Mr. Sanctions

December 9, 2025: OFAC Sudan-related Designations; Russia-related Designations Removals

Treasury Press Release: Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War

From today’s OFAC release:

The additions to the Sudan program:

The following individuals have been added to OFAC’s SDN List:

[SUDAN-EO14098] – Executive Order 14098 (Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition)

  • DUQUE BOTERO, Mateo Andres
    • Address: Calle 77 9 76 APT 302, Bogota, Colombia
    • DOB: 07 Apr 1975
    • POB: Bogota, Colombia
    • Nationality: Colombia
    • Alt. Nationality: Spain
    • Gender: Male
    • Cedula No.: 79782423 (Colombia)
    • Passport: AS272175 (Colombia) expires 31 Mar 2026
    • Alt. Passport: XDD789846 (Spain)
    • Alt. Passport: BF868819 (Colombia) expires 01 Mar 2035
    • Type: Individual
    • Linked To: MAINE GLOBAL CORP S.A.S.
    Supplemental Information:According to the Treasury Department, Mateo Andres Duque Botero (“Duque”) manages Maine Global Corp S.A.S., a Bogotá-based employment agency. He is a dual Colombian-Spanish national who holds positions as shareholder, president, or director in firms across Colombia, the United States, and the United Kingdom. Public records from the UK Companies House indicate a “Mateo Andres Duque Botero” was appointed director of Zeuz Global Ltd in July 2025. Duque allegedly utilized his U.S.-based firms to process payroll payments for Colombian fighters in Sudan and served as a foreign exchange intermediary to convert curre1ncies for the network.
  • MUNOZ UCROS, Monica (a.k.a. MUÑOZ UCROS, Monica)
    • Address: Calle 77 9 76 APT 302, Bogota, Colombia
    • DOB: 14 Jun 1976
    • POB: Bogota, Colombia
    • Nationality: Colombia
    • Gender: Female
    • Cedula No.: 52413003 (Colombia)
    • Passport: AX032470 (Colombia) expires 11 Mar 2031
    • Type: Individual
    • Linked To: MAINE GLOBAL CORP S.A.S.
    Supplemental Information:Monica Munoz Ucros serves as the alternate manager of Maine Global Corp S.A.S. and manages Comercializadora San Bendito S.A.S. The Treasury states she facilitated wire transfers between Duque Botero and U.S. companies to support the recruitment network.
  • OLIVEROS FORERO, Claudia Viviana
    • Address: Bogota, Colombia
    • DOB: 02 Jan 1973
    • POB: Bogota, Colombia
    • Nationality: Colombia
    • Gender: Female
    • Cedula No.: 52252815 (Colombia)
    • Passport: AZ321704 (Colombia) expires 20 Jul 2032
    • Type: Individual
    • Linked To: INTERNATIONAL SERVICES AGENCY S.A.S.
    Supplemental Information:Claudia Viviana Oliveros Forero (“Oliveros”) is the owner and manager of International Services Agency S.A.S. (A4SI), the central recruiting node for the network. She is the wife of Alvaro Andres Quijano Becerra. She previously served as president and treasurer of the Panama-based Talent Bridge, S.A. (formerly Global Staffing S.A.), maintaining affiliation to obfuscate the network’s activities.
  • QUIJANO BECERRA, Alvaro Andres
    • Address: Bogota, Colombia
    • Address: United Arab Emirates
    • DOB: 18 Jul 1967
    • POB: Bogota, Colombia
    • Nationality: Colombia
    • Alt. Nationality: Italy
    • Gender: Male
    • Cedula No.: 80413253 (Colombia)
    • Passport: AP628498 (Colombia)
    • Alt. Passport: YB7731256 (Italy) expires 01 Mar 2031
    • Type: Individual
    Supplemental Information:Alvaro Andres Quijano Becerra (“Quijano”) is a retired Colombian military officer and dual Colombian-Italian national based in the UAE. Treasury identifies him as the central figure recruiting former Colombian military personnel for the Rapid Support Forces (RSF) in Sudan. He co-founded A4SI. Public reports, including from The Sentry, allege Quijano is a former associate of the Norte del Valle Cartel. He reportedly utilizes his UAE connections to facilitate the deployment of mercenaries.

