Mr. Sanctions

Category: Regulatory

  • July 31, 2026: State announces additions to UFLPA Entity List

    Additions to the Uyghur Forced Labor Prevention Act Entity List

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, SPOKESPERSON

    JULY 31, 2026

    Today, the United States added 43 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, a key tool in preventing the importation into the United States of goods made with forced labor and leveling the playing field for American companies.  The UFLPA, enacted in 2021, aims to prevent goods tainted by forced labor of Uyghurs and other ethnic minorities in China from entering the U.S. market, holding accountable entities involved in such practices.

    The newly listed entities are connected to the production and sale of goods made in Xinjiang or with the forced labor of Uyghurs and other groups specified in the UFLPA, and include seafood, gold, copper, transportation infrastructure, aluminum, tomatoes, cotton, garments, and frozen food, among others.  These additions bring the total number of entities on the UFLPA Entity List to 187.

    Forced labor distorts markets and allows foreign actors to abuse the global trading system.  Through the expansion of the UFLPA Entity List, the Trump Administration is taking action to eliminate forced labor from global supply chains, restoring a fair market for Americans while reducing instances of forced labor worldwide. The United States expects our trading partners around the world to enact and enforce similar laws prohibiting goods made with forced labor.

    Today’s action is being taken by the Forced Labor Enforcement Task Force (FLETF), a task force of interagency partners dedicated to monitoring the enforcement of the prohibition on importing goods made wholly or in part with forced labor into the United States, including as mandated by the Uyghur Forced Labor Prevention Act.  Chaired by the Department of Homeland Security, FLETF’s voting members include the Departments of State, Labor, Commerce, Justice, and Treasury, and the U.S. Trade Representative. For details, please refer to the Department of Homeland Security’s Press Release.

    The press release from DHS:

    DHS Announces the Addition of 43 Companies to the UFLPA Entity List

    Release Date: July 31, 2026

    Goods produced by these entities are prohibited from entering the United States

    WASHINGTON – Today, the Department of Homeland Security (DHS), on behalf of the Forced Labor Enforcement Task Force (FLETF), announced the addition of 43 companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, as well as technical updates to two existing entities. Upon publication, 187 entities will be on the Entity List, a 30% increase in the number of entities listed and the single largest-ever expansion of the List.

    Effective August 3, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption that goods produced by these 43 entities are prohibited from entering the United States as a result of the companies’ activities, either sourcing materials from the Xinjiang Uyghur Autonomous Region (Xinjiang, the XUAR) or working with the government of Xinjiang to recruit, transport, transfer, harbor, or receive Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of the XUAR.

    “Today we are adding 43 Chinese companies to the Uyghur Forced Labor Prevention Act Entity List, and DHS will ensure their products do not enter our country,” said DHS Secretary Markwayne Mullin. “The American worker must not be undercut and cheated by foreign companies that use slave labor. Our job is to defend the Homeland, and that includes protecting our citizens from unfair competition that not only disadvantages Americans, but harms human dignity.”

    Since enactment of the UFLPA, CBP has denied entry to more than 24,300 shipments pursuant to this expanded authority, valued at nearly $1 billion, blocking illicit goods from reaching U.S. markets.

    DHS and the FLETF remain dedicated to ensuring that goods made with forced labor are prohibited from importation into the United States. By holding foreign businesses accountable for their inhumane and unfair practices, the Trump Administration is also creating a level playing field for American workers and manufacturers. These additions to the UFLPA Entity List demonstrate the Administration’s devotion to strengthening our economic and national security by keeping these illicit goods out of our markets.

    “The Trump Administration remains steadfast in its commitment to remove forced labor from U.S. supply chains and to holding foreign companies accountable for their exploitation,” said DHS Under Secretary for Strategy, Policy, & Plans Rob Law, who serves as the Chair of the Forced Labor Enforcement Task Force. “We are uncompromising in the continued prevention of unfair practices that undermine American businesses – expansion of the UFLPA Entity List is a tool by which DHS can ensure both our economic and national security.”

    The 43 new entities include companies in high-priority sectors for enforcement, including aluminum, apparel, copper, cotton, as well as tomatoes and downstream products. These additions to the UFLPA Entity List reflect the Administration’s priority to strengthen our national security and empower our economic prosperity by keeping these illicit goods out of our markets. In addition, the FLETF announced technical updates to the official names of two entities currently on the list.

    DHS and DOJ relatedly formed the Trade Fraud Task Force, which recently celebrated over $1 billion in penalties, recoveries and charged losses, and which continues to prioritize enforcement against forced labor as a significant trade fraud typology.

    “The DHS-DOJ Trade Fraud Task Force brings a new energy to our enforcement against illicit imports and our broader efforts to end the human suffering caused by forced labor,” said DHS Assistant Secretary for Trade and Economic Security Aris Kourkoumelis. “Importers should know that those who attempt to circumvent today’s action and knowingly import goods produced with forced labor will be prosecuted to the fullest extent of the law.”

    Since the implementation of the UFLPA, DHS and the FLETF continue to make significant strides to prevent the importation of goods made with forced labor into the United States. These advances reflect the Trump Administration’s commitment to eliminating forced labor from global supply chains. As articulated in the 2025 Updates to the UFLPA Strategy issued on August 19, 2025, today’s addition of 43 entities further demonstrates the Trump Administration’s commitment to combating the importation of goods made by companies that exploit human suffering.

    DHS and the FLETF continue to work closely with stakeholders across industry, mission-driven organizations, and international partners to strengthen enforcement and support compliance. Addressing these threats to our supply chains strengthens our economic and national security. Additions to the UFLPA Entity List assist CBP in its enforcement and help eliminate threats to American businesses from foreign competitors’ unfair practices.

    DHS will publish the revised UFLPA Entity List as an appendix to a Federal Register notice on August 3, 2026.

    Read more about DHS’s implementation and enforcement of the UFLPA by visiting: www.dhs.gov/uflpa.

    View the entity-specific information from this announcement.

    and the entity-specific information:

    26_0731_plcy_uflpa-entity-specific-informationDownload

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  • Burning Questions; My Dinner with Claude – When Does Money Actually Belong to Someone? A Payment-Law Detour

    My prompt:

    let’s go back to Scenario A: there has to be, in order to effectuate the instruction, an account relationship of some kind, doesn’t there? So why is that case different? You’ve got assets being allocated for a sanctioned party – the only difference is that, in Scenario A, it’s being taken from an existing pooled asset. Or am I missing something?

    Claude responded:

    You’re not missing something, and it’s a sharp catch — there genuinely is an “account relationship” and something IS being drawn from a pooled asset. But the question is whether that operational fact amounts to a legal interest for the designated person, and here payment law itself already draws the line you’re looking for, independent of sanctions law entirely.

    A wire transfer isn’t one asset moving through a pipe — it’s a chain of separate obligations

    Under the commercial law that actually governs funds transfers (UCC Article 4A in the US; the EU’s Settlement Finality Directive and the payment-services framework in Europe), a beneficiary acquires zero legal claim against their own bank until that bank “accepts” the payment order — the beneficiary’s bank is only obliged to pay the beneficiary once it accepts the order, and acceptance itself is defined narrowly: the earliest of the bank paying the beneficiary, notifying them of receipt, or receiving settlement for the order. Before that moment, nothing has legally reached the beneficiary — the money belongs to the recipient, free of any strings, only once finality is reached. This isn’t a sanctions-specific fiction. It’s the ordinary rule that governs every wire transfer on earth, sanctions or not — it’s what determines, say, whose money it is if a bank fails mid-transfer, or if a payment gets mis-keyed to the wrong account.

    So what is actually happening at your end when you debit Customer A?

    Bank A debiting Customer A’s account and sending a payment message isn’t Bank A moving the designated person’s property — it’s Bank A discharging (or beginning to discharge) its own contractual obligation to Customer A, funded out of Bank A’s own balance sheet and correspondent liquidity. That pooled asset is Bank A’s, being drawn down pursuant to A’s instruction; the designated person is a total stranger to that relationship until their own bank actually accepts the order on their behalf. If you refuse at that point, nothing reverses because nothing left — Customer A’s account was never debited (or is simply uncredited if it briefly was), and there’s no moment where the designated person held anything that now has to be “returned.” That’s precisely why refusal doesn’t require a licence the way unwinding a completed freeze does: there’s nothing to unwind.

    Why “belonging to/held/controlled by” tracks this, and why OFAC doesn’t

    The EU-family test (belonging to, owned, held, or controlled by) is simply importing the ordinary payment-law vesting point rather than inventing its own. OFAC’s blocking regime is the outlier specifically because its “interest of any nature whatsoever, direct or indirect” definition is deliberately written to reach behind that ordinary vesting rule — US commercial law (the same UCC 4A) agrees with the EU-family approach that the beneficiary has no claim pre-acceptance, but OFAC’s sanctions regulations override that for blocking purposes, treating mere intended-beneficiary status as sufficient. So the divergence being described here isn’t a difference in what property law says happens to a payment in flight — both systems’ underlying commercial law agrees on that. It’s that only one of them layers a sanctions-specific rule on top that disregards it.

    This also explains the countermand test from the UK “trapped payments” guidance covered previously — asking whether a designated bank still had the right to recall the funds is just asking whether finality/irrevocability had occurred yet. Same doctrinal line, applied to figure out whether the freeze duty travels with the money through a correspondent chain. And it’s why an intermediary bank in the EU-family model typically has nothing of the designated person’s to freeze mid-chain at all: under this same logic, none of the intervening correspondent legs constitute the beneficiary holding anything either, right up until the final beneficiary’s bank accepts.

    One thing worth keeping separate: this settles whether the Scenario A/B line is legally real rather than cosmetic — it doesn’t reopen the policy question of whether refuse is a strong enough response on its own. Those are different questions.

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  • Burning Questions; My Dinner with Claude – Is ‘Just Say No’ a Cop-Out? The Politics Behind Freeze vs. Refuse

    My prompt:

    By refusing or rejecting a transaction, isn’t the regulator copping out? After all, the transaction could be accomplished somewhere else – say, in China or Turkey

    Claude responded:

    It’s a fair gut reaction, but it conflates two different questions: “does this stop the sanctioned party from ever getting the money” and “what happens to the specific transaction sitting in front of this specific firm.” Those aren’t the same question, and once you separate them, block doesn’t actually beat reject on the first one.

