As I mention about once a week on this blog, the United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has been very aggresive in designating individuals and entities under the The Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). On Monday they designated four (4) more individuals, all of whom are thought to be linked to drug trafficking activities inside of Mexico.

One hundred and forty eight (148) different individuals and entities have been designated as either SDNTK (“Specially Designated Narcotics Trafficking Kingpins”) or SDNT (“Specially Designated Narcotics Traffickers”) since the beginning of the year. To put this in perspective, only seventy five (75) individuals and entities were designated during that same stretch of time last year. That’s double what it was a year ago.

Another interesting point is that when looking through the designations from last year and comparing them to now, one sees a dramatic jump in the number and frequency of narcotics related designations and a dramatic decrease in the number and frequency of terrorist related designations.

One has to wonder if there are changes inside of OFAC that are coming from the top down refocusing the mission on cutting off the drug cartels rather than global terrorist networks. It might also have to do with the belief that the global drug trade is thought to fuel terrorist organizations around the world. Either way, the impact of Obama’s administration on OFAC is already very visible.