OFAC Goes After Juan Carlos Ramirez Abadia's Asset's

On October 10, The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added to its list of Specially Designated Narcotics Traffickers seven individuals and 14 companies tied to Colombian narcotics trafficker Juan Carlos Ramirez Abadia.^[1] Among those designated are key financial associates of Ramirez Abadia, including Diego and Tulio Alzate Jimenez, and a Colombian currency exchange and money remittance company, Cambios y Capitales S.A.^[2]

Juan Carlos Ramirez Abadia, who was identified as a Specially Designated Narcotics Trafficker by OFAC in August 2000, was arrested in Brazil on August 7, 2007.^[3]

Diego Uriel Alzate Jimenez, Luis Holmes Alzate Jimenez, and Tulio Hernando Alzate Jimenez are among the primary shareholders of Cambios y Capitales S.A., which is headquartered in Bogota.^[4] One of the brothers, Tulio Hernando Alzate Jimenez, was indicted on federal narcotics trafficking and money laundering charges in the Southern District of Florida in 1994.^[5]

The announcement marks OFAC's third action targeting the assets of Ramirez Abadia since 2006; in August 2006, OFAC designated the Colombian pharmaceutical distribution company Disdrogas Ltda. along with Ramirez Abadia's parents, who were managing the company on his behalf.^[6] In August of 2007 OFAC designated several of Ramirez Abadia's key lieutenants as well as a theme park and a paso fino horse breeding farm located near Cali, Colombia.^[7]

Being a specially designated narcotics trafficker is a designation that is defined in 31 C.F.R. § 598.314, wherein it states that the term means: Significant foreign narcotics traffickers;^[8] and Foreign persons designated by the Secretary of the Treasury, in consultation with the Attorney General, the Director of Central Intelligence, the Director of the Federal Bureau of Investigation, the Administrator of the Drug Enforcement Administration, the Secretary of Defense, and the Secretary of State, because they are found to be:^[9]

1. Materially assisting in, or providing financial or technological support for or to, or providing goods or services in support of, the international narcotics trafficking activities of a specially designated narcotics trafficker;^[10]
2. Owned, controlled, or directed by, or acting for or on behalf of, a specially designated narcotics trafficker; or ^[11]
3. Playing a significant role in international narcotics trafficking.[12]

Federal criminal defense attorney Douglas McNabb has previously discussed the transnational crime of drug trafficking here.

---

^[1] US Treasury Dep’t, Press Release, Treasury Targets Financial Empire of Colombian Trafficker, October 10, 2007, available at http://www.ustreas.gov/press/releases/hp600.htm (last visited October 11, 2007).
^[2] Id.
^[3] Id. He was previously indicted on federal drug trafficking charges in Colorado in 1994 and the Eastern District of New York in 1995 and 2004. In 2004, Colombia's North Valle drug cartel was indicted in the District of Columbia under the federal Racketeer Influenced and Corrupt Organizations Act.
^[4] Id.
^[5] Id.
^[6] Id.
^[7] Id.
^[8] 31 C.F.R. § 598.314(a).
^[9] Id., at §598.314(b).
^[10] Id., at §598.314(b)(1).
^[11] Id., at §598.314(b)(2).
^[12] Id., at §598.314(b)(3); Note to §598.314: Please refer to the appendices at the end of this chapter V for listings of persons determined to fall within this definition who have been designated pursuant to this part. Section 501.807 of this chapter V sets forth the procedures to be followed by persons seeking administrative reconsideration of their designation or who wish to assert that the circumstances resulting in designation no longer apply.