    The workaround problem is real, but it’s not a reject-specific problem

    If a UK bank refuses to send the payment, sure, the customer can try Beijing, Istanbul, or Dubai. But if a US bank blocks the payment instead, the designated person’s next attempt at financing can just as easily route through those same channels — blocking one wire doesn’t inoculate the rest of their commercial life. This is a well documented, general limitation of unilateral and even coordinated multilateral sanctions: research on sanctions evasion has tracked how Chinese and Russian arms have continued flowing to embargoed destinations for decades through non-dollar channels that sit outside any single regime’s reach. So “they’ll just go elsewhere” is a real critique of sanctions regimes in general — it applies to block just as much as reject. Neither mechanism solves global circumvention; both only capture what happens to already be within a given firm’s grasp at a given moment.

    So is releasing that specific transaction really nothing?

    Not quite. A rejected payment still comes with a mandatory report to the competent authority in every jurisdiction covered so far — so even though the money moves on, the attempt gets logged: who tried to pay whom, through which counterparties, on what pretext. That’s raw material for future listings, for identifying facilitators, and for building the kind of evidentiary record these regimes’ own courts increasingly demand. It’s a much thinner form of “action” than seizing the money, and it isn’t honest to pretend otherwise — but it isn’t nothing either.

    The real reason isn’t laziness, it’s legal exposure

    Here’s the part that actually answers the question. The EU, UK, Switzerland, Canada, and Australia are all legal systems where courts have been genuinely aggressive about policing sanctions listings on due-process and property-rights grounds — and the cleanest illustration is that the same person, Mr. Kadi, brought parallel challenges in EU and US courts over the same asset freeze, and the EU courts ruled the listing process lacked fundamental protections while the US courts rejected the equivalent constitutional claims. If that’s how exacting these courts are about freezing a person who has actually been designated, extending that seizure power further — to a non-designated customer’s own money, based solely on their stated intent to pay someone else — would be a considerably bigger and more legally exposed step, one these systems have chosen not to take. The US, operating under IEEPA’s far more executive-deferential tradition, doesn’t face the same internal constraint, which is a large part of why it’s comfortable blocking property whose ownership hasn’t fully vested yet.

    There’s a structural reason layered on top of the legal one. The US can afford to cast that wide a net because so much of world trade has no way to avoid touching dollar clearing — roughly 88 percent of foreign-exchange transactions involve the dollar, and the correspondent banking system that actually moves the money concentrates through a small number of banks in New York and London. Blocking a dollar payment captures real marginal value precisely because rerouting around the dollar is genuinely hard. A rejected euro, pound, franc, Canadian, or Australian dollar payment is comparatively easy to complete elsewhere without touching that currency’s clearing system at all, so the deterrent value of seizing a non-designated customer’s funds is lower relative to the legal and political cost of doing it — this half of the explanation is an original synthesis of the two facts above, not something any regulator has stated as its rationale.

    And this isn’t a “the EU goes soft” story — the freeze side still bites, hard

    Worth remembering: none of this caution applies once a resource actually belongs to the designated party. The clearest proof is sitting in Belgium right now — roughly €210 billion of Russian Central Bank reserves are frozen in Europe, most of it at the Euroclear depository, and that’s a Scenario B freeze, not a reject outcome, because those securities already belonged to the CBR the moment it was designated. And the EU’s own hesitation about going one step further — from freezing that money to actually using it for a reparations loan — is itself a live demonstration of the exact caution just described: Belgium has resisted precisely on expropriation grounds, warning other reserve holders might flee European custody, and Russia’s central bank has already sued Euroclear for roughly $230 billion over the freeze itself. That’s not a regime being casual about property rights; if anything it’s the same instinct that keeps the reject rule in place for in-flight payments, now playing out at nation-state scale.

    Self-check

    • Kadi I/II outcomes and the EU/US divergence: confirmed across multiple sources including a direct comparison piece and the CJEU’s own case summary.
    • Dollar/FX and correspondent-concentration figures: from a 2026 explainer drawing on the Farrell & Newman “weaponized interdependence” literature — solid secondary sourcing, not a primary BIS/Fed data pull.
    • Euroclear/CBR figures (~€210bn, ~€193bn at Euroclear, Belgium’s objections, the Russian lawsuit): converging figures across CFR, CEPR, Squire Patton Boggs, and AP reporting from November 2025–January 2026 — figures move slightly by source and date, so treat the exact number as “roughly €200–210bn” rather than a fixed figure if publishing this.
    • The causal argument connecting legal-rights culture and dollar centrality to the reject/block design choice is original synthesis — no regulator has published that rationale in those terms.

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  • Burning Questions; My Dinner with Claude – Six Countries, Two Wires: A Sanctions Compliance Cheat Sheet

    My prompt:

    ok… let’s open the aperture a bit. Explain what a compliant firm is supposed to do, for the US, UK, EU, Canada, Australia and Switzerland, in the following 2 scenarios – assuming we’re talking blocking/freezing sanctions only: Scenario A: You receive instructions to make a payment that involved a sanctioned party. Scenario B: You receive funds that involve a sanctioned party. For each scenario, also denote whether the answer is different in the case you are the beneficiary bank or an intermediary bank. Phrase this for a sanctions novice, but feel free to quote text (not full regulatory sections) – like “make economic resources available”, for example. Assume that my goal is to eventually, once I refine the response, make a “Burning Questions” post out of this

    Claude responded:

    This is exactly the kind of question that makes a good Burning Questions piece, because the honest answer isn’t “six jurisdictions, six rules” — it’s one rule almost everyone agrees on, and one narrow but consequential place where the US breaks from the rest.

    Two moves, and two roles, defined simply

    A compliant firm facing a sanctioned party has two different levers available, and confusing them is the single most common mistake:

    • Freeze/block: take the resource into your own custody, lock it away from everyone — including the customer who originally owned it — and report it. Nobody gets it until a regulator says otherwise.
    • Refuse/reject: simply decline to carry out the instruction. The money never leaves the paying customer’s account, so there’s nothing to freeze.

    And two roles matter for how this plays out:

    • Beneficiary bank: the bank holding the account of the person or entity who’s supposed to end up with the money.
    • Intermediary (correspondent) bank: a bank in the middle of the chain, routing the payment onward, with no account relationship to either the sender or the ultimate recipient.

    Scenario A: you receive instructions to make a payment that involves a sanctioned party

    Picture a customer who isn’t sanctioned asking you to send money to someone who is.

    JurisdictionWhat you doBeneficiary vs. intermediary bank
    US (OFAC)Block. Take the funds into a blocked, interest-bearing account. Don’t send them, and don’t hand them back to the customer either.No difference in principle — blocking applies regardless of whether it is the originating or intermediary bank in the chain. A purely blind intermediary with no account relationship to a non-listed related party gets a narrow pass on investigating what it has no way of knowing, but the moment it knows or should know a designated person is involved, it blocks too.
    UK (OFSI)Refuse. Don’t execute the payment; the customer’s own funds are untouched.Same principle for any bank in the chain — but correspondent banks caught mid-chain have created a genuine practical headache here (see below).
    EURefuse — going ahead would mean making economic resources available to the designated person, which every EU regulation prohibits directly or indirectly.Same in principle for whoever in the chain is asked to move the money.
    Switzerland (SECO)Refuse, for the same reason — Swiss ordinances closely mirror the EU wording, prohibiting third parties from making economic resources available to a listed person.Same in principle.
    CanadaRefuse — completing the payment would breach the ban on making any goods available to a designated person, or providing services to their benefit.Same in principle, though published Canadian guidance addressing intermediary banks specifically the way the US and UK have could not be located.
    Australia (DFAT/ASO)Refuse — a person commits an offence if they make assets available to a designated person or entity.Same in principle.

    The one country that flips the answer is the US, and it’s worth pausing on why. OFAC treats a designated person’s status as intended beneficiary of a payment as itself an “interest” in the funds, so the moment the firm has possession or control of the money for the purpose of sending it their way, it’s already blockable property — even though it started out as the customer’s own money and never actually reached anyone. Everyone else in this table requires the resource to actually belong to, or be held or controlled by, the designated person before the freeze duty exists — and a payment instruction that hasn’t been executed yet doesn’t meet that bar. So the divergence isn’t really about freeze versus reject as competing philosophies; it’s about how early each regime decides a sanctioned party has acquired an interest in money that hasn’t arrived yet.

    Scenario B: you receive funds that involve a sanctioned party

    Now flip it: money has actually arrived, or is already sitting in an account, where a designated person has a real, present interest — as the account holder, or as the completed beneficiary of an inbound transfer.

    JurisdictionWhat you doBeneficiary vs. intermediary bank
    US (OFAC)Block, and report within 10 business days.No difference — whoever’s possession or control the funds come within, blocks, subject to the same narrow intermediary safe harbor as above.
    UK (OFSI)Freeze, and report.The beneficiary bank freezes without question. An intermediary bank is generally fine to keep routing a payment onward provided the funds aren’t owned, held, or controlled by a designated person at the point it’s dealing with them — which gets complicated fast if a designated bank sat somewhere upstream (see below).
    EUFreeze, and report to the national competent authority. Notably, a bank is explicitly permitted to credit an incoming third-party payment into a frozen account without needing prior authorization for that specific act — the funds simply join the frozen pool once they land.Same logic as the UK: a true intermediary that never holds the designated person’s resources has nothing to freeze; a beneficiary bank freezes on receipt.
    SwitzerlandFreeze, and report to SECO.Same principle as the EU.
    CanadaFreeze (functionally, by disclosing the property to the RCMP and being barred from dealing with it) — firms must report property in their possession or control that is owned or controlled by designated persons and freeze such property.Same principle, applied to whoever holds it.
    AustraliaFreeze, and notify the Australian Federal Police.Same principle for whoever is holding the asset.

    This is really the headline finding: on receipt, all six jurisdictions land in the same place. The freeze duty is nearly universal once a designated person actually has a stake in the resource — the interesting divergence lives entirely in Scenario A, where the US alone extends that duty backward to cover an unexecuted instruction.

    Two wrinkles worth knowing for intermediary banks specifically

    US: OFAC’s own guidance draws the safe-harbor line precisely. An intermediary bank with no account relationship to a non-listed party referenced in a wire, and no actual or constructive knowledge of a blocking issue, isn’t expected to go digging — but the instant it has information suggesting blocked status, the duty to block attaches regardless of its position in the chain.

    UK: because the UK (unlike the EU generally) has designated entire banks, correspondent banks kept finding themselves holding payments that had passed through a now-designated bank somewhere upstream, with no clean way to either complete or return them — the industry calls these “trapped payments.” OFSI’s analysis turned on whether the designated bank still had a right of countermand over the funds at that point in the chain: if it had already discharged its role and lost any right to pull the funds back, the funds were no longer considered owned, held, or controlled by that designated bank, so the freeze duty didn’t travel downstream with it. That general licence has since been superseded by later amendments, so it’s an illustration of the reasoning rather than current operative guidance — worth pulling OFSI’s live Russia guidance before citing the mechanism itself.

