SECTION 1

Impact of the Colombian Drug Cartels Economic Sanctions Program

SECTION 2

Cali Cartel

SECTION 3

North Valle Cartel

SECTION 4

North Coast Cartel

APPENDIX A

Authorities

APPENDIX B

Designation Announcements and Charts
IMPACT REPORT

Economic Sanctions Against 

COLOMBIAN DRUG CARTELS

Office of Foreign Assets Control

U.S. Department of the Treasury

March 2007 

www.treas.gov/ofac 
DEPARTMENT OF THE TREASURY 

WASHINGTON, D.C. 20220 

STATEMENT FROM THE DIRECTOR OF THE 

OFFICE OF FOREIGN ASSETS CONTROL 

Treasury’s Office of Foreign Assets Control (“OFAC”) integrates regulatory, national security, 

investigative, enforcement, and intelligence elements towards a single goal: eff ective implementation of economic sanctions programs against foreign threats and adversaries. OFAC currently 

administers and enforces more than 30 economic sanctions programs pursuant to Presidential 

and Congressional mandates,1 targeting select foreign countries and regimes, terrorist organizations, proliferators of weapons of mass destruction, and narcotics traffickers. OFAC acts under 

general Presidential wartime and national emergency powers, as well as specific legislation, to 

prohibit transactions and freeze (or “block”) assets within the United States or in possession or 

control of U.S. persons, including their foreign branches. These programs are administered in 

conjunction with diplomatic, law enforcement and occasionally military action. Since 1995, the 

Executive Branch has developed an array of “targeted” sanctions programs that focus on drug 

cartels and traffickers, international terrorist groups, proliferators of weapons of mass destruction, members of hostile regimes, and other individuals and groups whose activities threaten 

U.S. interests. 

Narcotics traffickers operating on a global scale require an extensive support network, including procurement, logistics, transportation, communications, security, money laundering, and 

other facilitation. Disguising the sometimes vast profits derived from major drug operations 

requires the purchase of ostensibly legitimate enterprises capable of handling business on an 

international scale. These illicitly funded “corporate empires” can be extensive, complex, and 

undermine the integrity of financial systems. They are also one of the drug cartels’ greatest 

vulnerabilities. 

To combat the threats of violence, corruption, and harm posed by narcotics traffi ckers and their 

networks, President Clinton signed Executive Order 12978 in October 1995, declaring a national emergency with respect to significant foreign narcotics traffickers centered in Colombia. 

The impact of these sanctions has been significant and, at times, dramatic. When OFAC designates an individual or entity, any assets within the United States or the possession or control of 

a U.S. person anywhere in the world, must be frozen. Trade with or through the United States 

is cut off. Moreover, many non-U.S. businesses and banks have voluntarily severed all ties with 

individuals and entities that OFAC has listed. As a result, designated persons may lose access 

to their bank accounts outside the United States, disrupting their operations and freedom of access. Finally, in many cases, Colombian authorities have taken law enforcement actions against 

designated companies or properties after OFAC listed them. Collectively, these actions have 

1. Some of these programs are no longer in effect but still require some residual administrative and enforcement 

activities. 

III 
disrupted more than $1 billion worth of assets—in blockings, seizures, forfeitures, and the failure of enterprises—and economically isolated the individuals who own and manage the enterprises. The Director of the Office of National Drug Control Policy (“ONDCP”), in fact, stated 

that OFAC’s efforts have resulted in “the forfeiture of billions of dollars worth of drug-related 

assets.” 

This report reviews the SDNT program’s achievements over the past 11 years, as it has targeted 

the leaders of Colombia’s Cali, North Valle, and North Coast drug cartels. It is our hope that 

the report will provide a useful window into the history and achievements of this program, as 

well as lessons for refining sanctions targeting and implementation in the future in this and 

other programs. 

 Adam J. Szubin

 Director

 Office of Foreign Assets Control 

IV 
CONTENTS 

STATEMENT FROM THE DIRECTOR OF THE OFFICE OF FOREIGN 


ASSETS CONTROL ............................................................................................................................ III


OVERVIEW OF SDNT COLOMBIA PROGRAM............................................................................. 1


SECTION 1: IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC 


SANCTIONS PROGRAM ................................................................................................................... 5


SECTION 2: CALI CARTEL................................................................................................................ 15


RODRIGUEZ OREJUELA Organization ................................................................................................................17

SANTACRUZ LONDOÑO Organization ..............................................................................................................27

HERRERA BUITRAGO Organization ......................................................................................................................31

VALENCIA TRUJILLO Organization .......................................................................................................................35

SECTION 3: NORTH VALLE CARTEL.............................................................................................. 41


URDINOLA GRAJALES Organization.....................................................................................................................43

HENAO MONTOYA Organization ...........................................................................................................................47

RAMIREZ ABADIA Organization ..............................................................................................................................51

PATIÑO FOMEQUE Organization ............................................................................................................................55

MONTOYA SANCHEZ Organization. ....................................................................................................................59

GOMEZ BUSTAMANTE Organization ..................................................................................................................63

PUERTA PARRA and HERNANDEZ ZEA Organization .............................................................................67

RENTERIA MANTILLA Organization ...................................................................................................................71

GRAJALES LEMOS Organization ...............................................................................................................................77

VARELA Organization .......................................................................................................................................................83

CANO CORREA Organization .....................................................................................................................................87

SABOGAL ZULUAGA Organization ........................................................................................................................91

SECTION 4: NORTH COAST CARTEL ............................................................................................ 95


