Mr. Sanctions

Category: Narcotics Trafficking

  • February 19, 2026: OFAC Sanctions-a-Rama: Changes to 4 different programs, and a new Counter-Terrorism General License

    First the General License, Counter-Terrorism General License 34 “Authorizing the Wind Down of Transactions Involving Kovay Gardens”:

    ct_gl34Download

    And the additions and updates:

    Counter Terrorism and Counter Narcotics Designations; Sudan-related Designations and Designation Update; Russia-related Designation Update; Issuance of Counter Terrorism General License

    Treasury Press Release: Treasury Sanctions Sudanese Paramilitary Commanders for Atrocities in El-Fasher

    Treasury Press Release: Treasury Targets Cartel-Linked Timeshare Resort Defrauding U.S. Citizens

    Additions:

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

    OFAC Program: [SUDAN-EO14098] Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition

    ADAM, Elfateh Abdullah Idris

    • AKA: * IDRIS, Al-Fateh Abdullah
      • “ABU LULU”
      • “ISSA ABU LULU”
    • nationality: Sudan
    • Gender: Male
    • Rapid Support Forces Commander in Sudan
    • Party Type: individual

    Supplemental Information: Adam is an RSF brigadier general who filmed himself in El-Fasher killing unarmed civilians and bragging about killing thousands. He interrogated, mocked, and verbally abused civilian and surrendered SAF captives.

    MOHAMED, Gedo Hamdan Ahmed (Arabic: جدو حمدان أحمد محمد)

    • AKA: * “ABANSHUK”
      • “ABU NSHOUK”
      • “ABU SHOK”
    • DOB: 1973
    • POB: Kutum, North Darfur, Sudan
    • nationality: Sudan
    • Gender: Male
    • National ID No.: 21932935991 (Sudan)
    • Party Type: individual

    Supplemental Information: Mohamed is an RSF major general who has served as the commander for North Darfur since 2021. He was filmed at an abandoned SAF base in El-Fasher following its capture by the RSF.

    MOHAMED, Tijani Ibrahim Moussa

    • AKA: * “AL ZEER SALEM”
      • “AL ZEIR SALEM”
    • nationality: Sudan
    • Gender: Male
    • Rapid Support Forces Field Commander in Sudan
    • Party Type: individual

    Supplemental Information: Mohamed is an RSF field commander who participated in the RSF’s siege and capture of El-Fasher.

    OFAC Programs: * [SDGT] Global Terrorism Sanctions Regulations

    • [ILLICIT-DRUGS-EO14059] Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    GUTIERREZ OCHOA, Jose Luis

    • AKA: “Tolin”
    • DOB: 29 Dec 1987
    • POB: Michoacan de Ocampo, 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.: GUOL871229HMNTCS09 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    JIMENEZ TAPIA, Oscar Enrique

    • AKA: “El Tagayas”
    • DOB: 13 Dec 1985
    • 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.: JITO851213HJCMPS07 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    PALACIOS RODRIGUEZ, Jose Eduardo

    • DOB: 12 Feb 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.: PARE880212HJCLDD01 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    RIOS GONZALEZ, Jonathan Faustino

    • AKA: * “Johnny Hood”
      • “Jonas Hood”
    • DOB: 25 Feb 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.: RIGJ890225HJCSNN06 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    RIVERA MIRAMONTES, Carlos Humberto

    • DOB: 14 Jan 1962
    • 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.: RIMC620114HJCVRR04 (Mexico)
    • Party Type: individual
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

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

    OFAC Programs: * [SDGT] Global Terrorism Sanctions Regulations

    • [ILLICIT-DRUGS-EO14059] Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    ADMINISTRADORA Y COMERCIALIZADORA DEL MAR, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 01 Dec 2014
    • Organization Type: Short term accommodation activities
    • Folio Mercantil No.: 1926 (Mexico)
    • Linked to: KOVAY GARDENS

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    AGENCIA DE SERVICIOS TURISTICOS INTERNACIONALES G8, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 May 2012
    • Organization Type: Real estate activities on a fee or contract basis
    • Folio Mercantil No.: 67889 (Mexico)
    • Linked to: PALACIOS RODRIGUEZ, Jose Eduardo

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    ASESORIA Y SERVICIOS IMPORTADORES, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 19 Jun 2003
    • Organization Type: Other business support service activities n.e.c.
    • Folio Mercantil No.: 18727 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    CLUB DEPORTIVO DE FORMACION AL FUTBOL GMX, S.DE R.L. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 17 Nov 2023
    • Organization Type: Activities of sports clubs
    • Folio Mercantil No.: N-2024010467 (Mexico)
    • Linked to: JIMENEZ TAPIA, Oscar Enrique

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    COLINAS PROYECTOS Y CONSTRUCCIONES, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 19 Jun 2003
    • Organization Type: Construction of buildings
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    CONSTRUCTORA PALACIOS PV, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 23 Jan 2023
    • Organization Type: Real estate activities on a fee or contract basis
    • Folio Mercantil No.: N-2023010539 (Mexico)
    • Linked to: PALACIOS RODRIGUEZ, Jose Eduardo

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    CORPORATIVO CONTROLADOR EXPLORA, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 19 Jun 2003
    • Organization Type: Activities of holding companies
    • Folio Mercantil No.: 18728 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    CORPORATIVO DE TRANSFERENCIAS INTERNACIONALES DE BIENES RAICES, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 18 May 2012
    • Organization Type: Real estate activities on a fee or contract basis
    • Folio Mercantil No.: 67922 (Mexico)
    • Linked to: PALACIOS RODRIGUEZ, Jose Eduardo

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    DEEP BLUE DESARROLLOS, S. DE R.L. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 08 May 2012
    • Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.
    • Folio Mercantil No.: 68136 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    DEEP BLUE SERVICIOS, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 16 Nov 2012
    • Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.
    • Folio Mercantil No.: N-2020017004 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    ESTRATEGIA PVR, S. DE R.L. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 19 Dec 2013
    • Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.
    • Folio Mercantil No.: 80595 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    HIGH LAND PARK, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 04 Mar 2014
    • Organization Type: Travel agency activities
    • Folio Mercantil No.: N-2020017828 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    HOTEL MANAGEMENT INTERNATIONAL, LLC

    • AKA: VALLARTA GARDENS RESORTS, LLC
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 14 Nov 2012
    • Organization Type: Other reservation service and related activities
    • Tax ID No.: 32049481941 (Texas) (United States)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    KOVAY GARDENS