    Self-check

    • US: OFAC FAQ 36 (reject example), FAQ 116 (intermediary safe harbor), and 31 CFR 501.603 (blocked-property reporting) pulled directly from ofac.treasury.gov.
    • EU: Regulation 36/2012 Article 14 template and the Council’s July 2024 Best Practices document, both previously verified.
    • UK: OFSI’s general guidance and reporting pages (gov.uk, ofsi.blog.gov.uk) plus the Trapped Payments general licence publication notice — flagged above as superseded, useful for the reasoning, not for current citation.
    • Canada: Global Affairs Canada’s own “Dealings prohibition and asset freeze” and disclosure pages — solid primary sourcing, but nothing found specific to intermediary-bank treatment; that’s a gap in published guidance, not a claim made by extension.
    • Australia: DFAT/Australian Sanctions Office guidance notes, all primary and current (2024–2025 dated).
    • Switzerland: sourced mainly through a Swiss press account describing the ordinance language rather than a direct ordinance or SECO FAQ pull — worth swapping in the exact ordinance article, and worth checking whether SECO’s FAQs address this reject/freeze point directly before publishing.
    • The “when does an interest attach” framing that ties the whole piece together is an original synthesis of the sourced material above, not a line any one source states outright.

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  • Burning Questions; My Dinner with Claude – Block vs. Refuse: Why the US and EU Handle the Same Wire Differently

    My prompt:

    so, let’s assume my customer A is neither listed nor implicated by ownership and control sanctions. It’s my understanding, therefore, if he instructs me to transfer some funds to a sanctioned part, in the EU, I can refuse the instruction. However, in the US, I am obligated to take the funds and freeze them. Am I mistaken?

    Claude responded:

    You’re not mistaken about the pattern, but the accurate version of it hinges on which US list the counterparty is on, so let’s walk through both sides properly.

    EU: refuse, don’t freeze A’s funds

    This is the “making available” half of the earlier discussion. Customer A isn’t designated and the money is still A’s property, so it never meets Article 2(1)’s trigger (belonging to, owned, held, or controlled by a designated person). Executing A’s instruction would be the firm making resources available to the designated person, which Article 2(2) flatly prohibits absent a derogation. So the firm declines to execute, and A’s account is untouched, not frozen. There is one obligation people miss here: the Council’s Best Practices guidance is explicit that firms must report attempted transactions, including customer attempts to make funds or economic resources available to a designated person without authorization, to their national competent authority. So “refuse” is the transaction-level answer, but it comes bundled with a reporting duty, not a freeze.

    US: block, don’t reject, don’t return to A

    This is where the mechanics genuinely diverge, and the reason is definitional. OFAC’s blocking obligation attaches to property or interests in property that are within the United States or come within the possession or control of a U.S. person, and “interest” is defined expansively as an interest of any nature whatsoever, direct or indirect, present, future, or contingent. A designated person named as the intended beneficiary of a payment has exactly that kind of interest in the funds the moment the firm, a U.S. person, has possession or control of them for the purpose of completing the transfer, even though the money started out as A’s and A was never designated. OFAC’s own FAQ on this is unambiguous: once property is blocked, title remains with the blocked person, and the exercise of ownership powers is suspended absent OFAC authorization; the funds must be frozen, not seized, and reported. And the obligation to block, rather than reject, applies regardless of whether the designated person is the originator or the intended recipient of the funds. So the firm takes custody of A’s payment, places it in a blocked, interest-bearing account, files the initial blocked-property report within 10 business days under 31 CFR 501.603, and then includes it in the comprehensive Annual Report of Blocked Property due every September 30 for anything still blocked as of the prior June 30. The money does not go back to A.

    The contrast, side by side

    EU (Art. 2(1)/(2) template)US (OFAC blocking programs)
    TriggerResource already belongs to/owned/held/controlled by the designated personAny interest of any nature — including a contingent interest as intended beneficiary — once the property is within a U.S. person’s possession or control
    What happens to A’s fundsNothing; instruction is simply not executed, funds stay in A’s ordinary accountRemoved from A’s ordinary account and placed in a blocked, interest-bearing account; A no longer has free use of them
    OwnershipA retains full ownership throughoutTitle is treated as passing to/vesting in the blocked person once blocked
    ReportingAttempted “making available” reported to the national competent authorityInitial blocked-property report within 10 business days (31 CFR 501.603), then annual reporting each September 30 while still blocked

    Where this framing needs a caveat

    This only holds for a US counterparty that’s a blocked person, meaning someone on the SDN list or otherwise subject to OFAC’s blocking authority (including via the 50 percent rule). If the “sanctioned party” is instead someone subject only to OFAC’s narrower sectoral-style restrictions, such as the Sectoral Sanctions Identifications List under the Russia/Ukraine directives, there’s no blockable interest at all: OFAC’s own FAQ 36 example is exactly this case, an underlying dealing that’s prohibited but has no SDN or blocked-government interest in it, and the answer there is reject, or don’t process and return to the originator, reported under the separate rejected-transaction regime at 31 CFR 501.604. So the real dividing line isn’t “EU versus US” as such, it’s whether the applicable regime treats the counterparty as subject to a full asset freeze/blocking designation (EU Annex listing, OFAC SDN) or a narrower restriction on specific dealings (OFAC SSI, and arguably the EU’s own sectoral trade and financial restrictions on Russia that don’t run through personal designation). Matched apples to apples, both EU and OFAC would tell you to reject; it’s specifically the blocked-person case where OFAC’s answer flips to block while the EU’s stays at refuse.

    Self-check

    • OFAC FAQ 9 (blocking definition, title/possession language) and FAQ 36 (reject vs. block, with the Iran third-country example) pulled directly from ofac.treasury.gov.
    • 31 CFR 501.603 (blocked-property reports, 10-business-day initial report, September 30 annual report) and 501.604 (rejected-transaction reports) confirmed against Cornell/GovInfo CFR text and a recent OFAC annual-report reminder.
    • The “regardless of originator or recipient” framing and the broad “interest of any nature whatsoever” phrasing came from secondary sources (a law-firm compliance blog and a client alert) rather than a direct CFR pull of that exact clause — both are standard, uncontroversial restatements of OFAC’s general definitions section, but if citing the definition itself for publication, pull the exact text from the specific program’s CFR part (the phrasing is boilerplate but repeated part by part, e.g. 31 CFR 594.311, 515.312, etc., rather than centralized in one place).
    • The claim that a blocked person’s title is treated as attaching to an unexecuted, in-process payment is a synthesis of FAQ 9’s title language plus the broad interest definition, not something one source states in that combined form — flagged as inference, not a verified single-source claim.

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  • Burning Question: When are US sanctions changes binding?

    The prompt:

    Speak to the following: The Federal Register vs. the OFAC website: which one is legally operative, and what about time gaps between the two?

    The response:

    The Federal Register is legally operative for OFAC actions that require notice-and-publication; the OFAC website is not a legal instrument.

    The distinction turns on the type of action. For designations under most sanctions programs, OFAC’s legal authority to add a party to the SDN List derives from the underlying statute and executive order, and the designation becomes effective when the Director (or Secretary) signs the determination, not when it appears anywhere. OFAC then publishes the SDN List update on its website, typically the same day, and follows with a Federal Register notice, sometimes days or weeks later.

    For rules that carry legal force in their own right, the Federal Register is authoritative. Amendments to the sanctions regulations in Title 31 CFR, general licenses that OFAC chooses to codify, and formal rulemakings take legal effect on the date and terms stated in the Federal Register. The Federal Register text is the official version; if the website and the published notice ever diverged, the Federal Register controls.

    On the time gaps: the practical answer for compliance purposes is that OFAC treats a designation as effective from the moment of the action, and the SDN List posting on the website is the operational trigger the industry screens against. The Federal Register notice is a legal formality that documents the action and satisfies publication requirements, but the absence of a same-day Federal Register notice does not delay the legal effect of a designation. A party added to the SDN List on Tuesday is blocked as of Tuesday, even if the corresponding Federal Register notice does not run until the following week. The prohibition attaches to the U.S. person’s dealings with blocked property, and OFAC’s position is that the obligation exists once the property interest is blocked, independent of publication timing.

    Two nuances worth flagging. First, some due-process and constructive-notice questions have been litigated, and courts have generally accepted that public availability of the SDN List provides adequate notice, which is why the website posting matters practically even though it is not the legal instrument. Second, the effective date stated in a Federal Register notice may differ from the website posting date; where a specific legal deadline or wind-down period runs from an effective date, read that date from the Federal Register text rather than inferring it from when the website was updated.

    If you want, I can pull the specific statutory publication requirements (for example, the IEEPA and APA provisions and any program-specific notice language) to tighten the citations.

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  • Burning Questions; My Dinner with Claude – Freeze or Refuse? Decoding the EU’s Two-Limb Sanctions Template

    My prompt:

    EU sanctions say you can’t make economic resources available to a Designated Person. Does that mean you freeze the resources, or do you refuse the transaction? Show your work

    Claude responded:

    Neither, cleanly — and the question itself flags where people go wrong, because EU sanctions regulations don’t treat “freeze” and “make available” as two labels for the same act. They’re two separate obligations, and which one governs a given fact pattern turns on a single question: do you already have the resource in your possession, custody, or control, or would you be the one handing it over?

    The architecture

    Nearly every EU sanctions regulation runs the identical two-paragraph template. Regulation 36/2012 (Syria) is a clean illustration: Article 14(1) freezes all funds and economic resources belonging to, owned, held, or controlled by listed persons, while Article 14(2) separately prohibits making funds or economic resources available, directly or indirectly, to or for the benefit of those persons. The Council’s own compliance guidance confirms this isn’t a Syria quirk: financial restrictive measures under EU regulations consist of freezing the funds and economic resources of designated persons, plus a separate prohibition on making funds and economic resources available to them. Regulation 269/2014 (Russia/Ukraine) uses the same two-limb split at Article 2(1)-(2), just with different article numbering.

    Freeze applies to what’s already theirs and already in your hands

    “Freezing” is defined as a status, not a transaction. For funds, the operative CJEU language is that freezing prevents any move, transfer, alteration, use of, access to, or dealing with funds in any way that would change their volume, amount, location, ownership, possession, character, or destination — and a March 2026 CJEU ruling on Regulation 269/2014 reads that as applying absolutely and unconditionally, extending even to ancillary rights like voting attached to frozen securities. Economic resources get the parallel treatment: freezing prevents their use to obtain funds, goods, or services. Critically, freezing doesn’t change who owns the thing and doesn’t require you to divest yourself of it: financial restrictive measures do not involve a change in ownership of frozen funds and economic resources and are not punitive, and a person who already holds or controls a designated person’s funds or economic resources is not required to give them up or seek authorization merely to continue holding them. What requires authorization is any new dealing with them.

