networks linked to narco-corruption and state-controlled energy activity in Venezuela.

On December 16, 2025, the U.S. Court of Appeals for the Eleventh Circuit issued a unanimous decision upholding the constitutionality of the Corporate Transparency Act (“CTA”), reversing a lower court ruling that had invalidated the statute.The decision represents a significant judicial endorsement of Congress’s effort to curb the use of anonymous companies in money laundering, sanctions evasion, and other forms of illicit finance.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed former Paraguayan President Horacio Manuel Cartes Jara and several affiliated companies from its Specially Designated Nationals (SDN) list, reversing measures that had been in place for nearly three years under the Global Magnitsky Human Rights Accountability Act.

The U.S. government is laser-focused on illicit fentanyl and synthetic opioid trafficking and has shifted its approach from targeting narcotics operators themselves to focusing on their financial and commercial infrastructure: banks, brokerage houses, trade intermediaries, corporations and logistics firms. There is a clear political and enforcement intent to “make examples” of institutions—regardless of size or degree of complicity—to establish deterrence, show resolve, and build domestic political capital.

Cristian Francos will be co-chairing the 27th annual transnational crime conference from May 14-16 at the Ritz-Carleton in Santiago, Chile.

Corruption often causes significant harm to businesses and individuals by undermining fair competition and depriving them of rightful opportunities. The United States’ Mandatory Victim Restitution Act (MVRA) provides a powerful legal mechanism for victims to seek restitution for their losses.

Cristián Francos co-moderates a panel on business crime crisis situations in a corporate environment at the International Bar Association's Annual Conference taking place in Mexico City on 15–20 September 2024.

Cristián Francos will be speaking at the 7th Marval Summit on Compliance, Anti-Corruption, and Investigations. Together with renowned speakers and colleagues, he will share experiences on the challenges, developments, and trends in this practice area. 

As part of the IBA's 26th Annual Transnational Crime Conference in Milan, Cristián Francos co-moderates a panel dissecting the intricate landscape of subsidies fraud in the aftermath of the Covid-19 pandemic.

Cristian Francos will moderate a panel at the inaugural IBA Arbitration and Criminal Law Conference. 

Cristián Francos moderated a panel exploring the growing trend to arbitrate disputes emerging from compliance investigations related to potential criminal conduct and will discuss the varying ways national courts review and accept any arbitral decisions in this area.

Partner Cristián Francos will co-chair a session on trends in global sanctions enforcement at the International Bar Association's 25th Annual Transnational Crime Conference.

Cristián Francos discussed the operation of Money Service Businesses without a license, US government enforcement and prosecution, and the impact for local financial actors.

Cristián Francos is Senior Vice Chair of the IBA’s Business Crime Committee and will be co-chairing “The transfer of criminal liability in M&A” session on November 3rd.

The U.S. Senate joined the House of Representatives and passed the 2021 National Defense Authorization Act, a defense spending bill, which included the Corporate Transparency Act (the “Act”).  That Act sets forth an expansion for the disclosure requirements for certain US and non-US companies doing business in the United States. 

The health effects of Covid-19 have created personal tragedies that seemed unimaginable a few short months ago. Despite the efforts of governments, the virus has shown that the world is inextricably interconnected. How we respond will dictate whether that interconnectedness is a positive or negative force as we try to recover from the economic crisis that has arisen in the wake of the pandemic. In Latin America, individuals and companies have either begun to see, or fear, the return of currency controls, defaults and chaos as the governments of the region confront historic challenges. Many have once again sought refuge in the perceived relative safety of the U.S. financial system. However, investors may find that their sudden search for a safe haven may bring on a series of unanticipated problems.

There is a popular misconception that asset forfeiture is limited to the luxury cars, private jets and speedboats of drug dealers, but many well-meaning businesses and individuals are finding themselves with their assets seized under statutes that provide U.S. authorities extremely broad powers. And these seizures often occur without any warning to, or even accusation against, the owner of the assets. Once seized it can take years to obtain recovery of perfectly legal assets. In these uncertain times, as many well-meaning people seek the relative safety of the U.S. banking system, individuals and companies in many countries may innocently use money-transfer systems that exponentially increase the risk of having their assets seized. Why does this happen and how can it be avoided?

In these tough times, when clients are looking to protect assets and increase revenue, it is more important than ever to ensure that their arbitral awards are collectible. A truly successful outcome requires the ability to enforce and monetize the award that was won in the arbitration. When faced with a recalcitrant award debtor, it is imperative to think strategically and work closely with counsel and experts to enforce and identify recoverable assets.

Lewis Baach Kaufmann Middlemiss partner Cristián Francos spoke at ACI's Anti-Corruption Compliance for High Risk Markets conference on July 24, 2019 in Washington, D.C.

