Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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12 OFAC TARGETS NARCOTICS TRAFFICKERS & CRIMINAL ORGANIZATIONS This quarter OFAC escalated its effort to curb illicit drug trafficking through multiple actions targeting members of two Mexican drug cartels: the Sinaloa Cartel and Cartel de Jalisco Nueva Generacion (CJNG). • In the first action, on February 10, OFAC sanctioned Wilder Emilio Sanchez Farfan and Miguel Angel Valdez Ruiz for participating in the international illicit drug trade. OFAC reports that Sanchez Farfan, an Ecuadorian national, is a cocaine supplier for the Sinaloa Cartel and CJNG, transporting multi-ton quantities of cocaine from Guayaquil, Ecuador to Mexico, and ultimately, into the US. Valdez Ruiz, a Mexican national, was sanctioned for working as an intermediary between Sanchez Farfan and a Sinaloa Cartel leader, Ismael Zambada Garcia. Both Sanchez Farfan and Valdez Ruiz have been indicted in the US District Court for the Southern District of California and are considered fugitives. • A week later, on February 17, OFAC designated Sergio Armando Orozco Rodriguez for laundering the proceeds of drug trafficking on behalf of CJNG in Puerto Vallarta, Mexico. According to OFAC, Orozco Rodriguez requires new businesses to receive unofficial permission from him prior to opening, then collects taxes from the businesses for the CJNG. • The next month, on March 18, OFAC designated the Los Huistas Drug Trafficking Organization and two of its leaders under E.O. 14059. According to OFAC, the Los Huistas both produce drugs for export and also smuggle cocaine, methamphetamine, and heroin from Northern Guatemala to the United States through Mexico with the help of sanctioned organizations like the Sinaloa Cartel and the CJNG. OFAC also designated Eugenio Dario Molina Lopez, who oversees the Los Huistas and primarily traffics South and Central American cocaine into Mexico. Another Los Hustas leader, Aler Baldomero Samayoa Recinos, organizes shipments of cocaine from Guatemala to Mexico and launders money.

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