    • AKA: VALLARTA GARDENS
    • Website: https://kovaygardens.com
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 2002
    • Organization Type: Short term accommodation activities
    • Linked to: CARTEL DE JALISCO NUEVA GENERACION

    Supplemental Information: A Mexican timeshare resort located northwest of Puerto Vallarta that serves as part of the timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    ORNITORRINCO INMOBILIARIA, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 07 Jun 2011
    • Organization Type: Real estate activities on a fee or contract basis
    • Folio Mercantil No.: 63646 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    PUNTO 54, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 19 Feb 2014
    • Organization Type: Travel agency activities
    • Folio Mercantil No.: 80025 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    REEF ADMINISTRACION AVANZADA, S. DE R.L. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 09 Jan 2014
    • Organization Type: Other financial service activities, except insurance and pension funding activities, n.e.c.
    • Folio Mercantil No.: 80598 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    SOLUGAS SOLUCIONES EN GASOLINERAS, S.A. DE C.V.

    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Type: Retail sale of automotive fuel in specialized stores
    • RFC: SSG080722688 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    VG DESARROLLOS DE LA BAHIA, S.A. DE C.V.

    • AKA: * FARO GRILL
      • GRUPO KOVAY
      • KOVAY DESARROLLOS
      • MARINE DIAMOND
      • NAVIS BY LA CRUZ
      • QUIYA RESIDENCES
      • SANTA JULIA SEASIDE LIVING
      • SELVARA SIGNATURE COLLECTION
      • ZUL BY LA CRUZ
    • Website: https://kovaydesarrollos.com
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 11 Jan 2013
    • Organization Type: Real estate activities on a fee or contract basis
    • Folio Mercantil No.: N-2020017740 (Mexico)
    • Linked to: RIVERA MIRAMONTES, Carlos Humberto

    Supplemental Information: Targeted as part of a timeshare fraud network led by the terrorist Cartel de Jalisco Nueva Generacion (CJNG).

    Amendments:

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

    OFAC Program: [RUSSIA-EO14024] Russian Harmful Foreign Activities Sanctions Regulations

    LIMITED LIABILITY COMPANY INVESTMENT CONSULTANT ELBRUS CAPITAL

    • AKA: CAPELLA CAPITAL LIMITED LIABILITY COMPANY (Cyrillic: ООО КАПЕЛЛА КАПИТАЛ)
    • Secondary sanctions risk: See Section 11 of Executive Order 14024.
    • Tax ID No.: 9703036511 (Russia)
    • Registration Number: 1217700261613 (Russia)

    Supplemental Information: No new supplemental public information identified.

    • List of Changes:
    • Field Name: Address
      • Changed: Nab. Presnenskaya D. 10, Floor 27, KOM. 11V, Moscow 123112, Russia to: 3/10 Elektricheskiy pereulok, building 1, office 1N/6, Presnenskiy District, Moscow 123557, Russia
    • Field Name: AKA
      • Added: CAPELLA CAPITAL LIMITED LIABILITY COMPANY (Cyrillic: ООО КАПЕЛЛА КАПИТАЛ)

    OFAC Program: [SUDAN-EO14098] Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition

    MUSA, Algoney Hamdan Daglo (Arabic: القوني حمدان دقلو موسى)

    • AKA: * DAGALO, Algoney Hamdan
      • DAGALO, Al-Qoni Hamdan
    • DOB: 07 Aug 1990
    • POB: Nayala North, Sudan
    • nationality: Sudan
    • Gender: Male
    • Passport: B00017334 (Sudan)
    • alt. Passport: B00024943 (Sudan) expires 27 Sep 2031
    • alt. Passport: AK1586127 (Kenya)
    • UAE Identification: 784199014302485 (United Arab Emirates)
    • Party Type: individual

    Supplemental Information: Musa is the procurement director of the RSF and a brother of Mohammed Hamdan Daglo (Hemedti), the leader of the RSF. He has extended the war in Sudan by leading RSF efforts to procure weapons and military materiel.

    • List of Changes:
    • Field Name: alt. Passport
      • Added: AK1586127 (Kenya)
    • Field Name: UAE Identification
      • Added: 784199014302485 (United Arab Emirates)

    Unrelated Administrative List Changes

    OFAC Program: [IRAN] Iranian Transactions and Sanctions Regulations

    NAFTIRAN INTERTRADE CO. LIMITED

    • AKA: * NAFT IRAN INTERTRADE COMPANY LTD
      • NAFTIRAN INTERTRADE COMPANY
      • NAFTIRAN INTERTRADE COMPANY LTD
      • “NICO”
    • Additional Sanctions Information: Subject to Secondary Sanctions; all offices worldwide
    • Linked to: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED

    Supplemental Information: No new supplemental public information identified.

    • List of Changes:
    • Field Name: Name
      • Changed: NAFTIRAN INTERTRADE CO. (NICO) LIMITED to: NAFTIRAN INTERTRADE CO. LIMITED
    • Field Name: AKA
      • Changed: NAFTIRAN INTERTRADE COMPANY (NICO) to: NAFTIRAN INTERTRADE COMPANY
    • Field Name: AKA
      • Changed: NICO to: “NICO”

    NAFTIRAN INTERTRADE CO. SARL

    • AKA: “NICO”
    • Additional Sanctions Information: Subject to Secondary Sanctions; all offices worldwide

    Supplemental Information: No new supplemental public information identified.

    • List of Changes:
    • Field Name: Name
      • Changed: NAFTIRAN INTERTRADE CO. (NICO) SARL to: NAFTIRAN INTERTRADE CO. SARL
    • Field Name: AKA
      • Changed: NICO to: “NICO”

    Press Chart: CHART – CJNG Timeshare Fraud Network – February 2026

    The State Department also issued related press releases:

    Targeting Paramilitary Commanders Committing Atrocities in Sudan

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 19, 2026

    Today, the United States is sanctioning Elfateh Abdullah Idris Adam, Gedo Hamdan Ahmed Mohamed, and Tijani Ibrahim Moussa Mohamed of the Rapid Support Forces (RSF), a paramilitary group whose members have committed genocide in Sudan. The RSF has perpetrated atrocities during the almost three-year conflict in Sudan. The RSF and allied militias engaged in a campaign of widespread killings, torture, and sexual violence in El Fasher, the capital of North Darfur, during the months-long siege and subsequent capture of the city in October 2025, targeting civilians based on their ethnicity and tribal identity. The RSF also prevented food and other humanitarian assistance from entering the city, leading to famine and disease.