The following entities have been added to OFAC’s SDN List:2

[SUDAN-EO14098] – Executive Order 14098 (Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition)3

  • COMERCIALIZADORA SAN BENDITO S.A.S.4
    • Address: Bogota, Colombia5
    • NIT #: 9011008200 (Colo6mbia)
    • Matricula Mercantil No: 02846256 (Colombia)
    • Linked To: MUNOZ UCROS, Monica
    Supplemental Information:Managed by Monica Munoz Ucros, this Bogotá-based entity allegedly engaged in wire transfers with U.S. companies associated with the network to move funds related to the recruitment of fighters.
  • INTERNATIONAL SERVICES AGENCY S.A.S. (a.k.a. “A4SI”; a.k.a. “ACADEMY FOR SECURITY INSTRUCTION S.A.S.”)
    • Address: Avenida Carrera 19 No. 97-31 Of. 603, Bogota, Colombia
    • Website: https://a4si.com.co
    • NIT #: 9010625922 (Colombia)
    • Matricula Mercantil No: 02792522 (Colombia)
    Supplemental Information:A4SI is an employment agency co-founded by Quijano and owned/managed by Oliveros. It is identified as the primary node for recruiting Colombian mercenaries for the war in Sudan, using its website and social media to fill positions for snipers and drone operators. The company describes itself on its website as a “transnational private employment management and placement agency.”
  • MAINE GLOBAL CORP S.A.S.
    • Address: Bogota, Colombia
    • Website: https://maineglobal.net
    • NIT #: 9018645322 (Colombia)
    • Matricula Mercantil No: 03863364 (Colombia)
    • Linked To: TALENT BRIDGE, S.A.
    Supplemental Information:Managed by Mateo Andres Duque Botero, this entity manages and disburses funds for the recruitment network. It reportedly processes payroll for fighters and acts as a foreign exchange intermediary.
  • TALENT BRIDGE, S.A. (a.k.a. GLOBAL STAFFING S.A.)
    • Address: Calle 54 Barrio PH Twist Tower, 28th Floor, Office F, Panama City, Panama
    • Website: https://globalstaffingsa.com/
    • RUC #: 155722003-2-2022 (Panama)
    • Linked To: INTERNATIONAL SERVICES AGENCY S.A.S.
    Supplemental Information:Formerly known as Global Staffing S.A., this Panama-based entity is used by A4SI to sign contracts and receive funds, thereby minimizing legal exposure and obscuring links to the RSF. Its website is reportedly identical to that of A4SI.

And the removals from Russian sanctions:

The following deletions have been made to OFAC’s SDN List:

[RUSSIA-EO14024]

  • [RUSSIA-EO14024] Russia Harmful Foreign Activities Sanctions: Russia Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587; Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation.”

ASTRAKHAN, Kirill Aleksandrovich (a.k.a. ASTRAKHAN, Kirill (Cyrillic: АСТРАХАНЬ, Кирилл)), Moscow, Russia; DOB 17 Nov 1987; POB Donetsk, Ukraine; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 721242410 (Russia) (individual)

ASTRAKHAN, Kirill (Cyrillic: АСТРАХАНЬ, Кирилл) (a.k.a. ASTRAKHAN, Kirill Aleksandrovich), Moscow, Russia; DOB 17 Nov 1987; POB Donetsk, Ukraine; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 721242410 (Russia) (individual)

SOBOLEV, Nikita Aleksandrovich, Malta; DOB 07 Jun 1986; nationality Russia; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport 550193782 (Russia); National ID No. 238667A (Malta) (individual) (Linked To: MALBERG LIMITED)

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