    Making available applies to what would newly become theirs

    This is where “refuse the transaction” comes in. The CJEU (Möllendorf, C-117/06) reads “making available” broadly: rather than a specific legal category of act, it covers whatever acts are necessary under the applicable national law for a person to obtain full power of disposal over the resource, and it applies regardless of whether adequate consideration is paid. There’s nothing to freeze here, because you’re not yet holding anything that belongs to the designated person — you’re holding your own funds, goods, or services and about to transfer disposal of them. So the compliance action isn’t a freezing decision, it’s a straight refusal: don’t complete the transaction absent a derogation from the competent authority.

    Why the same wire can trigger both obligations at once

    A frozen account receiving an incoming payment shows both rules operating on a single transaction from opposite sides. On the receiving end, a financial institution that receives funds transferred by a third party into a customer’s frozen account is permitted to credit those funds without prior authorization — Regulation 269/2014 builds this in explicitly, stating the making-available prohibition does not prevent crediting of frozen accounts by institutions that receive funds transferred by third parties onto a listed person’s account. But on the sending end, the remitting party needed authorization before initiating that transfer, because from their side, routing funds to a designated person’s account is exactly the act Article 2(2) prohibits. The receiving bank freezes (accepts the credit, then locks it down as part of the frozen balance); the remitter should have refused to send it in the first place.

    The trap worth flagging: indirect making available

    The refusal duty doesn’t stop at the listed name. Making resources available to a non-listed entity that is owned or controlled by a listed person is, in principle, treated as indirectly making them available to the listed person, unless a case-by-case assessment shows the resources won’t be used by or for that person’s benefit — this is the same ownership/control test (50%+ or the control indicators) that comes up again and again in this area.

    Self-check

    • Reg 36/2012 Art 14 and the Reg 269/2014 Art 2 language are confirmed against primary/near-primary text (Wikisource reproduction cross-checked against a March 2026 CJEU judgment quoting the operative articles directly).
    • The two-limb “freeze plus prohibition on making available” framing and the paragraph 30/44/57/59/68 content come from the Council’s July 2024 “EU Best Practices for the effective implementation of restrictive measures” (doc 11623/24) — non-binding Council guidance, not itself the law, and originally LIMITE-marked but retrievable from the public Consilium document register.
    • The CJEU case cited on “absolutely and unconditionally” (C-465/24, judgment of 12 March 2026) postdates my reliable knowledge and was pulled from a secondary reproduction (financialcrime.lu), not EUR-Lex/InfoCuria directly — worth a direct EUR-Lex pull before citing the CELEX number anywhere public.
    • Article numbering (2(1)-(2) vs. 14(1)-(2), etc.) varies by regulation even though the substantive template is uniform; derogation categories and exact definitions also live in each regulation’s own Article 1 and derogation articles, so don’t assume identical wording across regimes without checking.

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  • July 24, 2026: OFAC Update, Part 2: New Version of Russian GL, amended Russia and Venezuela FAQs, and final rule to update and correct CFR

    Today, OFAC issued Russian-related General License 131H:

    Russia_gl131HDownload

    and amended related Frequently Asked Questions 1224:

    1224. What negotiations does Russia-related General License 131H authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    On October 22, 2025, OFAC designated Public Joint-Stock Company Oil Company Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine. OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions. To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131H, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries. Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors. GL 131H expires on August 22, 2026.

    GL 131H does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset. Any contract entered into pursuant to GL 131H must expressly be made contingent upon the receipt of a separate authorization from OFAC. The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war.

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives. OFAC expects that, at a minimum, the proposed transaction must: completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps. Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131H at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: July 24, 2026

    Date Released

    November 19, 2025

    and 1225:

    1225. What activities do Russia-related General License 128C and General License 131Hauthorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”): GL 128C and GL 131H. The GLs are similar but have different expiration dates and terms as each serves a different purpose.

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation. OFAC subsequently issued GL 128C to extend the existing authorization until October 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities. OFAC subsequently issued GLs 131B, 131C, 131D, GL 131E, GL 131F, GL 131G, and GL 131H, to extend the existing authorization until August 22, 2026. Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.

    GL 128C and GL 131H expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128C and GL 131H. Transactions undertaken in the ordinary course of business may involve (but are not limited to): supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments. Also, both GL 128C and GL 131H authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.

    Both GL 128C and GL 131H also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128C and GL 131H. Similarly, non-U.S. persons may rely upon GL 128C and GL 131H regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128C and GL 131H, including the requirement that no payments may be transferred to any person or account located in the Russian Federation.

    Date Updated: July 24, 2026

    Date Released

    December 4, 2025

    as well as Venezuela FAQ 1239:

    1239. Where can I find the account information to make authorized payments to the Foreign Government Deposit Funds deposit account, as specified in Executive Order 14373?

    Answer

    To obtain payment account information for payments to the Foreign Government Deposit Funds deposit account established consistent with Executive Order (E.O.) 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” and referenced in certain Venezuela General Licenses, depositors must first email the official point of contact for the deposit account at: DepositorInquiries@state.gov. Potential depositors that fail to contact this email inbox and provide the requested transaction details may have their deposits rejected. Potential depositors should be prepared to provide all relevant transaction details, including the following, as appropriate:

    • Full legal names and addresses of corporate depositor and all contract parties (provide subsidiary information, as applicable);
    • Detailed description of the underlying contract or obligation, including the purpose and nature of the payment (include information on the type of product and amount purchased and/or sold);
    • Date of sale and copies of the corresponding invoice(s), contract number(s), and any relevant reference identifiers;
    • Total payment amount, currency, and proposed payment date(s);
    • Identification of the license authorizing the transaction;
    • Copies of any other transaction record(s) to validate the deposit; and
    • Primary point of contact for any follow-up questions, including name, title, telephone number, and email address.

    Once the Department of State has provided payment account information and the deposit has been made and accepted, the depositor will receive a confirmation email acknowledging the deposit, which can be used to inform all contract parties involved in the transaction.

    Date Updated: July 24, 2026

    Date Released

    March 4, 2026

    Finally, OFAC issued a new final rule:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adopting a final rule to update website and contact information in certain parts of the Code of Federal Regulations (CFR). Additionally, OFAC is amending one CFR part to update general licenses authorizing payments for legal services from funds originating outside the United States to replace the reporting requirement in the general license with a recordkeeping requirement and correcting typographical errors in two CFR parts. OFAC is also updating a part of 31 CFR chapter V to correct an erroneous cross-reference.

    Here’s the final rule:

    fr_Updating Website and Contact Information, and Authorizations for Payments for Legal ServicesDownload

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  • July 24, 2026: How to tell if you’re talking to OFSI (or not)

    Office of Financial Sanctions Implementation HM Treasury

    New guidance on verifying communications claiming to be from OFSI 

    OFSI has published new guidance on how to verify whether communications claiming to be from OFSI are genuine. 

    The guidance provides information to help individuals verify communications claiming to be from OFSI, including signs that a communication may not be genuine and sets out what to do if you are unsure. 

    The guidance:

    Check if an email or communication claiming to be from OFSI is genuine

    OFSI will never ask you to make a payment, transfer cryptocurrency, pay a fee to obtain a licence, or pay to release frozen funds. 

    1.  I’ve received a suspicious email or communication claiming to be from OFSI. What should I do? 

    If you receive a suspicious communication claiming to be from OFSI, HM Treasury or another government body: 

    • do not reply 
    • do not click any links or open attachments 
    • do not make any payments 
    • do not use the contact details they have provided 

    Instead, use the official contact details published on GOV.UK. If you’re unsure if a communication is genuine, contact OFSI directly at ofsi@hmtreasury.gov.ukimmediately. 

    2. How to check if an OFSI email or letter is genuine  

    Official OFSI emails are sent from: 

    Official UK government email addresses end in ‘gov.uk’. Always check the full email address carefully. 

    Scammers may use email addresses or display names that appear to come from a UK government department. 

    They may also use official-looking documents, branding, formatting or language to make communications appear genuine. A professional-looking email or letter does not mean it is authentic. 

    3. Does OFSI contact people by text message or WhatsApp? 

    No, OFSI will never contact you via: 

    • Text message  
    • WhatsApp 

    If you receive a message claiming to be from OFSI through these channels, you should treat it as suspicious.  

    4.  Signs an OFSI communication may be a scam 

    Be cautious if a communication claiming to be from OFSI: 

    • Asks you to pay a fee for an OFSI licence application. Applications for OFSI licences are made through the official GOV.UK website and there is no charge to apply for a licence   
    • Asks you to send or transfer money, cryptocurrency, or make a payment to unfreeze funds or release assets. OFSI does not require individuals to transfer money or cryptocurrency to obtain a licence, release frozen funds or assets, avoid enforcement action, or verify compliance with UK financial sanctions. Funds are frozen by relevant persons, such as banks, in accordance with UK sanctions legislation. Payment to OFSI, a bank or a third party will not unfreeze funds. 
    • Asks you to provide personal, banking or financial information. Genuine OFSI communications will not ask you to provide sensitive financial information or security credentials unexpectedly. If you are unsure whether a communication is genuine, contact OFSI directly using the contact details published on GOV.UK.  
    • Pressure you to make an immediate payment to avoid fines, penalties or other consequences. Communications that demand urgent payment or threaten enforcement action if you do not pay should be treated with caution. 

    5.  Report a scam or phishing email 

    If you believe you have received a scam or phishing email claiming to be from OFSI, you can report it to the National Cyber Security Centre.

    If you’ve been a victim of a scam, suffered financial loss or responded to a scam communication, report it to Report Fraud through their website or to Police Scotland by calling 101 if you live in Scotland.  

    You can report fraud to Report Fraud if you are in the UK, if the fraud occurred in the UK or if the fraud is related to the UK and the internet. Report Fraud also provides information on reporting fraud in a range of languages and guidance for people who may need support accessing its services. 

    If you live outside the UK, you can also report it to your local law enforcement agency or the relevant fraud reporting authority in your country.

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  • July 23, 2026: OFAC Update, Part 1: Lotsa Designations in lotsa programs, including Cuba, Narcotics and Terrorism

    Counter Terrorism Designations; Counter Narcotics Designations; Cuba Designations; Belarus-related Designation Removal; Issuance of Cuba-related General Licenses

    Additions:

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

    Treasury Press Release: Treasury Disrupts Muslim Brotherhood and Hamas Financial Networks

    State Press Release: Dismantling Muslim Brotherhood and Hamas Financial Networks

    OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594

    ALDEN, Khaldun Khamis Zakaria (Arabic: خلدون خمیس زكریا الدن)

    • Turkey
    • DOB: 19 Jul 1980
    • nationality: Palestinian
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • National ID No.: 905337655 (Palestinian)
    • Party Type: individual
    • Linked to: HAMAS

    Supplemental Information: Alden is the owner of Türkiye-based El-Kahira for General Trading (El-Kahira), which Treasury’s press release states has transferred hundreds of thousands of dollars for Hamas. He is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas.