    In addition, the Department of State is designating Elfateh Abdullah Idris Adam under Section 7031(c) for gross violations of human rights. Idris brazenly filmed his atrocities, including executing unarmed civilians in El Fasher. As a result, Idris and his immediate family members are ineligible for entry into the United States.

    The Trump Administration seeks a lasting peace in Sudan and an end to the world’s worst humanitarian crisis. We call on the belligerents to accept the U.S.-brokered humanitarian truce without preconditions.

    Today’s actions are being taken pursuant to the authorities under Executive Order (E.O.) 14098 and pursuant to Section 7031(c) of the National Security, Department of State, and Related Programs Appropriations Act, 2026 (Div. F, P.L. 119-75). For more information on today’s E.O 14098 action, please see the Department of the Treasury’s press release.

    and

    Sanctioning CJNG-Controlled Timeshare Resort for Defrauding U.S. Citizens

    PRESS STATEMENT

    THOMAS “TOMMY” PIGOTT, PRINCIPAL DEPUTY SPOKESPERSON

    FEBRUARY 19, 2026

    The United States is sanctioning Kovay Gardens, a Mexican timeshare resort, along with five Mexican individuals and 17 Mexican companies linked to timeshare fraud schemes orchestrated by the Cártel de Jalisco Nueva Generación (CJNG).

    Last year, the Trump Administration designated CJNG as both a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT). CJNG generates illicit revenue through drug trafficking, fuel theft, extortion, human trafficking, and timeshare fraud, and further endangers Americans by trafficking illicit fentanyl, which President Trump rightly designated as a weapon of mass destruction. The United States remains committed to protecting the American people from vicious FTOs and SDGTs.

    Today’s action was taken pursuant to Executive Order (E.O.) 14059, which targets the proliferation of illicit drugs and their means of production, and E.O. 13224, as amended, which targets terrorists and their supporters.

    For more information about today’s sanctions, please see Treasury’s press release.

    —

    , , , , , , ,

  • February 12, 2026: OFAC Settles for $1.7MM from IMG Academy

    Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and IMG Academy, LLC

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $1,720,000 settlement with IMG Academy, LLC to settle its potential civil liability for 89 apparent violations of OFAC counternarcotics sanctions. Between 2019 and 2025, IMG Academy dealt in the property or interests in property of two Specially Designated Nationals (SDNs) sanctioned for their ties to a sanctioned Mexico-based drug cartel. Specifically, IMG Academy entered into yearly tuition agreements with the SDNs and received and processed payments pursuant to those agreements. The settlement amount reflects OFAC’s determination that IMG Academy’s conduct was non-egregious and not voluntarily disclosed.

    Here’s Gemini’s take:

    Based on the OFAC Enforcement Release regarding IMG Academy, LLC (the document referenced by the URL provided), here is the reformatted and simplified breakdown as requested.

    What Happened

    The Core Issue

    IMG Academy, a Florida-based sports prep school, agreed to settle its legal liability after it was discovered they had been doing business with two people on the U.S. sanctions list. These individuals were sanctioned due to their ties to a major Mexican drug cartel.

    The Two Sets of Violations

    The school entered into two separate tracks of business dealings:

    • Customer 1 (SDN 1): Between 2018 and 2022, the school signed three separate yearly tuition contracts with this individual.
    • Customer 2 (SDN 2): During that same period, the school signed another three yearly tuition contracts with this second individual.

    In both cases, the school provided “elite academic and athletic training” for the children of these individuals. Even though the parents’ names were clearly listed on the U.S. government’s “No-Business” list (the SDN List), the school continued to invoice them, communicate with them about payments, and process their money.

    How the Money Moved

    The school didn’t just take one-off payments. They processed 89 total transactions over several years. This included:

    1. Direct Charges: Using credit cards the sanctioned parents had left on file.
    2. Third-Party Wires: Accepting wire transfers from other people and companies in Mexico intended to cover the students’ costs.

    Description of the Apparent Violations

    IMG Academy appears to have violated § 598.202 of the Foreign Narcotics Kingpin Sanctions Regulations. Essentially, the school “dealt in the property” of sanctioned persons by providing services in exchange for their money, which is a violation of federal law.

    The Bottom Line

    While the school eventually reported the issue, they only did so after the government had already started an investigation, meaning they did not get credit for a “voluntary” disclosure.

    The Penalty

    The final settlement amount is $1,720,000.

    Violation Breakdown

    OFAC categorized all 89 violations as non-egregious (meaning they weren’t considered a “worst-case scenario” of intentional defiance), but because the school didn’t self-report before the investigation began, the penalty was still substantial.

    • Total Violations: 89
    • Total Egregious Violations: 0
    • Total Non-Egregious Violations: 89
    • Base Penalty: $1,720,000 (The “schedule” amount for non-disclosed, non-egregious violations).

    Mitigating and Aggravating Factors

    Aggravating Factors (Why the penalty remained high)

    • Failure to Perform Basic Checks
      • General Factor: Reckless Disregard. The school failed to run the parents’ names through any sanctions screening software, even though the parents provided their real names which matched the SDN list exactly.
    • Management Awareness of the Relationship
      • General Factor: Awareness of Conduct. While the school might not have realized the parents were “sanctioned,” they had actual knowledge of the transactions. They sent invoices directly to the parents and spoke with them regularly about their accounts.
    • Providing a “Safety Valve” for Cartel Money
      • General Factor: Harm to Sanctions Program. By accepting this money, the school allowed people tied to a drug cartel to use the U.S. financial system and obtain high-end services in the U.S.

    Mitigating Factors (Why the penalty wasn’t higher)

    • A Clean Recent Record
      • General Factor: Compliance Record. IMG Academy had not been flagged for a sanctions violation in the five years before this happened.
    • Coming Clean and Cooperating
      • General Factor: Cooperation. Once they realized the government was looking into them, the school cooperated fully, shared information quickly, and agreed to extend the legal deadlines to help the investigation.
    • A Total Compliance Overhaul
      • General Factor: Remediation. After a change in ownership in 2023, the school hired a new Chief Legal Officer, conducted a deep audit of their past mistakes, and built a professional sanctions screening system.