NASSER DAVID Organization ......................................................................................................................................97

APPENDIX A: AUTHORITIES............................................................................................................ 102


International Emergency Economic Powers Act (“IEEPA”) ...........................................................................102

Executive Order 12978 ........................................................................................................................................................107

Code of Federal Regulations- Title 31, Part 536 (31 CFR 536) .....................................................................110

18 U.S.C.§ 3571 ........................................................................................................................................................................123

APPENDIX B: DESIGNATION ANNOUNCEMENTS AND CHARTS......................................... 124


V 
ACRONYMS USED IN THIS IMPACT REPORT


a.k.a. Also known as 

AUC United Self Defense Forces of Colombia (Autodefenses Unidas de 

Colombia) 

CFR Code of Federal Regulations 

DEA 

E.O. Executive Order 

f.k.a. Formerly known as 

FBI Federal Bureau of Investigation 

FNK Foreign Narcotics Kingpin 

ICE U.S. Immigration and Customs Enforcement 

n.k.a. Now known as 

Offi

ONDCP Office of National Drug Control Policy 

RICO Racketeer Infl

SDGT 

SDN Specially Designated Nationals 

SDNT fickers 

SDNTK fi

USC United States Code 

Drug Enforcement Administration 

IEEPA International Emergency Economic Powers Act 

OFAC ce of Foreign Assets Control 

uenced and Corrupt Organization Act 

Specially Designated Global Terrorist 

Specially Designated Narcotics Traf

Specially Designated Narcotics Traf ckers Kingpins 

ACRONYMS OF BUSINESS TYPES


(Aruban Exempt Corporation) 

Cia. Compañia (Company) 

E.U. Empresa Unipersonal (Sole Proprietorship) 

Ltda. Limitada (Limited) 

S. de H. Sociedad de Hecho (De Facto Partnership) 

S. en C. Sociedad en Comandita (Limited Partnership) 

S.A. Sociedad Anónima (Corporation) 

) 

S.C.A. Limited Partnership by Shares) 

S.C.S. Sociedad en Comandita Simple (Limited Partnership) 

A.V.V. Aruba Vrijgestelde Vennootschap

S.A. de C.V. Sociedad Anónima de Capital Variable (Variable Capital Company

Sociedad en Comandita por Acciones (

VI 
OVERVIEW OF


SDNT COLOMBIA PROGRAM


President Clinton issued Executive Order 12978, “Blocking Assets and Prohibiting Transactions 

with Significant Narcotics Traffickers,” on October 21, 1995, under authority of the International Emergency Economic Powers Act (“IEEPA”). The Executive Order found that the activities 

of significant foreign narcotics traffickers centered in Colombia and the unparalleled violence, 

corruption, and harm that they caused, constituted an unusual and extraordinary threat to the 

national security, foreign policy and economy of the United States. The Executive Order called 

upon the Treasury to target Colombian drug cartels using financial sanctions. Under this 

authority, OFAC launched the Specially Designated Narcotics Traffi ckers (“SDNT”) program 

on October 24, 1995. The objectives of the SDNT 

program are to isolate and incapacitate the businesses and agents of the Colombian drug cartels by 

publicly exposing them, freezing their assets, and 

denying them access to the financial system and to 

the benefits of trade and transactions involving U.S. 

businesses and individuals.2 

SDNT LIST 

OFAC’s principal tool for implementing these 

sanctions against narcotics traffickers is its list of 

Specially Designated Narcotics Traffi ckers.3

 OFAC 

works in close consultation with the U.S. Departments of Justice and State to develop this list. It 

names not only the principal leadership of targeted 

drug cartels, but also their businesses and associates. At the outset of the program, the list included 

the four Cali drug cartel kingpins named in the 

Annex to Executive Order 12978, Gilberto and 

Miguel RODRIGUEZ OREJUELA, Jose SANTA 

CRUZ LONDOÑO, and Helmer HERRERA 

BUITRAGO. Beginning in 1998, OFAC expanded 

the SDNT list beyond the Cali drug cartel and it 

EXAMPLE OF 

SDNT LISTING 

( / ). 

Please refer to OFAC’s website for complete 

listings www.treas.gov ofac

2. The Order further prohibits any transaction or dealing by a U.S. person or within the United States in property or 

interests in property of persons designated pursuant to the Order, and any transaction that evades or avoids, has 

the purpose of evading or avoiding, or attempts to violate, the prohibitions contained in the Order. Th is impacts 

trade transactions (involving, for example, letters of credit) as well as accounts and other assets. 

3. Another narcotics sanctions program was created on December 3, 1999, when the Foreign Narcotics Kingpin 

Designation Act (“Kingpin Act”) was signed in to law. The Kingpin Act was modeled by Congress after the highly 

effective Colombian SDNT program, targeting the activities of significant foreign narcotics traffi ckers and their 

organizations on a worldwide basis. As with E.O. 12978, OFAC is the lead agency for implementation of the 

Kingpin Act. Those designated under the Colombian SDNT program are listed as “[SDNT]” on OFAC’s “Specially 

Designated Nationals and Blocked Persons” list and those designated under the Kingpin Act are referred to as 

Specially Designated Narcotics Traffickers Kingpins “[SDNTK]” to differentiate the two programs. Th is report 

addresses only the Colombian SDNT program. 

1 
now includes the leaders, associates, and businesses of other Colombian drug cartels, such as 

the North Valle and North Coast drug cartels. 