    AL-JEBOURI, Abdulla Issam Ahmad (Arabic: عبد الله عصام أحمد الجبوري)

    • Turkey
    • DOB: 03 Oct 1988
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: B22037179 (Iraq) expires 11 Dec 2031
    • Party Type: individual
    • Linked to: EL-KAHIRA FOR GENERAL TRADING

    Supplemental Information: Abdullah Issam Ahmad Al-Jebouri is a shareholder of El-Kahira for General Trading. He is designated pursuant to E.O. 13224, as amended, for owning or controlling, directly or indirectly, El-Kahira for General Trading.

    AL-JEBOURI, Zaid Issam Ahmed (Arabic: زید عصام أحمد الجبوري)

    • Istanbul, Turkey
    • DOB: 03 Oct 1988
    • POB: Iraq
    • nationality: Iraq
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Digital Currency Address – TRX: TPyE2oSoaysrXfLzwf9wetBVr9JudLwjtD
    • alt. Digital Currency Address – TRX: TVgUsVzA7mpFExP4zS7HHbtKti6UuBDuwZ
    • alt. Digital Currency Address – TRX: TLoG3vbjDgqmTD5bM7w9rMgA6ysaNReuRy
    • alt. Digital Currency Address – TRX: TAhHpxPRwo1Bmm1A9m51uZ31tcB7EPq7SY
    • alt. Digital Currency Address – TRX: TScXZTbDjjZ6a6jiC7dZjgCqfNo4vm7atV
    • alt. Digital Currency Address – TRX: TGr2i8ZQiiMRjP3mWyQUH2MQBfKu8GJNqm
    • alt. Digital Currency Address – TRX: THJUJFyTnrBWb1ijWav7qfRBrjUuKgP49Z
    • Identification Number: 99909088080 (Turkey)
    • Party Type: individual
    • Linked to: EL-KAHIRA FOR GENERAL TRADING

    Supplemental Information: Zaid Issam Ahmed Al-Jebouri is a shareholder of El-Kahira for General Trading and, per Treasury’s press release, also provided underground banking services for a separate organized criminal group. He is designated pursuant to E.O. 13224, as amended, for owning or controlling, directly or indirectly, El-Kahira for General Trading.

    EL-ABIARY, Mahmoud

    • AKA: AL-IBIARY, Mahmoud
    • United Kingdom
    • DOB: 05 Jun 1952
    • nationality: Austria
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Passport: J0436609 (Austria) expires 08 May 2013
    • Party Type: individual
    • Linked to: EGYPTIAN MUSLIM BROTHERHOOD

    Supplemental Information: Mahmoud al-Abyari is a United Kingdom-based senior leader of the Egyptian Muslim Brotherhood (EMB), which OFAC designated as a Specially Designated Global Terrorist in January 2026. He is the Secretary General of the Muslim Brotherhood General Secretariat and has a long history of senior leadership roles within the Muslim Brotherhood. Treasury’s press release states he supported fundraising for the U.S.-designated Filistin Vakfi and Hayat Yolu, both previously sanctioned for their ties to Hamas, and worked with Muslim Brotherhood groups to support and provide financial assistance to Hamas. He is designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the Egyptian Muslim Brotherhood.

    Treasury Press Release: Treasury Takes Largest Action Ever Targeting Cartel de Jalisco Nueva Generacion

    State Press Release: Sanctioning Over 50 Targets Linked to Cártel de Jalisco Nueva Generación

    • OFAC Programs:
      • [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
      • [ILLICIT-DRUGS-EO14059] Executive Order 14059

    ALVARADO RODRIGUEZ, Martha Alicia

    • Tequila, Jalisco, Mexico
    • DOB: 02 Jan 1989
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: AARM890102MJCLDR02 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Alvarado is a CJNG member and the wife of fellow designee Roberto Jimenez Arias; the two jointly control crop production company Agropecuaria Amateq Del Valle S.A. de C.V., also designated today. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    AYALA BOTELLO, Miguel Angel

    • Mexico
    • DOB: 09 Aug 1978
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: AABM780809HMNYTG02 (Mexico)
    • Party Type: individual
    • Linked to: BOTELLO ROZALEZ, Gerardo

    Supplemental Information: Ayala Botello (Miguel Botello) is a cousin of Gerardo Botello Rozalez (El Cachas) with a leadership role in Bubux Baby Shoes S.A. de C.V. and additional entities linked to El Cachas’s family members. While El Cachas oversaw CJNG operations in Michoacan, Miguel Botello served as Director of the Public Safety Directorate of Tepalcatepec, Michoacan; fellow designees Gustavo and Wiliams Botello Rodriguez went on to become municipal police officers in Tepalcatepec under him. He is designated pursuant to E.O. 14059 for having provided, or attempted to provide, support to Gerardo Botello Rozalez, and pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided support to Gerardo Botello Rozalez.

    BOTELLO ORTIZ, Edgar Gerardo

    • Mexico
    • DOB: 04 Apr 1994
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BOOE940404HMNTRD00 (Mexico)
    • Party Type: individual
    • Linked to: GREEN AGROPACIFIC S.P.R. DE R.L. DE C.V.

    Supplemental Information: A son of Gerardo Botello Rozalez (El Cachas), Edgar Gerardo Botello Ortiz serves as Treasurer of the Board of Directors of Green Agropacific and is a partial owner of the company. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Green Agropacific S.P.R. de R.L. de C.V.

    BOTELLO ORTIZ, Jesus David

    • Mexico
    • DOB: 28 Jun 1997
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BOOJ970628HMNTRS00 (Mexico)
    • Party Type: individual
    • Linked to: GREEN AGROPACIFIC S.P.R. DE R.L. DE C.V.

    Supplemental Information: A son of El Cachas, Jesus David Botello Ortiz serves as Secretary of the Board of Directors of Green Agropacific and is a partial owner of the company. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Green Agropacific S.P.R. de R.L. de C.V.

    BOTELLO ORTIZ, Ricardo

    • Mexico
    • DOB: 24 Apr 1999
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BOOR990424HMNTRC08 (Mexico)
    • Party Type: individual
    • Linked to: RANCHO SAN MIGUEL LOS TRES HERMANOS S.P.R. DE R.L. DE C.V.

    Supplemental Information: Another son of El Cachas, Ricardo Botello Ortiz is Treasurer of the Board of Directors of Rancho San Miguel and, per Treasury’s press release, is also a partial owner of Green Agropacific. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Rancho San Miguel Los Tres Hermanos S.P.R. de R.L. de C.V.

    BOTELLO RODRIGUEZ, Gustavo

    • AKA:
      • “Tavo”
      • “Viejon”
    • Mexico
    • DOB: 20 Jan 1993
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BORG930120HMNTDS06 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: A nephew of El Cachas, Gustavo Botello operated a CJNG cell tied to huachicol (fuel theft) together with his brother Wiliams Geovanni Botello Rodriguez. He was arrested by the Government of Mexico in September 2025 on drug trafficking charges, and had previously become a municipal police officer in Tepalcatepec under Miguel Botello. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    BOTELLO RODRIGUEZ, Wiliams Geovanni

    • Mexico
    • DOB: 02 Mar 1995
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BORW950302HMNTDL09 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: El Cachas’s nephew and Gustavo Botello’s brother, Wiliams Botello operated the same fuel-theft-linked CJNG cell and also became a municipal police officer in Tepalcatepec under Miguel Botello. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    BOTELLO ROZALEZ, Gerardo

    • AKA:
      • BOTELLO ROSALES, Gerardo
      • “El Cachas”
    • Jalisco, Mexico
    • DOB: 03 Feb 1977
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: BORG770203HMNTZR05 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: El Cachas is a senior, long-standing CJNG member arrested in 2018 by the Government of Mexico while serving as bodyguard to the wife of CJNG’s longtime leader; Treasury’s press release notes he was publicly linked while in custody to the sexual abuse of female prison guards. Before, during, and after his 2018 imprisonment in Jalisco, he oversaw CJNG operations across multiple Mexican territories, and has most recently been linked to the Izaguirre Ranch training center, where CJNG recruited members through coercive means. His criminal activities have also included huachicol (fuel theft). He is a registered owner of Bubux Baby Shoes S.A. de C.V., also designated today. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    CASTELLANOS CEJA, Julio Cesar

    • Colima, Colima, Mexico
    • DOB: 18 Feb 1991
    • POB: Colima, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: CACJ910218HCMSJL08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Castellanos Ceja is one of seven individuals Treasury identifies as part of a professional cartel money-laundering network based in Zapopan and Guadalajara, Jalisco, which since at least 2023 has coordinated the collection of bulk cash narcotics proceeds from multiple U.S. cities, transferred the funds back to Mexico, and returned the money to CJNG’s leadership while taking a fee, laundering tens of millions of dollars per year. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    CISNEROS TAPIA, Liliana

    • Mexico
    • DOB: 09 Nov 1980
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: CITL801109MMNSPL07 (Mexico)
    • Party Type: individual
    • Linked to: GREEN AGROPACIFIC S.P.R. DE R.L. DE C.V.

    Supplemental Information: El Cachas’s most recent spouse, Cisneros Tapia is Secretary of Green Agropacific’s oversight body and a partial owner of the company. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Green Agropacific S.P.R. de R.L. de C.V.