    What are the Takeaways?

    • Screen the Payors: It is not enough to screen the student; you must screen the person signing the contract and the person sending the wire transfer.
    • Names are Enough: If a customer gives you their real name and it matches a sanctioned person, “I didn’t know” is not a valid excuse if you never bothered to check the list.
    • Non-Bank Businesses are at Risk: This case shows that OFAC is looking closely at “non-traditional” sectors like private schools, luxury goods, and specialized training centers.
    • Ownership Changes are an Opportunity: If you buy a company, conduct a “compliance lookback” immediately. IMG’s new management helped limit the damage by fixing the system as soon as they took over.

    Other Resources

    • OFAC Civil Penalties & Enforcement: Visit the official Treasury website to see a list of recent actions and understand how OFAC applies these rules to different industries.
    • Compliance Framework: Review the “Framework for OFAC Compliance Commitments” to see the five pillars of a strong legal safety net.
    • Contacting OFAC: If you find a potential violation, you can contact the OFAC Compliance Hotline or use their online reporting portal.

    Here’s the actual Enforcement Release:

    20260212_img_academyDownload

    Note: Gemini originally didn’t catch that there were 2 sets of violations with SDN 1 and SDN 2. What flagged this for me was that the date range of the violations was wrong.

    Fixing it was pretty simple – I just told Gemini to recheck its work and why I thought it had missed something.

    Probably a good thing to do with enforcement actions that have “multiple’ something – whether its sets of actions, sanctioned parties or affected sanctions programs. It’s generally good practice to have an AI tool check its work – since I asked for a simplified recap, I expected it to omit certain detail. But, this was not that…

    —

    , , ,

  • January 22, 2026: OFAC adds to Counter-Narcotics Sanctions

    Counter Narcotics Designations

    Treasury Press Release: Treasury Sanctions One of the Caribbean’s Largest Narcotics Traffickers and His Network

    Additions:

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

    OFAC Program: [ILLICIT-DRUGS-EO14059] Illicit Drug Trade Sanctions

    MC DONAL RODRIGUEZ, Anita Yorleny

    • AKA: MCDONALD RODRIGUEZ, Anita
    • Address: Limon, Costa Rica
    • DOB: 04 Oct 1974
    • Nationality: Costa Rica
    • Gender: Female
    • Cedula No.: 701120514 (Costa Rica)
    • Party Type: individual
    • Linked to: PICADO GRIJALBA, Luis Manuel

    Supplemental Information: Anita Yorleny Mc Donal Rodriguez is the mother-in-law of Luis Manuel Picado Grijalba (“Shock”). She used her businesses to launder money for Shock and notarized fraudulent transactions on his behalf.

    MC DONALD RODRIGUEZ, Estefania

    • AKA: MCDONALD RODRIGUEZ, Estefania
    • Address: Costa Rica
    • DOB: 09 Apr 1992
    • Nationality: Costa Rica
    • Gender: Female
    • Cedula No.: 702100887 (Costa Rica)
    • Party Type: individual
    • Linked to: PICADO GRIJALBA, Luis Manuel

    Supplemental Information: Estefania Mc Donald Rodriguez is the wife of Luis Manuel Picado Grijalba (“Shock”). She used her businesses to launder money for Shock and facilitate his drug trafficking operations.

    PENA RUSSELL, Tonny Alexander

    • AKA: PEÑA RUSSELL, Tonny Alexander
    • Address: Limon, Costa Rica
    • DOB: 29 Dec 1987
    • Nationality: Costa Rica
    • Gender: Male
    • Cedula No.: 701820333 (Costa Rica)
    • Party Type: individual
    • Linked to: PICADO GRIJALBA, Luis Manuel

    Supplemental Information: Tonny Alexander Pena Russell controls a gang of sicarios (hitmen) that allied with Shock and Noni. He was arrested in 2024 and charged with 78 counts of murder, many of which were carried out on Shock’s orders.

    PICADO GRIJALBA, Jordie Kevin

    • AKA: “Noni”
    • Address: Limon, Costa Rica
    • DOB: 19 May 1993
    • Nationality: Costa Rica
    • Gender: Male
    • Cedula No.: 702200042 (Costa Rica)
    • Party Type: individual

    Supplemental Information: Jordie Kevin Picado Grijalba, known as “Noni,” is a leader of the trafficking network and brother to Luis Manuel Picado Grijalba. He is responsible for importing cocaine to Costa Rica and storing it. Noni was arrested in Costa Rica in August 2025 and is held pending extradition to the United States.

    PICADO GRIJALBA, Luis Manuel

    • AKA: “Shock”
    • Address: Limon, Costa Rica
    • DOB: 22 Dec 1981
    • Nationality: Costa Rica
    • Gender: Male
    • Cedula No.: 801190098 (Costa Rica)
    • Party Type: individual

    Supplemental Information: Luis Manuel Picado Grijalba, known as “Shock,” is the leader of the network and one of the most prolific drug traffickers in the Caribbean. He is responsible for importing cocaine to Costa Rica and storing it. Shock was arrested in the United Kingdom in December 2024 and is held pending extradition to the United States.

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

    OFAC Program: [ILLICIT-DRUGS-EO14059] Illicit Drug Trade Sanctions

    3-101-507688 SA

    • Address: Limon, Costa Rica
    • Tax ID No.: 3-101-507688 (Costa Rica)
    • Linked to: MC DONALD RODRIGUEZ, Estefania

    Supplemental Information: This company is operated by Estefania McDonald to facilitate Shock’s criminal activities. It has been temporarily suspended by Costa Rican authorities due to its links to money laundering and drug trafficking.

    ASOCIACION DE LIDERES LIMONENSES DEL SECTOR PESQUERO

    • AKA: “ASOLIPES”
    • Address: Limon, Costa Rica
    • Tax ID No.: 3-002-384913 (Costa Rica)
    • Linked to: MC DONAL RODRIGUEZ, Anita Yorleny

    Supplemental Information: Operated by Estefania McDonald and Anita McDonald, this entity was designated for being owned or controlled by Anita McDonald Rodriguez. It has been temporarily suspended by Costa Rican authorities due to its links to money laundering and drug trafficking.

    CELAJES DE YORK CDY SA

    • Address: Limon, Costa Rica
    • Tax ID No.: 3-101-313254 (Costa Rica)
    • Linked to: MC DONALD RODRIGUEZ, Estefania

    Supplemental Information: This company is operated by Estefania McDonald to facilitate Shock’s criminal activities.