As of December 31, 2006, the SDNT list includes 527 companies and 815 individuals involved 

in the ownership or management of the 21 Colombian drug cartel leaders’ business empires. 

The businesses named as SDNTs range across industries and include drugstore chains, a supermarket chain, pharmaceutical laboratories, airlines, a medical clinic, hotels, restaurant service 

companies, radio stations, sports teams, communications companies, construction fi rms, real 

estate firms, investment and financial companies, consulting companies, off -shore fi rms, horse 

breeding farms and other agricultural businesses, mining operations, maritime agencies, and a 

department store. 

CRITERIA 

Companies and individuals may be identified as SDNTs and placed on the SDNT list if they are 

determined to: 

•	 play a significant role in international narcotics trafficking centered in Colombia; 

•	 materially assist in or provide financial or technological support for, or goods or services in 

support of, the narcotics trafficking activities of persons designated in or pursuant to the 

executive order; or 

•	 be owned or controlled by, or act for on or behalf of, persons designated in or pursuant to 

Executive Order 12978. 

BLOCKING 

U.S. individuals and companies are prohibited from engaging in unlicensed transactions, including any commercial or financial dealings with any of the SDNTs. Upon designation as an 

SDNT, all SDNT assets within the United States or in the possession or control of U.S. persons, 

including their foreign branches, are blocked. This includes bank accounts and other property 

and interests in property. 

LICENSING AUTHORITY 

When determined to be in the interest of U.S. foreign policy, OFAC may license activities to 

mitigate the effect of sanctions. For example, after OFAC designated Drogas La Rebaja, Colombia’s largest chain of drugstores, the Colombian Government seized the company and appointed 

a receiver to manage its more than 449 stores across the country. OFAC then established a 

licensing policy to allow U.S. suppliers to engage in transactions with these companies, thus 

preserving their commercial viability under Colombian Government control. 

LEGAL CHALLENGES 

OFAC sanctions in U.S. courts have been consistently upheld when challenged by SDNTs. Th e 

SDNT company Copservir filed a lawsuit in the U.S. District Court for the District of Columbia 

in April 1998 against the Secretary of the Treasury and the Director of OFAC. Copservir alleged violations of the Administrative Procedures Act, federal forfeiture laws and the U.S. Constitution. In March 1999, the court granted the defendants’ motion and dismissed Copservir’s 

2 
complaint. The court’s decision was upheld in March 2000 in the U.S. Court of Appeals for the 

D.C. Circuit. The U.S. Supreme Court subsequently denied Copservir’s petition for certiorari. 

Cooperativa Multiactiva v. Newcomb, No. 98-0949-LFO, 1999 U.S. Dist. Lexis 23168 (D.D.C. 

1999); aff ’d 221 F.3d 195 (D.C. Cir. 2000); cert. denied, 531 U.S. 817 (2000). 

PENALTIES 

Violations carry criminal penalties of up to $500,000 per violation for corporations and 

$250,000 for individuals, as well as imprisonment of up to 20 years. Civil penalties of up to 

$50,000 per violation may be imposed. 

3 
4 MAP OF COLOMBIA Cities identify locations of Colombian drug cartel businesses discussed in this report.
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

IMPACT OF THE COLOMBIAN DRUG CARTELS 

SECTION 1 ECONOMIC SANCTIONS PROGRAM 

“[T]he U.S. pressure is reaching unexpected extremes. The largest international 

suppliers refuse to deal with us. The banks have closed down our accounts. It is 

impossible for us to pay our obligations.” 

– As told to Colombian television in 1996 by Humberto RODRIGUEZ MONDRAGON—son of Cali 

drug cartel leader Gilberto RODRIGUEZ OREJUELA—referring to their business enterprises in

Colombia.

Economic sanctions are employed to financially and commercially impair and impede, and to 

ultimately isolate and incapacitate narcotics traffickers, their supporters, and business empires. 

OFAC designations help publicly identify drug traffickers and their business empires and are 

often accompanied or followed by U.S. law enforcement actions and Government of Colombia 

asset seizures and forfeitures. Additionally, the threat of designation often deters top managerial talent—needed to operate and manage the often complex drug traffi cking money laundering operations and business empires—from working for the drug traffickers and their business 

empires. As of December 2006, OFAC has identified drug traffickers’ assets under the Specially 

Designated Narcotics Traffickers program valued at more than $1 billion. 

Once designated, most narcotics traffickers try to evade and avoid the financial and commercial 

restrictions placed upon them and their businesses, by working through others or creating shell 

companies through which to control and conduct their business.4

 Initially, sanctions impair 

and impede their ability to function; however, as OFAC continues to identify and designate supporters, businesses, and front companies, the drug cartel organizations face increasing isolation 

and incapacitation. 

“We have been several years without sponsorships...we have more than one million dollars frozen that we won in international sports competitions.” 

– Colombian news magazine quoting the president of the professional Colombian soccer team 

America de Cali, in February 2006—the soccer team was designated in June 1999 as an SDNT of Cali

cartel leaders Miguel and Gilberto RODRIGUEZ OREJUELA. 

At the outset of a designation, all assets within the United States of a designated party are 

blocked.5

 Additionally, any transactions with a designated person that are caught in the United 

States are blocked. OFAC actions in 2006 alone resulted in multi-million dollar blockings in accounts and real property in the United States, stemming from focused, in-depth OFAC investigations of Colombia’s North Valle drug cartel’s business and financial networks. SDNT companies and individuals face real costs as a result of being denied access to banking services in the 

4. See text box at the end of this section that identifies the Colombian drug cartels and the organizations that comprise them. 

