On March 18, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control sanctioned a key leader of Lopez Human Smuggling Organization (“HSO”), a Guatemala-based Transnational Criminal Organization (“TCO”) that was sanctioned by OFAC in July 2024. According to OFAC, Jumilca Sandivel Hernandez Perez was designated for smuggling thousands of illegal aliens from Guatemala and into the United States with the help of members of La Linea, a U.S.- sanctioned drug trafficking organization. According to OFAC, between September 2020 and 2023, Lopez HSO generated between $104 million and $416 million from their human smuggling operation, transporting most illegal aliens through Mexico and into New Mexico, Arizona, and California.
The designation was made pursuant to Executive Order 13581, as amended by EO 13863, for being a foreign person that has acted on behalf of a significant TCO. As a result of this designation, all property and interests in property within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more designated persons are also blocked, unless they are exempt or transactions are authorized by a general or specific license issued by OFAC.
In addition to the designation, on March 18, 2025, OFAC issued an alert to raise awareness of the risks posed by international cartels that were recently designated as Foreign Terrorist Organizations (“FTOs”) and Specially Designated Global Terrorists (“SDGTs”). The alert urges companies that operate in or with persons in high-risk jurisdictions to assess their compliance programs to ensure that they minimize the risk of transacting with members of these designated terrorist organizations.
The alert also confirms that the following eight cartels were designated on February 20, 2025 as FTOs and SDGTs: Tren de Aragua, Mara Salvatrucha (MS-13), Cártel de Sinaloa, Cártel de Jalisco Nueva Generación, Cártel del Noreste (formerly Los Zetas), La Nueva Familia Michoacana, Cártel de Golfo (Gulf Cartel), and Cárteles Unidos. These organizations were designated by the Department of State pursuant to Executive Order 14157, which was issued by President Trump on January 20, 2025. EO 14157 enables the U.S. government to impose counterterrorism sanctions on cartels, exposing them and their supporters to sanctions and civil or criminal penalties in the United States. According to the alert, foreign financial institutions that knowingly facilitate significant transactions for designated organizations also risk exposure to U.S. correspondent or payable-through account sanctions under EO 13224, as amended.
U.S. Department of Treasury Press Release | OFAC Alert