OFAC Designates Naranjo Under Kingpin Act

Alleged Medellin-based narcotics trafficker Carlos Mario Jimenez Naranjo (a.k.a. "Macaco") has been recently designated as a Specially Designated Narcotics Trafficker pursuant to Executive Order 12978 by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). In addition, OFAC also targeted seven companies and seven individuals accused of comprising Jimenez Naranjo's financial network.^[1]

According to OFAC Director Adam J. Szubin, "Jimenez Naranjo is among the most dangerous Colombian narcotics traffickers today. Today's designation serves notice to Macaco and his associates that the United States is committed to disrupting their network of illicitly-obtained assets in Medellin and elsewhere."^[2]

Naranjo was indicted on federal drug trafficking charges in the U.S. District Court for the District of Columbia in 2005 and in the Southern District of Florida in 2007. He is currently in Columbian custody pending extradition to the United States.^[3]

Among the individuals designated today were Rosa Edelmira Luna Cordoba, Naranjo’s wife, and Marco Julio Londono Vasquez. Cordoba and Vasquez are alleged to have acted as front persons through their positions as owners and managers for entities that are either owned or controlled by Jimenez Naranjo. Both Cordoba and Vasquez were also indicted on federal drug trafficking charges in the Southern District of Florida in 2007.^[4]

The companies designated by OFAC are located in or around Medellin, Colombia. Among these companies are: Inversiones Licom Ltda., which does business as Restaurante Angus Brangus in Medellin; Tejar la Mojosa S.A., a ceramic products company that operates in the Colombian state of Antioquia; and the cattle companies Administradora Ganadera el 45 Ltda. and Ganaderia Luna Hermanos Ltda., both located in Medellin.^[5]

This designation is part of the continuing effort by the Departments of the Treasury, Justice, State and Homeland Security to implement Executive Order 12978 of October 21, 1995; a measure whose purpose is to apply financial sanctions against Colombia's drug cartels. OFAC’s designation freezes assets held by designees who are subject to U.S. jurisdiction and bars all financial and commercial transactions by any U.S. person with a designated company and/or individual.^[6]

On December 3, 1999, the President signed into law the Foreign Narcotics Kingpin Designation Act (the “Kingpin Act”),21 U.S.C. § 1901-1908, 8 U.S.C § 1182.^[7] The related regulations are styled the "Foreign Narcotics Kingpin Sanctions Regulations.”^[8]

As mentioned above, The Kingpin Act freezes all property and interests in property, subject to U.S. jurisdiction, owned or controlled by significant foreign narcotics traffickers as identified by the President.^[9] Furthermore, the Kingpin Act freezes the property and interests in property, subject to U.S. jurisdiction, of foreign persons designated by the Secretary of 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, who are found to be: (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 person designated pursuant to the Kingpin Act; (2) owned, controlled, or directed by, or acting for or on behalf of, a person designated pursuant to the Kingpin Act; or (3) playing a significant role in international narcotics trafficking.^[10]

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[1] Press Release, United States Department of Treasury, Treasury Targets Medellin Drug Lord (Feb. 12, 200) (available at http://www.ustreas.gov/press/releases/hp821.htm.
[2] Id.
[3] Id.
[4] Id.
[5] Id.
[6] Id.
[7] The Foreign Narcotics Kingpin Designation Act, 21 U.S.C. § 1901-1908 (2008); 8 U.S.C. § 1182 (2008).
[8] 31 C.F.R. Part 598.
[9] 21 U.S.C. § 1901-1908 (2008).
[10] Id.