OFAC has updated its list of specially designated nationals to add 3 people as Specially Designated Narcotics Trafficking Kingpins (SDNTK) and amend the existing entry of Peruvian entity Shining Path to reflect that it is now also listed as a SDNTK, in addition to its previous designations as a Specially Designated Global Terrorist (SDGT) and under the Foreign Terrorist Organisations Sanctions Regulations (FTO). Listed people and entities have all of their assets within US jurisdiction frozen, and US persons are generally prohibited from doing business with them. The newly listed people are:

  1. Florindo Flores Hala
  2. Jorge Quispe Palomino
  3. Victor Quispe Palomino

In its press release, the US Treasury stated that “Since its founding over three decades ago, the Shining Path has evolved from a militant terrorist group to a criminal nacro-terrorist organization responsible for trafficking cocaine throughout South America”. The Treasury states that the group alleges it is “committed to Maoist ideals and is dedicated to the violent overthrow of the democratically elected Government of Peru”. The three people designated are said to be leaders of the Shining Path.

This action follows changes to OFAC’s SDN list late last month, which added 6 people and 3 entities as SDNTKs, and deleted the listings of 7 people and 7 entities listed in connection with Mexican pharmaceutical company Productos Farmaceuticos Collins attempting to evade sanctions, the first of which were listed in 2009 (US Treasury press release here).

The new listings are:

  1. Gustavo Bolivar Zapata
  2. Luis Bustamante Jaramillo
  3. Jose Guarin Loaiza
  4. Herman Medina Diaz
  5. Alexis Romero Rodrigeuz
  6. Walter Varela Victoria
  1.  Freezer Air Contractor SA
  2. Megayates LTDA
  3. Quality Autos SA

The US Treasury’s press release states that Mr Guarin Loaiza “is the head of a Colombian drug trafficking network that specializes in transporting cocaine shipments via “go-fast boats” – small, fast boats which can be difficult to detect and intercept – from the northern Colombian coast as well as Venezuela”. He is designated along with 5 associates of the Guarin Loaiza drug trafficking organisation, and Megayates LTDA, a maritime company belonging to Mr Varela Victoria that has materially assisted Mr Guarin Loaiza’s network through its own established distribution network. The 2 other companies designated are owned or controlled by Mr Guarian Loaiza.

This entry was posted in Terrorist Sanctions, USA by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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