    INVERSIONES LAURITA L AND L SA

    • AKA: INVERSIONES LAURITA L&L SA
    • Address: San Jose, Costa Rica
    • Tax ID No.: 3-101-703720 (Costa Rica)
    • Linked to: MC DONALD RODRIGUEZ, Estefania

    Supplemental Information: This company is operated by Estefania McDonald to facilitate Shock’s criminal activities. It has been temporarily suspended by Costa Rican authorities due to its links to money laundering and drug trafficking.

    MAGIC ESTHETIC SALON SA

    • Address: San Jose, Costa Rica
    • Tax ID No.: 3-101-800676 (Costa Rica)
    • Linked to: MC DONALD RODRIGUEZ, Estefania
    • Linked to: MC DONAL RODRIGUEZ, Anita Yorleny

    Supplemental Information: This company is operated by Estefania McDonald and Anita McDonald to facilitate Shock’s criminal activities.

    Press Chart: PRESS CHART – Picado Grijalba Costa Rican Drug Trafficking Network

    —

    , ,

  • January 2, 2026: OFAC Counter-Narcotics Designation Update

    Counter Narcotics Designation Update

    Amendments:

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

    OFAC Program: ILLICIT-DRUGS-EO14059 Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    DIANA, Cristian

    • Address: Pordenone, Italy
    • DOB: 24 Nov 1971
    • POB: Pordenone, Italy
    • nationality: Italy
    • Gender: Male
    • Passport: YB8215970 (Italy)
    • Tax ID No.: DNICST71S24G888J (Italy)
    • Party Type: Individual
    • Linked to:
      • STILE ITALIANO S.R.L.
      • WINDROSE TACTICAL SOLUTIONS S.R.L.S.

    Supplemental Information: Cristian Diana is an Italian citizen designated for his role as a leader or official of Stile Italiano S.R.L. and Windrose Tactical Solutions S.R.L.S. According to the U.S. Treasury, he is a business associate of Gianluca Tiepolo and serves as president of the board of directors for both companies. These entities are part of a network linked to Ryan James Wedding, a transnational drug trafficker, and were used to launder drug profits and facilitate cartel operations.

    • List of Changes:
      • Field Name: Address
        • Changed: Isernia, Italy to: Pordenone, Italy
      • Field Name: DOB
        • Changed: 03 Oct 1974 to: 24 Nov 1971
      • Field Name: POB
        • Changed: Isernia, Italy to: Pordenone, Italy
      • Field Name: Passport
        • Changed: E619547 (Italy) to: YB8215970 (Italy)
      • Field Name: Tax ID No.
        • Added: DNICST71S24G888J (Italy)

    —

    , ,

  • Working Backwards: December 12, 2025 OFAC Designations and Designation Updates – with Formatting Corrections and Enhancements

    Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates

    Treasury Press Release: Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector

    Additions:

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

    OFAC Program: [ILLICIT-DRUGS-EO14059] Executive Order 14059 – Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    CAMPO FLORES, Efrain Antonio

    • Address: Caracas, Venezuela
    • DOB: 25 Aug 1986
    • POB: Valencia, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 18330183 (Venezuela)
    • Passport: 081303148 (Venezuela) expires 28 Nov 2018
    • Party Type: Individual

    FLORES DE FREITAS, Franqui Francisco

    • Address: Caracas, Venezuela
    • DOB: 14 Aug 1985
    • POB: Caracas, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 17751244 (Venezuela)
    • Passport: 066981222 (Venezuela) expires 24 Jan 2018
    • Party Type: Individual

    Supplemental Information: Efrain Antonio Campo Flores and Franqui Francisco Flores de Freitas are the nephews of Cilia Flores, the wife of Nicolas Maduro. They are being designated for their involvement in illicit drug trafficking activities.

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    CARRETERO NAPOLITANO, Ramon

    • Address: Panama City, Panama
    • DOB: 08 May 1965
    • POB: Colon, Panama
    • Nationality: Panama
    • Gender: Male
    • Cedula No.: 388114 (Panama)
    • Passport: 1874513 (Panama) expires 28 Mar 2017
    • Party Type: Individual

    Supplemental Information: Ramon Carretero Napolitano is a Panamanian businessman designated for operating in the oil sector of the Venezuelan economy and facilitating sanctions evasion for the Maduro regime.

    OFAC Program: [VENEZUELA] Venezuela Sanctions Regulations, 31 C.F.R. part 591

    MALPICA FLORES, Carlos Erik

    • Address: Naguanagua, Carabobo, Venezuela
    • DOB: 17 Sep 1972
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 11810943 (Venezuela)
    • Party Type: Individual

    Supplemental Information: Carlos Erik Malpica Flores is a former official of the Government of Venezuela and the nephew of Cilia Flores. He previously served as the National Treasurer and Vice President of Finance for PDVSA. He is designated for being a current or former official of the Government of Venezuela.

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

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARCTIC VOYAGER INCORPORATED

    • AKA: ARCTIC VOYAGER INC
    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 08 Nov 2024
    • Identification Number: IMO 0109600
    • Business Registration Number: 128742 (Marshall Islands)

    FULL HAPPY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 03 Mar 2023
    • Identification Number: IMO 6405624
    • Business Registration Number: 118736 (Marshall Islands)

    MYRA MARINE LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 24 Sep 2024
    • Identification Number: IMO 0088934
    • Business Registration Number: 128049 (Marshall Islands)

    POWEROY INVESTMENT LIMITED

    • AKA: POWEROY INVESTMENT LTD
    • Address: Virgin Islands, British
    • Identification Number: IMO 6438512

    READY GREAT LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 06 Jul 2023
    • Identification Number: IMO 0017035
    • Business Registration Number: 120806 (Marshall Islands)

    SINO MARINE SERVICES LIMITED

    • AKA: SINO MARINE SERVICES LTD
    • Address: 14, Wells View Drive, Bromley, Kent BR2 9UL, United Kingdom
    • Organization Established Date: 01 Jan 2016
    • Identification Number: IMO 5967460
    • Company Number: 10214578 (United Kingdom)

    Supplemental Information: These entities are part of a sanctions evasion network established to facilitate the illicit export of Venezuelan oil.

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

    OFAC Program: [VENEZUELA-EO13850] Executive Order 13850 – Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    H. CONSTANCE (3E2177)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2002
    • Vessel Registration Identification: IMO 9237773
    • MMSI: 352002009
    • Party Type: Vessel
    • Linked to: POWEROY INVESTMENT LIMITED

    KIARA M (3E2278)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9285823
    • MMSI: 352002348
    • Party Type: Vessel
    • Linked to: ARCTIC VOYAGER INCORPORATED

    LATTAFA (3E2298)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2003
    • Vessel Registration Identification: IMO 9245794
    • Party Type: Vessel
    • Linked to: READY GREAT LIMITED

    MONIQUE (E5U5122)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Cook Islands
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9311270
    • MMSI: 518999141
    • Party Type: Vessel
    • Linked to: FULL HAPPY LIMITED

    TAMIA (VRXC8)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Hong Kong
    • Vessel Flag: Other Vessel Flag China
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9315642
    • MMSI: 477186300
    • Party Type: Vessel
    • Linked to: SINO MARINE SERVICES LIMITED

    WHITE CRANE (HOA6213)

    • Vessel Type: Crude Oil Tanker
    • Vessel Flag: Panama
    • Vessel Year of Build: 2007
    • Vessel Registration Identification: IMO 9323429
    • MMSI: 352003199
    • Party Type: Vessel
    • Linked to: MYRA MARINE LIMITED

    Supplemental Information: These vessels are part of a shadow fleet used to transport Venezuelan oil in violation of U.S. sanctions.

    Amendments:

    Specially Designated Nationals List Update

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

    OFAC Programs:

    • [NPWMD] Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544
    • [IFSR] Iranian Financial Sanctions Regulations, 31 C.F.R. part 561

    ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY CENTER

    • AKA:
      • AICTC
      • ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE
      • “AICT”
    • Address: No. 5, Golestan Alley, Shahid Ghasemi St., Sharif University of Technology, Tehran, Iran
    • Website: www.aictc.ir
    • Additional Sanctions Information – Subject to Secondary Sanctions

    Supplemental Information: None

    List of Changes:

    • Field Name: AKA
      • Added: ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE
      • Added: “AICT”

    RAHIMIAN, Pezhman

    • AKA: RAHIMIAN, Pejman
    • Address: Iran
    • DOB: 29 Aug 1977
    • POB: Esfahan, Esfahan Province, Iran
    • Nationality: Iran
    • Additional Sanctions Information – Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 1285917855 (Iran)
    • Party Type: Individual
    • Linked to: ATOMIC ENERGY ORGANIZATION OF IRAN

    Supplemental Information: None

    List of Changes:

    • Field Name: DOB
      • Added: 29 Aug 1977

    —

    , , , ,

  • Yesterday’s OFAC update… now with designation updates

    The prompt is a work in progress, but I’m getting there…

    Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates

    Treasury Press Release:

    Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector

    Specially Designated Nationals List Update

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

    [ILLICIT-DRUGS-EO14059]

    Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade

    CAMPO FLORES, Efrain Antonio

    • Address: Caracas, Venezuela
    • DOB: 25 Aug 1986
    • POB: Valencia, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 18330183 (Venezuela)
    • Passport: 081303148 (Venezuela) expires 28 Nov 2018 (individual)

    Efrain Antonio Campo Flores is the nephew of Cilia Adela Flores de Maduro, the wife of Nicolas Maduro. Known as one of the “narco-nephews,” he was arrested in Haiti in November 2015 while finalizing a deal to smuggle cocaine into the United States. He was convicted in U.S. federal court but was granted clemency by President Biden in October 2022. According to the Treasury, since his return to Venezuela, he has resumed illicit drug trafficking activities.

    FLORES DE FREITAS, Franqui Francisco

    • Address: Caracas, Venezuela
    • DOB: 14 Aug 1985
    • POB: Caracas, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 17751244 (Venezuela)
    • Passport: 066981222 (Venezuela) expires 24 Jan 2018 (individual)

    Franqui Francisco Flores de Freitas is the nephew of Cilia Adela Flores de Maduro. He was arrested alongside his cousin, Efrain Antonio Campo Flores, in Haiti in 2015 for conspiring to import cocaine into the United States. Following his conviction and subsequent clemency grant by President Biden in October 2022, he returned to Venezuela where, according to the Treasury, he continues to engage in narcotics trafficking.

    [VENEZUELA-EO13850]

    Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    CARRETERO NAPOLITANO, Ramon

    • Address: Panama City, Panama
    • DOB: 08 May 1965
    • POB: Colon, Panama
    • Nationality: Panama
    • Gender: Male
    • Cedula No.: 388114 (Panama)
    • Passport: 1874513 (Panama) expires 28 Mar 2017 (individual)

    Ramon Carretero Napolitano is a Panamanian businessman designated for operating in the oil sector of the Venezuelan economy. He has secured contracts with the Government of Venezuela and maintains business ties with the Maduro-Flores family, including partnering with them in various companies. He is accused of facilitating the shipment of petroleum products for the regime.

    [VENEZUELA]

    Venezuela Sanctions Regulations, 31 C.F.R. part 591

    MALPICA FLORES, Carlos Erik

    • Address: Naguanagua, Carabobo, Venezuela
    • DOB: 17 Sep 1972
    • Nationality: Venezuela
    • Gender: Male
    • Cedula No.: 11810943 (Venezuela) (individual)

    Carlos Erik Malpica Flores is the nephew of Cilia Flores and previously served as the National Treasurer of Venezuela and Vice President of Finance for PDVSA. He was originally designated by OFAC in July 2017 but was delisted in 2022 to encourage political negotiations in Mexico City. Treasury has redesignated him for being an official of the Government of Venezuela.

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

    [VENEZUELA-EO13850]

    Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    ARCTIC VOYAGER INCORPORATED

    AKAs: ARCTIC VOYAGER INC

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 08 Nov 2024
    • Identification Number: IMO 0109600
    • Business Registration Number: 128742 (Marshall Islands)

    Arctic Voyager Incorporated is the registered owner of the vessel KIARA M. The Treasury reports that this vessel loaded oil in Venezuela in September and October 2025 for transport to Asia.

    FULL HAPPY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 03 Mar 2023
    • Identification Number: IMO 6405624
    • Business Registration Number: 118736 (Marshall Islands)

    Full Happy Limited is the registered owner and commercial manager of the vessel MONIQUE. The vessel reportedly loaded and transported Venezuelan oil to Asia in late May 2025.

    MYRA MARINE LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 24 Sep 2024
    • Identification Number: IMO 0088934
    • Business Registration Number: 128049 (Marshall Islands)

    Myra Marine Limited is the registered owner and commercial manager of the vessel WHITE CRANE. The vessel loaded oil in Venezuela as recently as October 2025 and utilized deceptive practices, such as obscuring its location, to hide its activities.

    POWEROY INVESTMENT LIMITED

    AKAs: POWEROY INVESTMENT LTD

    • Address: Virgin Islands, British
    • Identification Number: IMO 6438512

    Poweroy Investment Limited is the registered owner of the vessel H. CONSTANCE. The vessel reportedly loaded Venezuelan oil in October 2025 and manipulated its location transmissions.

    READY GREAT LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Majuro, Ajeltake Island 96960, Marshall Islands
    • Organization Established Date: 06 Jul 2023
    • Identification Number: IMO 0017035
    • Business Registration Number: 120806 (Marshall Islands)

    Ready Great Limited is the registered owner of the vessel LATTAFA. The vessel is accused of making multiple shipments of Venezuelan oil to Asia throughout 2025 while using deceptive tracking practices.

    SINO MARINE SERVICES LIMITED

    AKAs: SINO MARINE SERVICES LTD

    • Address: 14, Wells View Drive, Bromley, Kent BR2 9UL, United Kingdom
    • Organization Established Date: 01 Jan 2016
    • Identification Number: IMO 5967460
    • Company Number: 10214578 (United Kingdom)

    Sino Marine Services Limited is the ship manager and operator of the vessel TAMIA. The vessel reportedly loaded and transported Venezuelan oil to Asia in June 2025 while manipulating its location transmissions.

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

    [VENEZUELA-EO13850]

    Blocking Property of Additional Persons Contributing to the Situation in Venezuela

    H. CONSTANCE

    • Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2002
    • Vessel Registration Identification: IMO 9237773
    • MMSI: 352002009 (vessel)Linked to: POWEROY INVESTMENT LIMITED

    The H. CONSTANCE is a Panama-flagged crude oil tanker identified for loading Venezuelan oil in October 2025 and manipulating its transmissions to hide its location.

    KIARA M

    • Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2004
    • Vessel Registration Identification: IMO 9285823
    • MMSI: 352002348 (vessel)Linked to: ARCTIC VOYAGER INCORPORATED

    The KIARA M is a Panama-flagged crude oil tanker that loaded oil in Venezuela in September and October 2025, destined for Asia.

    LATTAFA

    • Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2003
    • Vessel Registration Identification: IMO 9245794 (vessel)Linked to: READY GREAT LIMITED

    The LATTAFA is a Panama-flagged crude oil tanker accused of transporting multiple shipments of Venezuelan oil to Asia in 2025 while obfuscating its movements.

    MONIQUE

    • Type: Crude Oil Tanker
    • Flag: Cook Islands
    • Vessel Year of Build: 2005
    • Vessel Registration Identification: IMO 9311270
    • MMSI: 518999141 (vessel)Linked to: FULL HAPPY LIMITED

    The MONIQUE is a Cook Islands-flagged crude oil tanker that loaded and transported Venezuelan oil to Asia in late May 2025.

    TAMIA

    • Type: Crude Oil Tanker
    • Flag: Hong Kong
    • Other Vessel Flag: China
    • Vessel Year of Build: 2006
    • Vessel Registration Identification: IMO 9315642
    • MMSI: 477186300 (vessel)Linked to: SINO MARINE SERVICES LIMITED

    The TAMIA is a Hong Kong-flagged crude oil tanker that loaded and transported Venezuelan oil to Asia in June 2025, using deceptive practices to hide its location.

    WHITE CRANE

    • Type: Crude Oil Tanker
    • Flag: Panama
    • Vessel Year of Build: 2007
    • Vessel Registration Identification: IMO 9323429
    • MMSI: 352003199 (vessel)Linked to: MYRA MARINE LIMITED

    The WHITE CRANE is a Panama-flagged crude oil tanker that loaded oil in Venezuela in October 2025 and employed deceptive practices, such as failing to transmit its location, to hide its activities.

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

    [NPWMD]

    Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544

    [IFSR]

    Iranian Financial Sanctions Regulations, 31 C.F.R. part 561

    ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY CENTER

    AKAs: ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE; AICTC; AICT

    • Address: No. 5, Golestan Alley, Shahid Ghasemi St., Sharif University of Technology, Tehran, Iran
    • Website: www.aictc.ir
    • Additional Sanctions Information: – Subject to Secondary Sanctions

    List of Changes:

    Field Name: a.k.a.

    Changed: “a.k.a. AICTC” to: “a.k.a. ADVANCED INFORMATION AND COMMUNICATION TECHNOLOGY RESEARCH INSTITUTE; a.k.a. AICTC; a.k.a. “AICT””

    RAHIMIAN, Pezhman

    AKAs: RAHIMIAN, Pejman

    • Address: Iran
    • DOB: 29 Aug 1977
    • POB: Esfahan, Esfahan Province, Iran
    • Nationality: Iran
    • Additional Sanctions Information: – Subject to Secondary Sanctions
    • Gender: Male
    • National ID No.: 1285917855 (Iran) (individual)Linked to: ATOMIC ENERGY ORGANIZATION OF IRAN

    List of Changes:

    Field Name: DOB

    Added: 29 Aug 1977

    —

    , , ,

  • December 11, 2025: Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates

    The following are the additions made from Counter Narcotics Designations; Venezuela-related Designations; Non-Proliferation Designation Updates (I have to find my prompt for updates) – and here is the Treasury Press Release “Treasury Targets Illegitimate Maduro Regime Insiders and Sanctions Evaders in Venezuela’s Oil Sector”

    Individuals

    [VENEZUELA-EO14059]

    • Definition: Executive Order 14059 of December 15, 2021, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade”.

