• November 5, 2024

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OFAC Designates New Individuals and Entities Under Kingpin Sanctions

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The United States Department of the Treasury Office of Foreign Assets (“OFAC”) has added twenty (20) Colombian nationals and twenty-four (24) businesses to the list of Specially Designated Narcotics Trafficking Kingpins (“SDNTKs”). These designated parties have had their assets under jurisdiction frozen and U.S. persons are prohibited from engaging in transactions with them.

All of the designated parties are accused of being affiliated with the drug trafficking organization controlled by Daniel Barrera Barrera, or as he is commonly referred to as “El Loco” Barrera, and Pedro Oliveiro Guerrero, otherwise known as “Cuchillo.” These two individuals are amongst the most wanted criminals in Colombia. Both Barrera and Guerrero have been previously designated as SDNTKs. OFAC has alleged that Barrera and Guerrero have assisted the FARC in the illegal drug trade.

Thirty (30) people who allegedly served as front men for various business entities believed to have laundered drug money for Barrera and Guerrero were designated as SDNTKs in March 2010. The Colombian Popular Anti-Terrorist Army (ERPAC), a paramilitary drug trafficking organization, was also added to the list. In Central and South America, the list of SDNTKs is also known as the Clinton List, because the Kingpin Sanctions Regulations was promulgated under the administration of former U.S. President Bill Clinton.

These designations are just another example of how aggressive OFAC has been in enforcing counter narcotics sanctions against Columbia based individuals and entities they believe to be engaged in large scale narcotics trafficking. These designated parties will remain on this list until they seek to have the designation removed. That process can take many years, so designated parties should seek to remove their designation as soon as possible, lest they feel the consequences of these designations for many years to come.

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 or ferrari@ferrari-legal.com.

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Erich Ferrari

As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. With over 12 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals.