The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has added three new entities today to the SDN list by designation via the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”).

Those individuals and entities designated under the Kingpin Act are blocked from engaging in transactions with U.S. persons. Furthermore, any of their property and/or interests in property under U.S. jurisdiction is blocked.

The name given to these individuals and entities is that of a Specially Designated Narcotics Trafficker (“SDNT”). SDNTs are those individuals which OFAC accuses of significant international narcotics trafficking. In addition, those individuals and entities thought to be providing material support to such parties may also be designated as SDNTs.

The entities designated today by OFAC includes La Familia Michoacana, Los Zetas, and the Sinaloa Cartel.

These are some pretty big names. My only question is: why has it taken OFAC so long to designate these parties as SDNTs? Indeed, I have represented clients before OFAC who have been designated for their alleged material support of the Sinaloa Cartel, so it was strange to see them designated after all this time.

If you have reason to believe that you may have violated the Kingpin Act please contact the author at 202-467-3827 or by email at ferrari@ferrari-legal.com