    CAMPO FLORES, Efrain Antonio

    • Aliases: a.k.a. “Campo”; a.k.a. “Efraín Campo”; a.k.a. “Efraín Flores”
    • Nationality: Venezuela
    • DOB: [Approx. 1986]
    • Gender: Male
    • Type: Individual

    Supplemental Information: Efrain Antonio Campo Flores is the nephew of Cilia Flores, the wife of Nicolas Maduro. Known as one of the “Narco Nephews,” he was arrested in Port-au-Prince, Haiti, in November 2015 during a DEA sting operation while finalizing a deal to transport 800 kilograms of cocaine to the United States. He was convicted in the U.S. District Court for the Southern District of New York on narcotics trafficking charges in November 2016 and sentenced to 18 years in prison. In October 2022, he was granted clemency by President Joe Biden in a prisoner exchange for seven Americans detained in Venezuela. The Treasury Department states that since his return to Venezuela, he has continued his involvement in illicit drug trafficking activities.

    FLORES DE FREITAS, Franqui Francisco

    • Aliases: a.k.a. “Flores de Freitas”; a.k.a. “Franqui Flores”
    • Nationality: Venezuela
    • DOB: [Approx. 1985]
    • Gender: Male
    • Type: Individual

    Supplemental Information: Franqui Francisco Flores de Freitas is the nephew of Cilia Flores and cousin of Efrain Antonio Campo Flores. He was arrested alongside his cousin in Haiti in November 2015 for conspiring to smuggle cocaine into the U.S. and was convicted in New York in 2016, receiving an 18-year prison sentence. Like his cousin, he was granted clemency in October 2022 as part of a prisoner swap. The Treasury Department has designated him for continuing to engage in activities that contribute to the international proliferation of illicit drugs.

    [VENEZUELA-EO13692]

    • Definition: Executive Order 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela”.

    MALPICA FLORES, Carlos Erik

    • Aliases: a.k.a. “Malpica”; a.k.a. “Malpica Flores, Carlos”
    • Address: Naguanagua, Carabobo, Venezuela
    • DOB: 17 Sep 1972
    • Nationality: Venezuela
    • Cedula No.: 11810943
    • Gender: Male
    • Type: Individual

    Supplemental Information: Carlos Erik Malpica Flores is another nephew of Cilia Flores. He formerly served as the National Treasurer of Venezuela and as the Vice President of Finance for the state-owned oil company, Petroleos de Venezuela, S.A. (PDVSA). He was previously designated by OFAC in July 2017 but was removed from the sanctions list in June 2022 by the Biden administration in an effort to encourage negotiations between the Maduro regime and the opposition. The Treasury Department has re-designated him for being a current or former official of the Government of Venezuela, citing the regime’s refusal to recognize democratic values.

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    CARRETERO NAPOLITANO, Ramon

    • Aliases: a.k.a. “Carretero”
    • Nationality: Panama
    • DOB: 26 Nov 1990
    • POB: Ciudad de Panama, Panama
    • Gender: Male
    • Type: Individual

    Supplemental Information: Ramon Carretero Napolitano is a Panamanian businessman and former professional cyclist. He competed in the 2014 Giro d’Italia but was suspended from the sport in 2015 after testing positive for EPO. In the business world, he is accused of engaging in lucrative contracts with the Maduro regime and facilitating shipments of petroleum products on behalf of the Venezuelan government. He has partnered in several companies with the Maduro-Flores family. In September 2025, he reportedly survived a plane crash in Maiquetía, Venezuela, aboard a private jet (YV3440) linked to his business dealings.

    Entities

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    ARCTIC VOYAGER INCORPORATED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: KIARA M

    Supplemental Information: A Marshall Islands-registered company that is the registered owner of the Panama-flagged vessel Kiara M. The vessel loaded oil in Venezuela in September and October 2025 and transported it to Asia.

    FULL HAPPY LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: MONIQUE

    Supplemental Information: A Marshall Islands-registered company that owns and manages the Cook Islands-flagged vessel Monique. The vessel loaded and transported Venezuelan oil to Asia in May 2025.

    MYRA MARINE LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: WHITE CRANE

    Supplemental Information: A Marshall Islands-registered company that owns and manages the vessel White Crane. The vessel loaded oil in Venezuela as recently as October 2025 and has used deceptive shipping practices, such as manipulating its location transmissions.

    POWEROY INVESTMENT LIMITED

    • Address: Tortola, Virgin Islands, British
    • Type: Entity
    • Linked To: H. CONSTANCE

    Supplemental Information: A British Virgin Islands-registered company that owns the Panama-flagged vessel H. Constance. The vessel loaded Venezuelan oil in October 2025 and has repeatedly manipulated its AIS transmissions to hide its location.

    READY GREAT LIMITED

    • Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands
    • Type: Entity
    • Linked To: LATTAFA

    Supplemental Information: A Marshall Islands-registered company that owns the Panama-flagged vessel Lattafa. The vessel has made multiple shipments of Venezuelan oil to Asia throughout 2025 and has engaged in location obfuscation.

    SINO MARINE SERVICES LIMITED

    • Address: London, United Kingdom
    • Type: Entity
    • Linked To: TAMIA

    Supplemental Information: A UK-registered company that manages and operates the Hong Kong-flagged vessel Tamia. The vessel loaded and transported Venezuelan oil to Asia in June 2025 and has manipulated its transmissions to hide its activities.

    Vessels

    [VENEZUELA-EO13850]

    • Definition: Executive Order 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”.

    H. CONSTANCE

    • IMO: 9237773
    • Flag: Panama
    • Type: Vessel
    • Linked To: POWEROY INVESTMENT LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    KIARA M

    • IMO: 9285823
    • Flag: Panama
    • Type: Vessel
    • Linked To: ARCTIC VOYAGER INCORPORATED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    LATTAFA

    • IMO: 9245794
    • Flag: Panama
    • Type: Vessel
    • Linked To: READY GREAT LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    MONIQUE

    • IMO: 9311270
    • Flag: Cook Islands
    • Type: Vessel
    • Linked To: FULL HAPPY LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    TAMIA

    • IMO: 9315642
    • Flag: Hong Kong
    • Type: Vessel
    • Linked To: SINO MARINE SERVICES LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    WHITE CRANE

    • IMO: 9323429
    • Flag: Marshall Islands
    • Type: Vessel
    • Linked To: MYRA MARINE LIMITED

    Supplemental Information: An oil tanker identified as blocked property for transporting Venezuelan oil.

    The video below discusses the recent plane crash involving Ramon Carretero Napolitano, highlighting the “web of corruption” connecting him to the Maduro regime, which makes it relevant context for his designation.

    ACCIDENT IN VENEZUELA UNCOVERS CORRUPTION NETWORK

    —

    , ,