5. Assets within the United States include those in the possession or control of U.S. persons, including foreign 

branches. 

IMPACT REPORT 5 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

United States. An even more significant impact can come from the severing of trade with the 

United States. Some companies named as SDNTs that were heavily dependent upon trade with 

SECTION 1 U.S. businesses have been forced out of business. 

OFAC’s designation of companies and individuals tied to Colombia’s drug cartels often prompts 

non-U.S. parties to take similar actions. Many non-U.S. banks have, as a routine practice, 

closed the accounts of all persons (individuals and entities) on the OFAC SDNT list. For 

example, many Latin American banks have 

advised OFAC that they rely on the SDNT list 

as part of their due diligence in identifying 

high-risk account holders. Non-U.S. companies 

that have no obligation to comply with U.S. 

sanctions often refuse to work for, supply or 

otherwise do business with SDNT commercial 

enterprises or employ persons on the SDNT list, 

thereby further isolating them commercially. 

As a result, designated persons are impeded 

from functioning effectively in the legitimate 

economy or business world. 

As of December 2006, public records in Colombia and other countries show that hundreds 

of companies named as SDNTs have dissolved, 

are in the process of dissolution, or are inactive. 

As some SDNT companies attempt to continue their operations through changes to their 

company names, corporate structure, or other 

evasion schemes, OFAC has pursued them for 

designation as well. 

LEGAL CHALLENGES 

IN COLOMBIA 

, , 

to 

,

In Colombia, the courts have upheld a Colombian bank’s right to deny service to high-risk 

account holders, such as SDNTs. In March 

2001 Copservir a pharmacy chain owned by 

the RODRIGUEZ OREJUELA drug traffi cking organization, filed a lawsuit in the circuit 

court in Cali, Colombia against six Colombian 

banks for refusing to provide banking services 

Copservir because of its status on OFAC’s 

SDNT list. In May 2003, the Colombian Constitutional Court ruled in favor of the banks’ 

right to refuse such services Eff ectively, SDNT 

businesses are forced out of the formal fi nancial 

sector—depriving them the use of bank services to pay for goods and payroll, receive payment 

for goods enjoy credit lines, and issue letters of 

credit to foreign suppliers. These businesses are 

often forced to work on a cash basis. 

“[The OFAC list] is the most powerful tool the United States has against the traffi ckers.” 

– As one Colombian cartel source described OFAC designations. 

Throughout the sanctions process, OFAC cooperates with law enforcement agencies. Its designations often provide a picture of the cartels’ support networks, helping further inform U.S. 

law enforcement actions and a variety of foreign government enforcement actions geared to 

disrupting and dismantling the financial infrastructure of the Colombian drug cartels. Companies designated as SDNTs by OFAC have concurrently or subsequently been investigated by law 

enforcement authorities in Colombia, Panama, Ecuador, Costa Rica, Peru, Spain, and Aruba. 

In Colombia, the government has initiated numerous asset forfeiture cases against many of the 

6 IMPACT REPORT 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

SDNT companies.6 

SECTION 1 “[The OFAC] list is tough.” 

– A complaint made to U.S. authorities by an SDNT principal individual. Because of OFAC’s list, his 

companies were going out of business, his grown children could not get a job, and it became hard for 

him to pay for their university studies. 

The Department of State also uses the SDNT list. It has denied U.S. visas and revoked existing 

U.S. visas to individuals named as SDNTs, which means that family members and other designated associates may be deprived of high-priced and highly-prized U.S. college educations as 

well as the amenities and entertainments that their wealth might otherwise aff ord. 

Individuals are deterred from associating with designated narcotics traffickers and their businesses, in part, because their reputations could be ruined, and in part because by doing so, they 

also might be designated. An SDNT designation of an individual in Colombia and elsewhere 

carries an overwhelming social stigma that tarnishes or ruins personal reputations and forecloses many financial and commercial opportunities. Designation of enterprises has the additional effect of impairing their ability to hire, train, and retain the top talent needed to operate 

and manage their often complex narcotics trafficking operations and business empires, as many 

talented managers and personnel refuse to work for them. For example, in November 2006, 

within 72 hours of the designation of the soccer team Cortulua, the team’s president and three 

of its five board members resigned, sponsors withdrew their support, and key business partners 

publicly announced the severing of all commercial ties with the team. 

As previously mentioned, sanctions initially impair and impede the ability of narcotics traffi ckers and their enterprises to function, but as OFAC continues to identify and designate supporters, businesses, and front companies, the drug cartel organizations face increasing isolation and 

incapacitation. This is best illustrated by the actions OFAC has taken over eleven years against 

the RODRIGUEZ OREJUELA narcotics trafficking organization—part of the Cali drug cartel in 

Colombia—that helped dismantle this organization. 

Cali Cartel – The RODRIGUEZ OREJUELA Organization 

“What was suffered was more than what was enjoyed.” – As quoted by one RODRIGUEZ OREJUELA family member, referring to the effect of being placed 

on OFAC’s SDNT list. 

In October 1995, President Clinton named the two RODRIGUEZ OREJUELA brothers Miguel 

and Gilberto, in the Annex to Executive Order 12978. During the next eleven years, OFAC 

designated more than 200 front companies, including a prominent Colombian drugstore chain 

Drogas La Rebaja—and its successor businesses, which had been created with the purpose of 

6. In December 2002, Law 793 replaced the existing 1996 legislation (Law 333) that governed asset forfeiture in 

Colombia. Law 793 allows Colombian authorities to better enforce asset forfeiture actions in Colombia against 

the illicit assets of Colombian drug cartel leaders. The Colombian Government has moved swiftly to pursue more 

complex asset forfeiture investigations against the Cali and North Valle drug cartels pursuant to Law 793. 

