Target: professionals and organizations that knowingly or negligently facilitate sanctions evasion by designated parties. (This, dear reader, includes lawyers!)
Not Surprising
The Cartel del Noreste (“CDN”, also known as “Los Zetas”) has been involved in narcotics trafficking, human trafficking, arms trafficking, money laundering, vehicle theft, oil theft, extortion, kidnapping, and murder. In March 2022, CDN even attacked the U.S. Consulate in Nuevo Laredo, Texas with gunfire and grenades!
Because of this misbehavior, CDN has been collecting sanctions designations for almost 20 years:
- On April 15, 2009, Los Zetas was designated as a significant foreign narcotics trafficker.
- On July 24, 2011, it was named a “transnational criminal organization.”
- On December 15, 2021, the Office of Foreign Assets Control (of the U.S. Treasury, “OFAC”) designated CDN as a Specially Designated National.
- On February 20, 2025, the U.S. State Department identified CDN as a “Specially Designated Global Terrorist” and a “Foreign Terrorist Organization”.
Surprising
On April 14, 2026, designated six individuals and entities for sanctions evasion facilitation:
- Two casinos used for money laundering;
- The company operating those casinos;
- An attorney; and
- An individual presenting as a human rights activist who runs disinformation campaigns to boost public opinion.
The designations were issued under Executive Order 14059 and Executive Order 13224; they follow the previous designation of “Narco-Rapper” Ricardo Hernández Medrano (who was accused of laundering funds through concerts and royalties).
OFAC also issued a wind-down general license (GL 35) through May 13, 2026, for transactions involving the casinos and their operator.
Why This Matters:
Considering Mexico as a high-risk jurisdiction is nothing new. Treasury’s Financial Crimes Enforcement Network had already:
- Flagged gambling institutions in Mexico as “primary money laundering concerns”;
- Cut off certain foreign financial institutions tied to opioid trafficking; and
- Expanded reporting requirements for cash transactions in US border regions.
Similarly, OFAC going after narco-networks is nothing new.
What is new: OFAC now also targets “professional enablers.” In this case, not only are the cartel leadership and (obvious) front companies being targeted, but also (less obvious) businesses that move money (the casinos), professionals who facilitate communications or operations (the lawyer); and people shaping the narratives in support of the organizations (the disinformation actor).
Three outlined risks:
- You could inadvertently violate sanctions. As an example: one of the casinos (Casino Centenario) was located just 2 miles from the U.S. border. U.S. authorities alleged that the facility was used to store fentanyl and cocaine, launder illicit money, and conduct acts of torture in its back rooms. After its designation, Mexican authorities closed down the casino. Were it still allowed to continue to operate, U.S. persons visiting the casino would likely violate U.S. sanctions by doing so.
- You could violate criminal statute. Providing “material support” to an FTO is a federal crime under 18 U.S.C. § 2339B. “Material support or resources” is defined broadly as any tangible or intangible property or service, including: currency, financial services, lodging, training, safehouses, false documentation, communication equipment, facilities, weapons, and transportation. While the law requires that the support be provided “knowingly,” the adverb only relates to knowledge that such property or service was provided. In other words, U.S. persons could violate federal law by merely playing cards or buying a drink.
- Lawyers are targets for sanctions enforcement. We have already reported on attorney liability for sanctions violations. In this case, a currently-jailed CDN boss used his defense attorney as an intermediary with the cartel’s current leadership. That attorney was considered a professional enabler and likewise sanctioned.
Practical Takeaway:
To protect against sanctions violations, screening agents is now necessary but insufficient. Caution recommends additionally screening (1) gaming companies and non-traditional financial institutions, (2) counterparties in high-risk areas, and (3) any cash-intensive businesses.
Have any further questions or need some advice? Contact us today!