    CORONA PIMENTEL, Efrain

    • Mexico
    • DOB: 15 Apr 1994
    • POB: Colima, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: COPE940415HCMRMF01 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Treasury identifies Corona Pimentel as an additional CJNG associate of Audias Flores Silva (Jardinero). He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    CRUZ CABRERA, Jorge Fernando

    • Zapopan, Jalisco, Mexico
    • DOB: 23 Jun 1993
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: CUCJ930623HJCRBR03 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Cruz Cabrera is a member of the Zapopan/Guadalajara-based professional money-laundering network described above. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    DIAZ ROBLES, Marcial Apolinar

    • AKA: “ROBLES, Polo”
    • Guadalajara, Jalisco, Mexico
    • DOB: 26 Aug 1988
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: DIRM880826HJCZBR05 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Marcial Apolinar Diaz Robles and his twin brother Pedro Marcial Diaz Robles lead a CJNG-linked cocaine trafficking network from Guadalajara. Treasury’s press release states the twins have a very close relationship with several members of CJNG’s inner circle and have used those connections to facilitate large shipments of cocaine and other narcotics from South America to Mexico and onward to the United States and Europe. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    DIAZ ROBLES, Pedro Marcial

    • AKA: “ROBLES, Peter”
    • Guadalajara, Jalisco, Mexico
    • DOB: 26 Aug 1988
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: DIRP880826HJCZBD00 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Pedro Marcial Diaz Robles is Marcial Apolinar Diaz Robles’s twin and co-leader of the same Guadalajara-based cocaine trafficking network described above. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    DOMINGUEZ AGUILERA, Joana

    • Mexico
    • DOB: 22 Oct 1981
    • POB: Tamaulipas, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: DOAJ811022MTSMGN08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Treasury identifies Dominguez Aguilera as a CJNG member and additional associate of Jardinero. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    GARCIA MARTINEZ, Jose Octaviano

    • Mexico
    • DOB: 29 May 1987
    • POB: Tamaulipas, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: GAMO870529HTSRRC08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Garcia Martinez is a plaza boss subordinate to Jardinero for Florencia, Zacatecas. Treasury states that plaza bosses in this network produce large quantities of fentanyl, cocaine, and methamphetamine in clandestine laboratories in Jalisco and Zacatecas and operate extensive distribution networks transporting narcotics to U.S. cities. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    GONZALEZ RAMIREZ, Francisco Noe

    • AKA: “El F1”
    • Mexico
    • DOB: 05 Feb 1981
    • POB: Aguascalientes, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: GORF810205HASNMR05 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: El F1 is a high-ranking CJNG member Treasury describes as engaged in drug trafficking, kidnapping, extortion, and violence in Zacatecas. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    GONZALEZ, Juan Carlos

    • AKA:
      • VALENCIA GONZALEZ, Juan Carlos
      • “Pelon”
    • Mexico
    • 24892 Three Springs Rd, Hemet, CA 92545, United States
    • DOB: 12 Sep 1984
    • POB: Santa Ana, California, United States
    • nationality: Mexico
    • alt. nationality: United States
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: GOXJ840912HNENXN06 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Pelon is the new leader of CJNG, a dual Mexican-U.S. national who rose to the position following the February 2026 death of his stepfather, CJNG founder Ruben Oseguera Cervantes (El Mencho), during a Mexican government operation. Pelon is charged in a U.S. federal drug trafficking indictment filed in the U.S. District Court for the District of Columbia, and the State Department’s Narcotics Rewards Program is offering up to $5 million for information leading to his arrest and/or conviction. Prior to his current position, he led an armed wing of CJNG that engaged in significant violence. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    GUTIERREZ VALDEZ, Jose Jesus

    • Ixtlan Del Rio, Nayarit, Mexico
    • DOB: 28 Aug 1979
    • POB: Zacatecas, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: GUVJ790828HZSTLS18 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Gutierrez Valdez oversees several methamphetamine laboratories in Zacatecas and controls furniture company Productores Vagu S.A. de C.V., also designated today. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    HERNANDEZ MORALES, Uriel

    • Mexico
    • DOB: 02 Aug 1988
    • POB: Chiapas, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: HEMU880802HCSRRR07 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Hernandez Morales is another of the plaza bosses subordinate to Jardinero described above, tied to fentanyl, cocaine, and methamphetamine production and distribution. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    JIMENEZ ARIAS, Roberto

    • Amatitan, Jalisco, Mexico
    • DOB: 26 Oct 1988
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: JIAR881026HJCMRB04 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Jimenez operates beverage crop producer Casa Tequilera El Origen Del Tequila S.A. de C.V. and construction company Hurrari Kash S.A. Promotora de Inversion de C.V., both designated today, and jointly controls crop producer Agropecuaria Amateq Del Valle S.A. de C.V. with his wife, fellow designee Martha Alicia Alvarado Rodriguez. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    LEDEZMA RAMIREZ, Feliciano

    • AKA: “Chano Limones”
    • Mexico
    • DOB: 20 Oct 1981
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: LERF811020HMNDML00 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Chano Limones traffics fentanyl to the United States and has also been involved in significant violence in the Nuevo Italia and Mugica areas of Michoacan. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    LOPEZ LARIOS, Angel Gabriel

    • Mexico
    • DOB: 01 Nov 1992
    • POB: Nayarit, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: LOLA921101HNTPRN09 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Treasury identifies Lopez Larios as an additional CJNG associate of Jardinero. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    LOZA GARCIA, Rodolfo Alejandro

    • AKA: “El 26”
    • Villas Las Alvarez, Colima, Mexico
    • DOB: 11 Jun 1983
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: LOGR830611HJCZRD03 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: El 26 is a senior CJNG narcotics trafficker and enforcement member Treasury describes as engaged in significant violence on behalf of CJNG in northern Jalisco. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    MEDINA CHAVIRA, Adolfo Gabriel

    • Zapopan, Jalisco, Mexico
    • DOB: 17 Mar 1974
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MECA740317HJCDHD05 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Medina Chavira is a member of the Zapopan/Guadalajara-based professional money-laundering network and separately controls Mundo Fit Suplementos S.A. de C.V. and Medin Products, both designated today. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    MEDINA FLORES, Areli Isis

    • Mexico
    • DOB: 18 Apr 1985
    • POB: Mexico, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MEFA850418MMCDLR08 (Mexico)
    • Party Type: individual
    • Linked to: FLORES SILVA, Audias

    Supplemental Information: Medina Flores is Jardinero’s cousin; together with Gabriel Serrano Magana, she helps Jardinero maintain control of gas station company Petrocoda S.A. de C.V., and she co-owns wholesale clothing company Stella Servicios Comerciales Y Empresariales S.A. de C.V. with Karely Lizbeth Ramirez Banales. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Audias Flores Silva.

    MENA ALVARADO, Alma Laura

    • Mexico
    • DOB: 27 Dec 1983
    • POB: Zacatecas, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MEAA831227MZSNLL04 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Mena, together with her husband Jose Mora Leon, owns a logistics company engaged in diverting liquid fentanyl to CJNG, and Treasury states she is separately engaged in extracting and stealing gasoline in a CJNG-controlled area. She and Mora control Strong Energy S.A. de C.V. and Transic Logistic S.A. de C.V., both designated today. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    MENDOZA GARCIA, Luis Mario

    • Zapopan, Jalisco, Mexico
    • DOB: 05 May 1999
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MEGL990505HJCNRS07 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Mendoza Garcia is a member of the Zapopan/Guadalajara-based professional money-laundering network described above. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    MORA LEON, Jose

    • Mexico
    • DOB: 03 Feb 1978
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MOLJ780203HMNRNS00 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Mora, husband of Alma Laura Mena Alvarado, jointly owns with her the logistics company engaged in diverting liquid fentanyl to CJNG, and the couple control Strong Energy S.A. de C.V. and Transic Logistic S.A. de C.V. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    MORENO LOPEZ, Fidel Damian

    • Magdalena, Jalisco, Mexico
    • DOB: 12 Apr 1984
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: MOLF840412HJCRPD08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Treasury identifies Moreno Lopez as an additional CJNG associate of Jardinero. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    RAMIREZ BANALES, Karely Lizbeth

    • AKA: BANUELOS RAMIREZ, Kareli Lizbeth
    • Mexico
    • DOB: 19 May 1996
    • POB: Nayarit, Mexico
    • nationality: Mexico
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • R.F.C.: RABK9605191P7 (Mexico)
    • C.U.R.P.: RABK960519MNTMXR03 (Mexico)
    • Party Type: individual
    • Linked to: FLORES SILVA, Audias

    Supplemental Information: Jardinero’s wife, Ramirez Banales owns beverage store El Almacen Licoreria, also designated today, and co-owns wholesale clothing company Stella Servicios Comerciales Y Empresariales S.A. de C.V. with Areli Isis Medina Flores. She is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Audias Flores Silva.

    RIVERA ZEPEDA, Cuauhtemoc

    • Mexico
    • DOB: 17 Aug 1989
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: RIZC890817HJCVPH08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Rivera Zepeda is another of the plaza bosses subordinate to Jardinero tied to fentanyl, cocaine, and methamphetamine production and distribution networks reaching U.S. cities. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    RODRIGUEZ FLORES, Salvador Israel

    • Zapopan, Jalisco, Mexico
    • DOB: 04 May 1992
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: ROFS920504HJCDLL00 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Rodriguez Flores is a member of the Zapopan/Guadalajara-based professional money-laundering network described above. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    RUIZ BANUELOS, Jose Guadalupe

    • AKA: “Venado”
    • Mexico
    • DOB: 14 Jul 1975
    • POB: Nayarit, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: RUBG750714HNTZXD05 (Mexico)
    • Party Type: individual
    • Linked to: FLORES SILVA, Audias

    Supplemental Information: Venado is Jardinero’s trusted pilot, who Treasury states has utilized clandestine landing strips across Nayarit. He is designated pursuant to E.O. 14059 for having provided support to Audias Flores Silva, and pursuant to E.O. 13224, as amended, for having materially assisted Audias Flores Silva.

    SANCHEZ TAMAYO, Hugo Alejandro

    • Tlaquepaque, Jalisco, Mexico
    • DOB: 06 Jul 1969
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: SATH690706HJCNMG09 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Sanchez Tamayo is a member of the Zapopan/Guadalajara-based professional money-laundering network described above. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    SERRANO MAGANA, Gabriel

    • Mexico
    • DOB: 21 Aug 1986
    • POB: Michoacan, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: SEMG860821HMNRGB06 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Serrano Magana is a subordinate of Jardinero who, together with Areli Isis Medina Flores, helps Jardinero maintain control of gas station company Petrocoda S.A. de C.V. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    VILLA SANCHEZ, Jorge

    • Guadalajara, Jalisco, Mexico
    • DOB: 20 Jul 1970
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: VISJ700720HJCLNR02 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Villa Sanchez is a member of the Zapopan/Guadalajara-based professional money-laundering network described above. He is designated pursuant to E.O. 14059 for having provided support to CJNG, and pursuant to E.O. 13224, as amended, for having materially assisted CJNG.

    VILLASENOR OLIVARES, Cesar Alejandro

    • AKA: “El Guero Conta”
    • Mexico
    • DOB: 03 Dec 1980
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: VIOC801203HJCLLS08 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: El Guero Conta was, along with Jardinero, arrested by Mexican authorities in April 2026. Treasury states he is responsible for overseeing Jardinero’s network of front companies, individuals, and family members designed to conceal Jardinero’s interest in assets initially obtained with illicit proceeds. He is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, CJNG.