IMPACT REPORT 7 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

evading the original designation—and key family members and business associates who managed the business enterprises owned by the RODRIGUEZ OREJUELA organization. 

SECTION 1 

In September 2004, the Colombian authorities seized Drogas La Rebaja, which they estimated 

to be worth over $200 million. 

In a September 2006 agreement with the U.S. Government, Miguel and Gilberto RODRIGUEZ 

OREJUELA and 28 SDNT individuals—all key family members associated with the RODRIGUEZ OREJUELA drug trafficking organization—agreed to forfeit their interests in all narcotics-related entities world-wide up to $2.1 billion,7

 which mainly consisted of the hundreds of entities designated by OFAC since 1995.8

 The entities addressed by the agreement will be forfeited 

in the jurisdiction in which they are located, primarily Colombia. The agreement also commits 

the family members to assist the U.S. and Colombian Governments in any future forfeiture actions. In connection with this agreement, Miguel and Gilberto RODRIGUEZ OREJUELA also 

pled guilty to all federal drug trafficking and money laundering charges in the Southern District 

of Florida and the Southern District of New York. 

Cali Cartel – the VALENCIA TRUJILLO Organization 

“The list demonizes you in Colombia. The worst part is for the family. Th e 

banks simply close their doors to you.”

 – A major Colombian narcotics traffi cker 

Designations of individuals and entities in the VALENCIA TRUJILLO organization provide additional examples of the impact of the sanctions program. 

Joaquin Mario VALENCIA TRUJILLO, head of the VALENCIA TRUJILLO organization, 

employed family members, including his brother, Guillermo, and several sisters—to run his 

enterprises.9

 He and his family were once considered to be reputable business persons both 

in Colombia and internationally. Since designation, the VALENCIA TRUJILLO organization 

has been unable to liquidate assets or sell enterprises to third parties. Many of the designated 

businesses were either seized by Colombian authorities or forced to close because of the OFAC 

designation. All family members involved in the enterprise have been designated and face the 

same sanctions prohibitions. 

One of the most illustrative examples of the crippling effect that an OFAC designation can 

have on a business enterprise involves Criadero La Luisa, a horse breeding farm, which OFAC 

designated in March 2003. The farm maintained about 300 paso fi no horses—some of which 

7. The $2.1 billion figure is derived from the estimated worth of the 200,000 kilograms of cocaine that Gilberto and 

Miguel RODRIGUEZ OREJUELA admitted they imported into the United States and/or distributed in the United 

States since 1990. 

8. See text box, “Prepared Remarks on the Acceptance of Plea Agreements and 30-year Sentences by the RODRIGUEZ OREJUELA Brothers,” by Adam Szubin, Director Office of Foreign Assets Control. 

9. These companies include an industrial paper company, a real estate management company, a financial loan company, and a maritime agency. See the section on the VALENCIA TRUJILLO organization for further details. 

8 IMPACT REPORT 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

were estimated to be worth more than $1 million a piece. Prior to designation, U.S. customers accounted for the majority of the farm’s horse sales and breeding services. Shortly after the 

enterprise’s designation, OFAC sent out alert letters to the U.S. horse breeding industry, which SECTION 1 

effectively shut down all U.S. business relationships and hindered other lucrative non-U.S. sales. 

North Valle Cartel – Examples of the RENTERIA MANTILLA, GRAJALES 

LEMOS, PUERTA PARRA and HERNANDEZ ZEA, and VARELA Organizations 

Since 2000, OFAC also has focused its sanctions investigations on Colombia’s North Valle drug 

cartel. The impact of these designations is beginning to take hold. For example, in the past two 

years more than $160 million in assets have been affected in a series of actions against four of 

the more than 14 North Valle drug cartel leaders. 

In March 2005, concurrently with the designation of Carlos Alberto RENTERIA MANTILLA 

(a.k.a. “Beto” RENTERIA) , OFAC blocked approximately $1 million worth of assets belonging 

to Beto RENTERIA and his family, including bank accounts, cars, and real estate in Boston, 

Massachusetts and Miami, Florida. On May 11, 2005, OFAC designated Raul Alberto GRA 

JALES LEMOS and in the following days, Colombian authorities arrested Raul GRAJALES 

LEMOS and several of his SDNT associates on charges of money laundering. 

In February 2005, five months after its designation by OFAC, the Colombian authorities seized 

the airline, Intercontinental de Aviacion, controlled by the PUERTA PARRA and the HERNANDEZ ZEA organizations of the North Valle drug cartel. The seizure included the airline’s fl eet 

of six airplanes worth approximately $21 million, according to a Colombian source familiar 

with the airline. 

In June 2005, shortly after having been designated by OFAC, Colombian authorities seized the 

GRAJALES LEMOS organization-controlled Grupo Grajales—one of the largest agricultural 

conglomerates in the country that includes a winery and fruit companies, as well as real estate 

and other assets. The authorities estimated the worth of the conglomerate to be worth over 

$100 million. 