Cristián Francos served as Organising Committee Head for the 22nd Transnational Crime Conference in Buenos Aires. 

Many people outside of Argentina, as well as those within, have watched in wonder as the explosive investigation of the Cuadernos case evolves and touches upon more and more individuals and companies. Recent experience has taught us that investigations of this magnitude are never contained within a country’s borders and individuals and companies that have done, or are doing, business in Argentina must consider the civil and criminal ramifications of the growing corruption scandal regardless of their own culpability.  

The increasing global focus on corruption has led to stronger international cooperation and coordination among regulators, resulting in landmark enforcement actions in new jurisdictions. [...] This panel offered private and public sector prespectives on the latest enforcement trends, the key elements of the new anti-corruption laws, and what all this means for businesses and individuals involved in transnational corruption cases.

Authored by Eric L. Lewis, Manuel S. Varela and Cristián Francos.

Lewis Baach Kaufmann Middlemiss earns firm rankings from Chambers and The Legal 500 for its international asset tracing and recovery practice.

Lewis Baach Kaufmann Middlemiss is recognized in the 2026 Legal 500 United States for boutique white-collar crime. This is the first time the firm  has been named to Legal 500's nationwide list.

The Legal 500 US City Elite 2026 recognizes five Lewis Baach Kaufmann Middlemiss partners in Washington and New York for excellence in international litigation and white-collar defense.

Chambers and Partners has recognized Lewis Baach Kaufmann Middlemiss among the top international counsel for corporate crime and investigations in Latin America in its 2026 Global Guide. 

Global Investigations Review has named Lewis Baach Kaufmann Middlemiss PLLC to its 2025 "GIR 100" list, which ranks the top law firms handling complex, cross-border investigations globally. This is the second year in a row that LBKM has made the list.

Much has been written about sweeping changes in Foreign Corrupt Practices Act (FCPA) enforcement under the Trump Department of Justice (DOJ).  An executive order signed by Mr. Trump when he took office commanded a pause in all FCPA cases, and subsequent policy memoranda and statements by DOJ officials signaled substantial changes in enforcement standards and prosecutorial focus.  A recent case filed by DOJ shows that FCPA indictments are still on the table, at least in some cases.

The trial of former Brazilian President Jair Bolsonaro, accused of a failed coup attempt following his defeat in the 2022 election, is set to end Friday, September 12, 2025. With a conviction widely anticipated and calls from Bolsonaro allies for expanded U.S. action, Brazil is bracing for potential new sanctions targeting individuals and institutions connected to the case.

Lewis Baach Kaufmann Middlemiss has been recognized for the second year in Chambers annual Latin America Guide for its Corporate Crime and Investigations practice area. Firm partners Adam Kaufmann and Cristián Francos also ranked for the first time as practitioners for the sector, demonstrating LBKM’s deepening strength and expertise in handling key issues impacting clients from the region.

Chambers has again noted Lewis Baach Kaufmann Middlemiss PLLC (LBKM) for its expertise in Latin America.

The 2025 Chambers Global guide ranks the firm among the top international counsel for corporate crime and investigation matters arising out of Latin America. LBKM is the only boutique firm to be included in this elite list.

Cristián Francos was quoted in Deutsche Welle on the Trump administration's decision to pause enforcement of the Foreign Corrupt Practices Act and the potential effects on Latin America.

Cristián Francos was quoted in Clarín on the Trump administration's decision to pause enforcement of the Foreign Corrupt Practices Act.

Global Investigations Review has ranked LBKM as one of the world’s leading firms for cross-border investigations.

The Engel List was designed as a critical foreign policy tool to identify and target individuals believed to be involved in corruption and actions undermining democratic institutions in Central America. While the List serves an important role in identifying the individuals responsible for corrupt practices in Central America, like many U.S. “lists,” it presents significant challenges from a due process perspective.

Lewis Baach Kaufmann Middlemiss made its debut this year in Chambers’ annual Latin America Guide, ranking as a leading international firm in the Corporate Crime & Investigations practice area.

LBKM is the only boutique firm to be so ranked.

Cristián Francos was quoted in an article discussing the frameworks used in many Western countries to provide compensation to overseas victims of economic crime.

Who's Who Legal (WWL) has again recognized Cristián Francos as a global leader in the field of investigations. WWL highlights lawyers at the forefront of the investigations field, spanning white-collar crime, corporate compliance and regulatory enforcement.

LBKM filed an amicus brief in support of the Republic of Argentina with the United States Court of Appeals for the Second Circuit in Petersen v. Argentina and a related appeal. LBKM represented OFEPHI, an organization of ten Argentine provinces, arguing that the district court misconstrued Argentina's expropriation law, and that complex questions of Argentine law should be left to Argentine courts.

