May 5, 2025

United States sanctions oil smuggling network and issues alert to warn of Cartel-related oil smuggling schemes

On May 1, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated three Mexican individuals and two Mexico-based entities for their alleged involvement in a drug trafficking and fuel theft network linked to the Cartel Jalisco Nueva Generacion (“CJNG”).  According to OFAC, the network generates hundreds of millions of dollars per year for the CJNG, a group responsible for a significant proportion of fentanyl and other illegal drugs into the United States.  The CJNG was sanctioned in the United States in 2015 under the Narcotics Kingpin Designation Act and then again in 2021 under Executive Order 14059, which targets those involved in the proliferation of illicit drugs and their means of production.  On February 20, 2025, the U.S. Department of State also designated the CJNG as a Foreign Terrorist Organization and as a Specially Designated Global Terrorist.

The new designations were imposed pursuant to Executive Order 14059, which targets persons involved in the international proliferation of illicit drugs or their means of production, and pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters.  As a result of these designations, all property and interests in property of the designated person 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 blocked persons are also blocked.

In coordination with OFAC and the new designations, the Financial Crimes Enforcement Network (“FinCEN”) concurrently issued an alert to warn financial institutions of the efforts of Mexico-based cartels to smuggle stolen oil from Mexico across the U.S. southwest border.  According to FinCEN, several Mexico-based transnational criminal organizations participate in oil smuggling schemes, including the CJNG.  In the alert, FinCEN reports that fuel theft in Mexico has become the most significant source of non-drug revenue for the cartels.  The alert provides financial institutions with methodologies and financial typologies that cartels have used in their oil smuggling operations as well as common red flags that might indicate that a transaction is associated with an oil smuggling scheme.  FinCEN also urges financial institutions to be vigilant in their efforts to detect and identify suspicious activity and to report any transactions that might be related to an oil smuggling scheme.

U.S. Department of Treasury Press Release | FinCEN Alert