In March 2006, a Colombian newspaper announcement placed by the department store chain 

Casa Estrella—controlled by the RENTERIA MANTILLA and GRAJALES LEMOS organizations and named as an SDNT in May 2005—stated that the chain would be closing its Barranquilla store. The department store chain’s closing was due to the fact that it did not have fi nancial services and checking accounts, could not accept credit or debit cards, and some national 

suppliers refused to sell products to the chain. Subsequently, in August 2006, the Colombian 

Government seized the Casa Estrella department store chain, along with other companies and 

properties. The real property alone had an estimated worth of approximately $38.5 million 

In June 2006, OFAC named five companies in Panama as SDNTs, including Cipe Investments 

Corporation, Elizabeth Overseas, Inc., Karen Overseas, Inc., Kattus II Corporation, and Rixford 

IMPACT REPORT 9 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

Investment Corporation. All of these companies had financial ties to the RENTERIA MANTILLA and GRAJALES LEMOS organizations in Colombia through associates in Casa Estrella. SECTION 1 Shortly afterwards, the Panamanian press reported that judicial authorities initiated a money 

laundering investigation against the fronts. 

In September 2006, Colombian authorities seized properties and companies belonging to 

SDNT individual Eduardo RESTREPO VICTORIA, a key associate of the VARELA organization. Colombian authorities valued the seized assets at more than $22 million. 

In November 2006, within 72 hours of the designation of the soccer team Cortulua, the team’s 

president and three of its five board members resigned, sponsors withdrew their support, and 

key business partners publicly announced the severing of all commercial ties with the team. 

COLOMBIA ECONOMIC SANCTIONS PROGRAM 

j , 

j

j

IMPACTS AND IMPLICATIONS OF THE SDNT 

Economic sanctions are employed to expose, impair and impede, and to isolate and incapacitate 

narcotics traffickers and their support structures. In the Specially Designated Narcotics Traffi ckers 

program, there have been five major impacts on and implications for the drug traffi cking groups and 

their business empires. These are: 

Asset Blocking in the United States. Any money, assets, or property of a designated person 

within U.S. urisdiction are blocked and any subsequent transactions which are caught are blocked

depriving the designee use of these assets. 

Isolation from U.S. Financial and Commercial Markets. Financial transactions and commercial 

dealings by a U.S. person with designated persons are prohibited, barring the designee from the 

benefits of the U.S. financial and commercial systems. 

Isolation from Non-U.S Financial and Commercial Markets. Many banks outside U.S. urisdiction refuse to hold funds, provide any type of financial services for the SDNT or the SDNT’s 

commercial enterprises, and have closed their bank accounts. Businesses outside of U.S. jurisdiction also may refuse to work with the SDNT or supply or do business with the SDNT’s commercial 

enterprises. 

Law Enforcement. The SDNT list often provides a picture of the cartels’ support networks, helping 

inform U.S. law enforcement actions and foreign seizures and forfeitures geared to disrupting and 

dismantling the financial and commercial infrastructure of the Colombian drug cartels. 

Deterrence. Anyone—family members, friends, and associates—who is employed by the narcotics 

traffickers or controls or manages their business empires is sub ect to designation under E.O. 12978. 

The threat of designation and the reputational risk often deters top managerial talent—needed to 

operate and manage the often complex drug trafficking money laundering operations and business 

empires—from working for designated drug traffickers and their business empires. 

10 IMPACT REPORT 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

SECTION 1 

IMPACT REPORT 11 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

SECTION 1
 OVERVIEW OF 

DRUG CARTEL GROUPS 

10

, 

, 

, 

• 

• 

• 

• 

)

) 

10. 

tel. 

COLOMBIA’S DRUG CARTELS AND 

For ease of reference, set forth below is a brief summary of the Cali, North Valle, and North Coast drug cartels and their principal component organizations. More detailed descriptions of these groups and organizations are set forth in Sections 2, 3, and 4, respectively, of this report and additional information can be found 

in Appendix A and B. 

Cali Cartel 

The Cali drug cartel is based in the city of Cali, Colombia. Led by Gilberto RODRIGUEZ OREJUELA

Miguel RODRIGUEZ OREJUELA, Jose SANTACRUZ LONDOÑO, and Helmer HERRERA BUITRAGO

the Cali drug cartel orchestrated the manufacture of hundreds of tons of cocaine in Colombia in the early 

1980s, which were then moved through the Caribbean and Mexico to U.S. markets. By the early 1990s, the 

Cali drug cartel was responsible for approximately 80 percent of the world’s cocaine supply. Actions taken 

by U.S. and Colombian authorities led to the surrender or arrest of the RODRIGUEZ OREJUELA brothers

SANTACRUZ LONDOÑO, HERRERA BUITRAGO, and other Cali drug cartel leaders between 1994 and 

1996, and the dismantling of the Cali drug cartel’s trafficking infrastructure. Colombian law enforcement 

and OFAC actions led to the disruption of the business empires built with their illicit drug traffi cking proceeds. The principal individuals designated by OFAC are: 

Gilberto Jose & Miguel Angel RODRIGUEZ OREJUELA 

Jose SANTACRUZ LONDOÑO 

Helmer HERRERA BUITRAGO 

Joaquin Mario & Guillermo VALENCIA TRUJILLO 

North Valle Cartel 

Based in the northern part of Colombia’s Valle del Cauca region, the North Valle drug cartel rose to prominence in the 1990s. It began as a splinter group of the Cali drug cartel following the arrest of Cali drug cartel 

leaders Miguel and Gilberto RODRIGUEZ OREJUELA in 1995. Through its brutal tactics and alliances with 

narco-terrorist organizations such as the United Self Defense Forces of Colombia (“AUC” , the North Valle 

drug cartel was able to export over one million pounds of cocaine, worth an estimated $10 billion, to the 