Cristián Francos, partner at Lewis Baach Kaufmann Middlemiss and head of the firm’s Latin America practice, has again been recognized by Who's Who Legal as a global leader in the field of investigations.

The International Bar Association (IBA) has appointed partner Cristián Francos as Co-Chair of its Business Crime Committee for a two-year term.

El Departamento de Justicia de los Estados Unidos colocó en el ojo público la actividad de transferencia de dólares sin licencia habilitante en los Estados Unidos. Las repercusiones para la industria financiera de Uruguay fueron tratadas por Cristián Francos y Jean-Jacques Bragard Cooper en el siguiente artículo publicado en el diario El Observador.

En una demanda por confiscación de fondos presentada ante una corte del Distrito Sur de Nueva York, los fiscales estadounidenses explicaron porqué el movimiento de esos dólares en su entrada y paso por el país norteamericano sería ilegal.

According to U.S. authorities, the U.S.-based activities of “blue dollar peso exchangers” are illegal, and those exchangers that maintain U.S. bank accounts are subject to asset forfeiture and criminal prosecution. The recent U.S. forfeiture case brought by U.S. authorities in the U.S. District Court for the Southern District of New York against Partners Capital Investment (“PCI”) illustrates intense interest by U.S. authorities in the “blue dollar peso exchange,” and additional U.S. actions should be expected. 

Cristián Francos has again been recognized as a global leader in the field of investigations by Who’s Who Legal in its Investigations: 2022 guide.

Arthur Middlemiss and Cristián Francos secured the return of all funds seized by the U.S. Department of Justice from U.S. accounts maintained by two broker-dealers based in Uruguay and New Zealand, respectively, both of which operated in Argentina. 

On December 9, 2021, the Biden administration published the first-ever United States Strategy on Countering Corruption. This Strategy sets forth a “whole-of-government” approach to combating corruption in the United States and around the world. Individuals and entities should expect an increase in sanctions and scrutiny of activities that present high corruption-related risk. As such, companies and individuals should immediately review current business activities to ensure that they understand their exposure to corruption-related risk and have in place commensurate controls to deter and detect potential problems. A proactive approach to corruption risk now will provide material future benefits if the expected increase in regulatory and law enforcement scrutiny results in a corruption-related inquiry.

LBKM partner Cristián Francos has been appointed as Senior Vice Chair of the IBA’s Business Crime Committee.

Cristián Francos been recognized as a Global Leader in Who’s Who Legal: Investigations 2021.  Who’s Who Legal is one of the world’s leading directories of legal practitioners.

Mr. Truppel was sentenced in the U.S. District Court for the Southern District of New York to time served, with no supervisory probation or fine imposed, and was allowed to return to Argentina.

Partner Cristián Francos was highlighted by Global Investigations Review as a lawyer of note and a member of Argentina's investigations bar.

An amended complaint filed in Miami-Dade County alleges that Amicorp, an international trust services company, actively participated in a multi-million-dollar real estate fraud which victimized many Latin American families. 

Partners Manuel Varela and Cristián Francos authored a paper on the Argentine Notebooks investigation which was quoted in Argentina’s La Nación.

Mr. Francos was quoted in the article saying, “If someone received a bribe, then someone had to have paid the bribe,” he said. “Companies should be well prepared [to be investigated].”  He continued to say, many Argentinian companies that are contracted by the state do not have established policies in terms of compliance and integrity, and will likely rush to put together new compliance programmes. Francos said “this shock could be good” to improve standards quickly.  “This [scenario] creates a problem for companies, but also an opportunity that will bring change to Argentina’s business culture,” he said.

En Lewis Baach Kaufmann Middlemiss asesoran a clientes internacionales en litigios también internacionales, investigaciones y compliance. "Nuestra práctica trasciende las fronteras de los Estados Unidos permanentemente. En mi caso, me dedico a asesorar clientes latinoamericanos respecto de sus necesidades legales en los Estados Unidos", dice Cristian Francos, socio de la firma y su cara en la Argentina.

Mr. Francos is quoted in the article.

Mr. Francos is a contributing author.

Mr. Francos is mentioned in the article.

AUNO Abogados magazine interview with Manuel Varela and Cristián Francos on Lewis Baach’s practice for clients in Argentina and the rest of Latin America. 

Ariel Neuman, Natalia Alonso and Alfredo Veronesi, reporters from AUNO Legal Magazine, interviewed Manuel Varela and Cristián Francos regarding the Lewis Baach PLLC Latin American practice and it's Buenos Aires office as well as the careers of  Messrs. Varela and Francos.