Well unless you have been living under a rock–or simply just don’t follow the developments in Mexico’s drug war–Arturo Beltran Levy was killed in a two hour gun battle with Mexican Marines on Wednesday. His death comes mere weeks after the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) designated 22 individuals and 11 entities tied to Levy’s drug cartel as drug Kingpins under the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). However, OFAC wasted no time in replacing one Kingpin with seven more.

On Wednesday, OFAC designated three individuals and four entities they allege are connected to the Sinaloa Cartel as Specially Designated Narcotics Trafficking Kingpins (“SDNTKs”). As such U.S. persons are prohibited from engaging in any transactions with these individuals and entities. Those you do engage in transactions with SDNTKs face both serious civil and criminal penalities.

OFAC accuses these individuals of providing material support to the narcotics trafficking activities of the Sinaloa Cartel. The Sinaloa Cartel was first designated as an entity in April 2009, however OFAC has been designating individuals they accuse of being connected to the Sinaloa Cartel for years. In fact, I personally have represented such individuals in their designation removal proceedings before OFAC. Despite their late designation, the Sinaloa Cartel has been aggressively attacked by OFAC using the tools available to them under the Kingpin Act and its accompanying federal regulations.

As I have mentioned in the past, there are procedures in which an SDNTK designation can be removed. If you have found yourself designated by OFAC contact an attorney with experience and knowledge in U.S. sanctions law to help you get off the list.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or

Bookmark and Share