    ZEPEDA RODRIGUEZ, Jorge

    • AKA: “ZEPEDA, George”
    • Marroquin de Abajo, Guanajuato, Mexico
    • DOB: 18 Jan 1967
    • POB: Jalisco, Mexico
    • nationality: Mexico
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • C.U.R.P.: ZERJ670118HJCPDR06 (Mexico)
    • Party Type: individual
    • Linked to:
      • DIAZ ROBLES, Marcial Apolinar
      • DIAZ ROBLES, Pedro Marcial

    Supplemental Information: Zepeda is a Guadalajara-based businessman, money launderer, and cocaine broker heavily involved in the Diaz Robles twins’ drug trafficking operations; Treasury states he paid the twins millions of dollars for access and connections to various Mexican ports and worked with them to smuggle cocaine to the United States and globally. He controls Optic Private Transportation S.A. de C.V., also designated today. He is designated pursuant to E.O. 14059 for having provided support to Marcial Apolinar Diaz Robles and Pedro Marcial Diaz Robles, and pursuant to E.O. 13224, as amended, for having materially assisted them.

    State Press Release: Additional Sanctions Designations Targeting the Corrupt Cuban Communist Regime and Its Financial Backers

    OFAC Program: [CUBA-EO14404] Executive Order 14404

    PORTAL MIRANDA, Jose Angel

    • Havana, Cuba
    • DOB: 10 Jan 1967
    • POB: Cuba
    • nationality: Cuba
    • Gender: Male
    • National ID No.: 67011009482 (Cuba)
    • Party Type: individual

    Supplemental Information: Publicly available information identifies a Jose Angel Portal Miranda as Cuba’s Minister of Public Health since July 2018, the ministry that oversees Cuba’s overseas medical brigade program. Secretary Rubio’s press statement describes today’s action as designating, among other things, two individuals responsible for the exploitation and forced labor of Cuban medical workers through the regime’s overseas medical brigades, pursuant to E.O. 14404.

    SANCHEZ PADRON, Gretza

    • Villa Clara, Cuba
    • DOB: 28 Nov 1970
    • POB: Villa Clara, Cuba
    • nationality: Cuba
    • Gender: Female
    • National ID No.: 70112814739 (Cuba)
    • Party Type: individual
    • Linked to: UNIDAD CENTRAL DE COOPERACION MEDICA

    Supplemental Information: Sanchez Padron is linked to Unidad Central de Cooperacion Medica, also designated today, which administers Cuba’s overseas medical-brigade program. She appears to be the second of the two individuals Secretary Rubio’s press statement describes as designated for responsibility in the exploitation and forced labor of Cuban medical workers through the regime’s overseas medical brigades, pursuant to E.O. 14404.

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

    Treasury Press Release: Treasury Disrupts Muslim Brotherhood and Hamas Financial Networks

    State Press Release: Dismantling Muslim Brotherhood and Hamas Financial Networks

    OFAC Program: [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594

    EL-KAHIRA FOR GENERAL TRADING (Arabic: شركة القاھرة للتجارة العامة)

    • AKA:
      • DUBAI COMPANY FOR EXCHANGE
      • ELKAHIRA TICARET EMLAKCILIK DOMESTIC AND FOREIGN TRADE LIMITED COMPANY
      • PRIMATECH
      • PRIMATECH TEKNOLOJI SANAYI (Latin: PRİMATECH TEKNOLOJİ SANAYİ)
      • PRIMATECH TEKNOLOJII SANAYI IC VE DIS TICARET LIMITTED SIRKETI AND FOREIGN TRADE LIMITED COMPANY (Latin: PRİMATECH TEKNOLOJİ SANAYİ İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ)
      • “EL-KAHIRA EXCHANGE OFFICE” (Arabic: “مكتب القاھرة للصرافة”)
    • Baris Mah. Belediye CD., No: 28/12, Beylikduzu, Istanbul, Turkey
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 25 Jun 2019
    • alt. Organization Established Date: 2022
    • Trade License No.: 197146-5 (Turkey)
    • Chamber of Commerce Number: 1186929 (Turkey)
    • Linked to: HAMAS

    Supplemental Information: Treasury’s press release states that Türkiye-based El-Kahira has transferred hundreds of thousands of dollars for Hamas, and that it provided underground banking services, servicing both fiat currency and cryptocurrencies, to known Sweden-based organized crime groups such as the Foxtrot Network. It is owned by fellow designee Khaldun Khamis Zakaria Alden, with Zaid Issam Ahmed Al-Jebouri and Abdulla Issam Ahmad Al-Jebouri as shareholders. It is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas.

    MADAD PALESTINE CHARITABLE SOCIETY (Arabic: جمعیة مداد فلسطین الخیریة)

    • AKA:
      • MADAD AI-KHAIR
      • MADDAD FALASTIN
      • MADDAD FOUNDATION
      • MIDAD ALKHAIR
      • MIDAD PALESTINE CHARITABLE ASSOCIATION
      • SUPPLY PALESTINE CHARITABLE SOCIETY
    • Gaza
    • Website: https://midad-alkhair.com
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 2014
    • Target Type: Charity or Nonprofit Organization
    • Chamber of Commerce Number: 8441 (Palestinian)
    • Linked to: HAMAS

    Supplemental Information: Treasury’s press release describes Madad Palestine Charitable Society as a Gaza-based front created by Hamas to raise funds for its military wing; funds were reportedly collected for the benefit of civilians but were instead knowingly diverted by Hamas for military purposes. It is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas.

    TUJUH BULIR GLOBAL (Arabic: السبع السجلات العالمیة)

    • AKA:
      • SEVEN SPIKES GLOBAL
      • SEVEN SPIKES GLOBAL FOUNDATION
    • Ruka SOHO, Blok H No. 9, Jalan Muhammad Kahfi II, RT 008/RW 010, Kelurahan Jagakarsa, Kecamatan Jagakarsa, Jakarta Selatan, DKI Jakarta, Indonesia
    • Website: https://tujuhbulir.com
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 2025
    • Organization Type: Other human health activities
    • Linked to: HAMAS

    Supplemental Information: Operating under the alias Seven Spikes Global, this Indonesia-based entity was, per Treasury’s press release, created by Hamas to fundraise and provide revenue for its military wing. It is designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas.

    Treasury Press Release: Treasury Takes Largest Action Ever Targeting Cartel de Jalisco Nueva Generacion

    State Press Release: Sanctioning Over 50 Targets Linked to Cártel de Jalisco Nueva Generación

    • OFAC Programs:
      • [SDGT] Global Terrorism Sanctions Regulations, 31 C.F.R. part 594
      • [ILLICIT-DRUGS-EO14059] Executive Order 14059

    AGROPECUARIA AMATEQ DEL VALLE S.A. DE C.V.

    • Tequila, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 26 Aug 2021
    • Organization Type: Support activities for crop production
    • Folio Mercantil No.: N-2021076329 (Mexico)
    • Linked to:
      • JIMENEZ ARIAS, Roberto
      • ALVARADO RODRIGUEZ, Martha Alicia

    Supplemental Information: This Jalisco crop-production company is jointly controlled by Roberto Jimenez Arias and his wife, Martha Alicia Alvarado Rodriguez. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Jimenez and Alvarado.

    BUBUX BABY SHOES S.A. DE C.V.

    • San Francisco del Rincon, Guanajuato, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 Apr 2014
    • Organization Type: Retail sale of clothing, footwear and leather articles in specialized stores
    • Folio Mercantil No.: 4439 (Mexico)
    • Linked to: BOTELLO ROZALEZ, Gerardo

    Supplemental Information: Bubux purports to sell baby shoes and is registered to El Cachas, whose cousin Miguel Angel Ayala Botello holds a leadership role in the company. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Gerardo Botello Rozalez.

    CASA TEQUILERA EL ORIGEN DEL TEQUILA S.A. DE C.V.

    • Amatitan, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 Nov 2022
    • Organization Type: Growing of beverage crops
    • Folio Mercantil No.: N-2022080980 (Mexico)
    • Linked to: JIMENEZ ARIAS, Roberto

    Supplemental Information: This beverage-crop producer is operated by Roberto Jimenez Arias. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Jimenez.

    CORPORATIVO DE SEGURIDAD PRIVADA ALFA Y GAMA S.A. DE C.V.

    • Morelia, Michoacan, Mexico
    • Zapopan, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 29 Nov 2018
    • Organization Type: Private security activities
    • R.F.C.: CSP1811293I5 (Mexico)
    • Folio Mercantil No.: 2020051100 (Mexico)
    • License: 1006097025 (Mexico)
    • Linked to: AYALA BOTELLO, Miguel Angel

    Supplemental Information: This Michoacan- and Jalisco-based private security company maintains a state-level license to carry firearms. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Miguel Angel Ayala Botello.

    EL ALMACEN LICORERIA

    • Ixtlan del Rio, Nayarit, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 01 Apr 2021
    • Organization Type: Retail sale of food in specialized stores
    • R.F.C.: RABK9605191P7 (Mexico)
    • Linked to: RAMIREZ BANALES, Karely Lizbeth

    Supplemental Information: This beverage store is owned by Jardinero’s wife, Karely Lizbeth Ramirez Banales. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Ramirez Banales.

    GREEN AGROPACIFIC S.P.R. DE R.L. DE C.V.

    • Tepic, Nayarit, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 30 Jun 2023
    • Organization Type: Growing of beverage crops
    • Folio Mercantil No.: 2023064007 (Mexico)
    • Linked to: AYALA BOTELLO, Miguel Angel

    Supplemental Information: This Nayarit-based beverage-crop company is partly owned by El Cachas’s most recent spouse, Liliana Cisneros Tapia, and two of his sons, Jesus David and Edgar Gerardo Botello Ortiz, who respectively serve as Secretary of its oversight body and Secretary/Treasurer of its Board of Directors. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Miguel Angel Ayala Botello.

    HURRARI KASH S.A. PROMOTORA DE INVERSION DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 Sep 2024
    • Organization Type: Construction of buildings
    • Folio Mercantil No.: N-2025015902 (Mexico)
    • Linked to: JIMENEZ ARIAS, Roberto

    Supplemental Information: This construction company is operated by Roberto Jimenez Arias. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Jimenez.

    MEDIN PRODUCTS

    • AKA: MEDIN PRODUCTS S.A.S.
    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 25 Jul 2022
    • Organization Type: Retail sale of food in specialized stores
    • Company Number: SAS2022523655 (Mexico)
    • Linked to: MEDINA CHAVIRA, Adolfo Gabriel

    Supplemental Information: Controlled by money launderer Adolfo Gabriel Medina Chavira, this entity is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Medina Chavira.

    MUNDO FIT SUPLEMENTOS S.A. DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 27 Sep 2022
    • Organization Type: Manufacture of medical and dental instruments and supplies
    • Folio Mercantil No.: N-2022069078 (Mexico)
    • Linked to: MEDINA CHAVIRA, Adolfo Gabriel

    Supplemental Information: A second entity controlled by Adolfo Gabriel Medina Chavira, it is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Medina Chavira.

