• November 22, 2024

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OFAC Continues to Target La Oficina de Envigado

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Since June 26, 2014, OFAC has taken significant steps to disrupt the financing of La Oficina de Envigado, a Colombian-based criminal group, and its associated individuals and entities. Acting pursuant to the Kingpin Act, OFAC has designated La Oficina and a host of related persons and groups as part of its efforts to counter La Oficina’s alleged narcotics-trafficking and violent activities.

Last week, OFAC continued to accelerate the pressure on La Oficina by adding to the list of La Oficina-related individuals and entities designated for sanctions. On December 10, 2015, OFAC designated a criminal subgroup of La Oficina, Los Chatas, under the Kingpin Act for engaging in “drug trafficking and an array of violent crimes such as extortion, murder, and theft on behalf of [La Oficina].” Along with Los Chatas, OFAC designated “three Colombian nationals identified as leaders of Los Chatas and top lieutenants or associates of Juan Carlos Mesa Vallejo,” a La Oficina leader himself designated for sanctions in September 2014.

La Oficina de Envigado is alleged to have served as the ‘enforcement’ arm of the Medellin Cartel in the 1980s and 1900s, providing “drug debt collection services,” amongst other things. Following the demise of the Medellin Cartel, La Oficina expanded its activities in aid of transnational criminal organizations outside Colombia, including the Sinaloa Cartel, according to OFAC. These activities, OFAC has stated, involved the provision of La Oficina operatives to support narcotics trafficking worldwide via “money laundering, extortion, and murder for hire.”

Last week’s designations were the first targeting La Oficina since June 2015. Since La Oficina was first targeted for sanctions in June 2014, OFAC has taken a series of enforcement actions against the group and its associates – six (6) in total according to our count. Presuming that OFAC is zeroed in on La Oficina as a result, the expectation is that more designations will follow, though perhaps not at the same pace as the past 18 months.

Tyler Cullis

Mr. Cullis is an Associate Attorney at Ferrari & Associates, P.C. where he is engaged in the practice of U.S. economic sanctions, including trade compliance, regulatory licensing matters, and federal investigations and prosecutions. Mr. Cullis has extensive experience counseling clients on matters falling under the purview of the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS). He has provided counsel to U.S. and foreign parties on complex cross-border transactions and compliance with U.S. economic sanctions; conducted corporate internal investigations and developed sanctions compliance policies; and submitted license applications and voluntary self-disclosures to OFAC. Mr. Cullis has advised global financial institutions, multi-national corporations, U.S. and foreign exporters and insurers, as well as private individuals regarding U.S. sanctions matters, including matters involving Russia, Iran, and Cuba.