According to the cited documentsScope of Decree 11-2025: to be confirmedTo be confirmedOperational security
It is a federal legal risk: OSAC states in as many words that paying extortion demands to criminal groups designated as FTOs may constitute "material support" under 18 U.S.C. § 2339A-D, and recommends that compliance departments verify that they are not giving material support, knowingly or otherwise, to FTOs. Since November 2025 it is also, potentially, an offense of terrorist financing under Guatemalan law (Decree 11-2025). "Pay the rent and keep operating" ceases to be an option for subsidiaries of US companies.