United States via Mexico between 1990 and 2004. In 2004, the Drug Enforcement Administration (“DEA”

described the North Valle drug cartel as the “largest and most powerful drug cartel in Colombia” and stated 

that the North Valle drug cartel was responsible for one-third to one-half of the cocaine that reaches American shores. The principal individuals designated by OFAC are: 

Until the early 1990s, U.S. and Colombian authorities had focused their efforts on the violent Medellin drug carBy the end of 1993, the heads of the Medellin drug cartel were either dead or in jail—Medellin Cartel kingpin 

Pablo Escobar Gaviria was killed in a shootout with Colombian police in late 1993, the Ochoa Vasquez brothers 

had turned themselves in to Colombian authorities, Gonzalo Rodriguez Gacha had been killed (1989) and their 

financial empires were either destroyed, seized or in complete disarray. The focus on the Medellin drug cartel allowed the Cali drug cartel to quietly grow in power and influence and establish the financial networks that would 

eventually attract the attention of U.S. authorities prior to 1995. 

12
 IMPACT REPORT 
IMPACT REPORT  IMPACT OF THE COLOMBIAN DRUG CARTELS ECONOMIC SANCTIONS PROGRAM 

SECTION 1


• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

j

• 

Ivan & Julio Fabio URDINOLA GRAJALES 

Arcangel de Jesus HENAO MONTOYA 

Juan Carlos RAMIREZ ABADIA 

Victor Julio PATIÑO FOMEQUE 

Diego Leon MONTOYA SANCHEZ 

Luis Hernando GOMEZ BUSTAMANTE 

Gabriel PUERTA PARRA and Luis Antonio HERNANDEZ ZEA 

Carlos Alberto RENTERIA MANTILLA 

Raul Alberto GRAJALES LEMOS 

Wilber VARELA 

Jhon Eidelber CANO CORREA 

Orlando SABOGAL ZULUAGA 

North Coast Cartel 

Various drug trafficking organizations based along the northern coast of Colombia have operated maritime 

drug smuggling routes for the Medellin, Cali, and North Valle drug cartels since the 1970s. One major 

North Coast drug trafficker, Julio Cesar NASSER DAVID, ran a drug and money laundering group based 

out of the city of Barranquilla, Colombia. Since the 1970s, NASSER DAVID’s organization has smuggled 

multi-ton quantities of cocaine and mari uana to the United States via commercial shipments and maritime 

vessels. This organization was seriously impaired as a result of NASSER DAVID’s arrest in 1997, OFAC sanctions since May 1998, and NASSER DAVID’S subsequent death in 2001. The principal individual designated 

by OFAC is: 

Julio Cesar NASSER DAVID 

IMPACT REPORT 13

14 MAP OF COLOMBIA Cities in bold mark locations of Cali drug cartel businesses.
IMPACT REPORT  CALI CARTEL 

CALI CARTEL


During the time the Colombian National Police were engaged in their campaign to bring down 

the Medellin drug cartel in the late 1980s and early 1990s, a group of powerful drug traffi ckers 

from Cali, Colombia were building what was to become one of the most prolific and successful criminal enterprises in recent history. Led by Gilberto RODRIGUEZ OREJUELA, Miguel SECTION 2 

RODRIGUEZ OREJUELA, Jose SANTACRUZ LONDOÑO, and Helmer HERRERA BUITRA 

GO, the Cali drug cartel trafficked approximately 80 percent of the world’s cocaine by the early 

1990s. At the height of their power, the Cali drug cartel’s annual revenue reached an estimated 

$7 billion. 

Working collaboratively, the four principal Cali drug cartel leaders formed an organization 

that handled both the entire chain of narcotics trafficking—such as raw material procurement, 

processing, delivery, wholesaling, retailing—and subsequent laundering of the illicit proceeds. 

While the Cali drug cartel consolidated the production and distribution of illicit narcotics into 

one operation, the proceeds from these operations were distributed separately among four 

major organizations, each headed by one of the four principals. Each organization largely invested, developed, and managed its own separate business empire. Each business empire grew 

to include a vast network of companies, run by family members and a cadre of trusted business 

associates in Colombia, Ecuador, Panama, Peru, Spain, and Venezuela. The Cali drug cartel 

headquartered its business empire in and around Cali, Colombia, developing a political, social, 

and business base of support. 

The Cali drug cartel’s operations began to unravel in the mid-1990s with a series of U.S. law 

enforcement indictments, OFAC designations, and Colombian Government actions. Law 

enforcement uncovered the various drug trafficking operations, while OFAC commercially 

isolated the drug cartel’s business empires by identifying and designating their companies and 

principal managers. Ultimately, it was the sheer size of the narcotics traffi cking enterprise that 

made its operations vulnerable. 

Sanctions against the Cali drug cartel began with the naming of all four Cali drug cartel leaders 

by the President in the Annex to Executive Order 12978 on October 21, 1995. 

As will be explained in more detail below, OFAC’s continued sanctions pressure was a key 

impetus to the guilty pleas of Miguel and Gilberto RODRIGUEZ OREJUELA in U.S. Federal Court in Miami, Florida on September 26, 2006. Miguel and Gilberto RODRIGUEZ 

OREJUELA admitted to over two decades of drug trafficking and to laundering the proceeds 

through the network of companies that OFAC had targeted in over a dozen investigations over 

the past decade. The brothers were sentenced to 30 years in jail and ordered to forfeit up to $2.1 

billion in assets. 