    OPTIC PRIVATE TRANSPORTATION S.A. DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 26 Aug 2015
    • Organization Type: Activities of holding companies
    • Folio Mercantil No.: 91490 (Mexico)
    • Linked to: ZEPEDA RODRIGUEZ, Jorge

    Supplemental Information: This holding company is controlled by money launderer and cocaine broker Jorge Zepeda Rodriguez. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Zepeda Rodriguez.

    PETROCODA S.A. DE C.V.

    • Ziracuaretiro, Michoacan, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 Feb 2016
    • Organization Type: Retail sale of automotive fuel in specialized stores
    • R.F.C.: PET160218N40 (Mexico)
    • Folio Mercantil No.: 15149 (Mexico)
    • Linked to: FLORES SILVA, Audias

    Supplemental Information: This gas station company is one of the vehicles Jardinero uses to hold cartel-linked assets; Treasury states he maintains control of it through his cousin Areli Isis Medina Flores and subordinate Gabriel Serrano Magana. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Audias Flores Silva.

    PRODUCTORES VAGU S.A. DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 29 Jun 2015
    • Organization Type: Manufacture of furniture
    • Folio Mercantil No.: 90943 (Mexico)
    • Linked to: GUTIERREZ VALDEZ, Jose Jesus

    Supplemental Information: This furniture manufacturer is controlled by Jose Jesus Gutierrez Valdez, who Treasury states oversees several methamphetamine laboratories in Zacatecas. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Gutierrez Valdez.

    RANCHO SAN MIGUEL LOS TRES HERMANOS S.P.R. DE R.L. DE C.V.

    • Zapotlan El Grande, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 02 Aug 2019
    • Organization Type: Manufacture of other food products n.e.c.
    • Folio Mercantil No.: 2019070393 (Mexico)
    • Linked to: AYALA BOTELLO, Miguel Angel

    Supplemental Information: This Jalisco tequila and agave company’s Board of Directors includes El Cachas’s son Ricardo Botello Ortiz as Treasurer. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Miguel Angel Ayala Botello.

    STELLA SERVICIOS COMERCIALES Y EMPRESARIALES S.A. DE C.V.

    • Ahuacatlan, Nayarit, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 13 Mar 2019
    • Organization Type: Retail sale of textiles in specialized stores
    • R.F.C.: SSC190313CY6 (Mexico)
    • Folio Mercantil No.: N-2019021848 (Mexico)
    • Linked to:
      • RAMIREZ BANALES, Karely Lizbeth
      • MEDINA FLORES, Areli Isis

    Supplemental Information: This wholesale clothing company is co-owned by Jardinero’s wife, Karely Lizbeth Ramirez Banales, and his cousin, Areli Isis Medina Flores. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Medina Flores and Ramirez Banales.

    STRONG ENERGY S.A. DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 09 May 2017
    • Organization Type: Support activities for petroleum and natural gas extraction
    • R.F.C.: SEN170509R53 (Mexico)
    • Folio Mercantil No.: N-2017038887 (Mexico)
    • Linked to:
      • MORA LEON, Jose
      • MENA ALVARADO, Alma Laura

    Supplemental Information: Controlled by spouses Jose Mora Leon and Alma Laura Mena Alvarado, this petroleum and natural gas extraction support company is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mena and Mora.

    TRANSIC LOGISTIC S.A. DE C.V.

    • Guadalajara, Jalisco, Mexico
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 05 Oct 2020
    • Organization Type: Transportation and storage
    • Folio Mercantil No.: N-2020078956 (Mexico)
    • Linked to:
      • MORA LEON, Jose
      • MENA ALVARADO, Alma Laura

    Supplemental Information: The logistics company Treasury states is engaged in diverting liquid fentanyl to CJNG, controlled by Jose Mora Leon and Alma Laura Mena Alvarado. It is designated pursuant to E.O. 14059 and E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mena and Mora.

    State Press Release: Additional Sanctions Designations Targeting the Corrupt Cuban Communist Regime and Its Financial Backers

    OFAC Program: [CUBA-EO14404] Executive Order 14404

    CEIBA INVESTMENTS LIMITED

    • Les Echelons Court, Les Echelons, St. Peter Port, Channel Islands GY1 1AR, Guernsey
    • Organization Established Date: 10 Oct 1995
    • Organization Type: Trusts, funds and similar financial entities
    • Legal Entity Number: 213800XGY151JV5B1E88
    • Registration Number: 30083 (Guernsey)

    Supplemental Information: Secretary Rubio’s press statement describes today’s Cuba-related action as including four entities associated with sanctions evasion efforts linked to U.S.-designated Grupo de Administración Empresarial S.A. (GAESA), Cuba’s military-run business conglomerate, without naming each individually. Note that OFAC is separately issuing Cuba General Licenses 2 and 3, both captioned as authorizing wind-down and debt/equity transactions involving CEIBA Investments Limited specifically — a strong indication this entity is among the four, though this is an inference on our part rather than a statement made explicitly in either press release.

    CENTRO DE INVESTIGACIONES DEL PETROLEO S.A.

    • AKA: “CEINPET”
    • Cerro, Cuba
    • Organization Established Date: 02 Jun 2020
    • Target Type: State-Owned Enterprise
    • Entity Code: 14774 (Cuba)

    Supplemental Information: CEINPET’s petroleum-research profile places it, in our reading, among the three entities Secretary Rubio’s statement describes as operating in Cuba’s energy sector, though the statement does not name the three individually.

    COMERCIALIZADORA DE SERVICIOS MEDICOS CUBANOS SA

    • AKA:
      • “CSMC”
      • “CUBAN MEDICAL SERVICES MARKETING COMPANY”
      • “SERVICIOS MEDICOS CUBANOS”
      • “SMC”
    • Havana, Cuba
    • Organization Established Date: 11 Oct 2011
    • Tax ID No.: 3000186940 (Cuba)

    Supplemental Information: As the entity that markets Cuba’s overseas medical-brigade labor, CSMC appears to be one of the two entities Secretary Rubio’s statement describes as responsible, together with two individuals, for the exploitation and forced labor of Cuban medical workers through the regime’s overseas medical brigades.

    CORAL MARITIMA S.A.

    • Havana, Cuba
    • Organization Established Date: 2019
    • Organization Type: Sea and coastal freight water transport
    • Entity Code: 60301 (Cuba)
    • Linked to: GRUPO EMPRESARIAL DE TRANSPORTE MARITIMO PORTUARIO

    Supplemental Information: Coral Maritima’s link to a state maritime and port transport holding group is, in our reading, consistent with the GAESA-linked sanctions-evasion category in Secretary Rubio’s statement, though the statement does not name the four entities in that category individually.

    EINARBO S.A.

    • Havana, Cuba
    • Organization Established Date: 19 Feb 2020
    • Organization Type: Wholesale of solid, liquid and gaseous fuels and related products
    • Entity Code: 60636 (Cuba)

    Supplemental Information: Einarbo’s fuel-wholesaling profile places it, in our reading, among the three energy-sector entities referenced in Secretary Rubio’s statement.

    EMPRESA DE ENERGIA S.A.

    • AKA: “ENERSA”
    • Havana, Cuba
    • Organization Established Date: 01 Jan 2012
    • Organization Type: Wholesale of solid, liquid and gaseous fuels and related products
    • Entity Code: 60600 (Cuba)

    Supplemental Information: ENERSA’s fuel-wholesaling profile likewise places it, in our reading, among the three energy-sector entities referenced in Secretary Rubio’s statement.

    ORBIT S.A.

    • Havana, Cuba
    • Organization Established Date: 02 Mar 2020
    • Organization Type: Financial and Insurance Activities
    • Entity Code: 60642 (Cuba)

    Supplemental Information: Orbit’s financial-services profile is, in our reading, consistent with the GAESA-linked sanctions-evasion category in Secretary Rubio’s statement, though this is an inference rather than a statement made explicitly in either press release.

    TERMINAL DE CONTENEDORES DE MARIEL S.A.

    • AKA:
      • MARIEL CONTAINER TERMINAL S.A.
      • TCM S.A.
    • Vista del Mar, Cuba
    • Organization Established Date: 01 Jun 2011
    • Organization Type: Cargo handling
    • Entity Code: 60597 (Cuba)
    • Linked to: GRUPO DE ADMINISTRACION EMPRESARIAL S.A.

    Supplemental Information: This container terminal operator is directly linked in the listing itself to Grupo de Administración Empresarial S.A. — GAESA’s full name — making it, in our reading, one of the four GAESA-linked entities referenced in Secretary Rubio’s statement.

    UNIDAD CENTRAL DE COOPERACION MEDICA

    • AKA:
      • “CENTRAL UNIT FOR MEDICAL COOPERATION”
      • “UCCM”
    • Marianao, Cuba
    • Organization Established Date: 30 Sep 1984
    • Entity Code: 9809 (Cuba)

    Supplemental Information: UCCM, to which fellow designee Gretza Sanchez Padron is linked, administers Cuba’s overseas medical-brigade program and appears to be the second of the two entities Secretary Rubio’s statement describes as responsible, together with two individuals, for the exploitation and forced labor of Cuban medical workers through those brigades.

    Delistings:

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

    OFAC Program: [BELARUS-EO14038] Executive Order 14038

    BEL-KAP-STEEL LLC, Miami, FL 33130, United States; Organization Established Date: 1998; Tax ID No.: 52-2083095 (United States); Business Registration Number: 0582030 (Connecticut) (United States); alt. Business Registration Number: M99000000961 (Florida) (United States) (Linked To: OPEN JOINT STOCK COMPANY BYELORUSSIAN STEEL WORKS MANAGEMENT COMPANY OF HOLDING BYELORUSSIAN METALLURGICAL COMPANY).

    Sources:

    • [CUBA-EO14404] does not yet appear on OFAC’s Program Tag Definitions page as of July 2026; the description above uses the underlying executive order citation, consistent with how OFAC has documented other newly issued single-EO tags there.
    • José Ángel Portal Miranda’s identification as Cuba’s Minister of Public Health: CiberCuba
    • The mapping of individual Cuba-related entities to the three sub-categories described in Secretary Rubio’s press statement (GAESA-linked sanctions evasion, energy sector, medical-brigade labor exploitation) is our own inference from the entities’ stated business activities and linkages, cross-referenced against the category counts in the statement — it is not stated explicitly, entity-by-entity, in either underlying press release.

    and OFAC included two press charts – one of CJNG’s leaders:

    20260723_cjng_leadersDownload

    and one of networks linked to it:

    20260723_cjng_networksDownload

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