CALI CARTEL 15 
IMPACT REPORT  CALI CARTEL 

RODRIGUEZ OREJUELA ORGANIZATION 

Background: 

The Cali drug cartel was formed in the 1970s by Gilberto and Miguel RODRIGUEZ OREJUELA 

and Jose SANTACRUZ LONDOÑO. While Gilberto and Miguel RODRIGUEZ OREJUELA SECTION 2 

were initially involved in other criminal activities such as kidnappings in the late 1960s, they 

gradually expanded into smuggling cocaine base from Peru and Bolivia to Colombia for conversion into powder cocaine. By the late 1970s, the RODRIGUEZ OREJUELA brothers were 

known as major transportation specialists who moved cocaine out of Colombia into the United 

States and other countries. Gilberto RODRIGUEZ OREJUELA was responsible for the strategic, long-term planning of the organization. Miguel RODRIGUEZ OREJUELA was the handson manager who ran the day-to-day operations. They maintained a sophisticated, highly-structured drug trafficking organization that was tightly controlled. Each day, details of loads and 

money shipments were electronically communicated to heads of cocaine cells operating within 

the United States. The RODRIGUEZ OREJUELA brothers were intimately involved in every 

phase of the business—production, transportation, financing, and communications. Th ey knew 

the how, when, and where of every cocaine shipment, down to the markings on the packages. 

They even set production targets for the cocaine they sold. 

A November 1994 Drug Enforcement Administration (“DEA”) report entitled, “The Cali Cartel: 

The New Kings of Cocaine,” stated that Gilberto and Miguel RODRIGUEZ OREJUELA controlled “what may be the most powerful of the Cali Cartel organizations.” 

In June 1995, a federal grand jury in Miami, Florida issued a landmark Racketeer Infl uenced 

and Corrupt Organizations Act (“RICO”) indictment against the leaders of the Cali drug cartel, including Miguel and Gilberto RODRIGUEZ OREJUELA, and charged the Cali drug cartel 

with the importation of 200,000 kilograms of cocaine and the laundering of $2 billion from 

1983 through 1995. 

In reaction to law enforcement actions, the RODRIGUEZ OREJUELA brothers used a network 

of family members and associates as front persons in their companies to disguise the true ownership or control of their assets. Both Miguel and Gilberto were identified early on in public 

documents in Colombia as partners in several companies. Subsequently, however, they attempted to conceal their continuing control of these companies in order to insulate their assets 

from seizure by law enforcement authorities. Their companies are now held under the names of 

family members and associates who may appear as shareholders, officers, or managers at different points in the companies’ histories, while in fact the companies continue to be owned or 

controlled by Gilberto and Miguel RODRIGUEZ OREJUELA. 

Gilberto and Miguel RODRIGUEZ OREJUELA were arrested by Colombian police operations 

in June and August 1995, respectively. On October 24, 1995, subsequent to their naming by 

CALI CARTEL 17 
IMPACT REPORT  CALI CARTEL 

the President in the Annex to E.O. 12978, OFAC designated 13 businesses and 32 individuals 

involved with the RODRIGUEZ OREJUELA organization, including its most important asset, 

the Drogas La Rebaja drugstore chain. 

In late 1996, the RODRIGUEZ OREJUELA brothers reached an agreement with the Colombian Government to plead guilty to drug charges in Colombia, rather than face future possible 

SECTION 2 extradition to the United States. However, they continued to control the Cali drug cartel from 

prison. 

Since the implementation of E.O. 12978 in October 1995 until September 2006, OFAC continued to identify new assets of the RODRIGUEZ OREJUELA organization and followed the organization’s attempted evasions to preserve assets by changing names or restructuring of already 

designated companies. This resulted in the designation of 246 front companies over 11 years 

under at least 12 separate OFAC designation actions against the RODRIGUEZ OREJUELA 

organization. OFAC identified assets of the organization in 10 countries, including Colombia, 

Costa Rica, Ecuador, Panama, Peru, Spain, Venezuela, the Bahamas, the British Virgin Islands, 

and the United States. 

In December 2003 and March 2004, two new 

federal indictments were unsealed and extradition warrants filed requesting that the Colombian Government extradite Gilberto and 

Miguel RODRIGUEZ OREJUELA, based on

new U.S. charges of narcotics traffi cking and 

money laundering. Subsequently, they were

extradited to the United States in December 

2004 and March 2005, respectively.

In September 2006, Gilberto and Miguel RODRIGUEZ OREJUELA pled guilty to all federal 

drug trafficking and money laundering charges 

brought by the U.S. Attorney’s Offi ce for the 

Southern District of Florida and the U.S. Attorney’s Office for the Southern District of New 

York. 

Related Impact: 

OFAC designations since October 1995 helped 

identify the RODRIGUEZ OREJUELA fi nancial 

and business empire throughout the world. Th e 

economic sanctions played a key role in the commercial and financial isolation of the 

RODRIGUEZ OREJUELA businesses and impaired its organizational integrity. 

SOUTHERN DISTRICT OF 

EXCERPT FROM THE 

NEW YORK INDICTMENT 

“In 1996, after OFAC applied sanctions against 

many of their principal companies, Gilberto 

and Miguel RODRIGUEZ OREJUELA arranged 

for their pharmaceutical drugs to be sold to 

numerous companies outside Colombia in an 

effort to protect their assets and avoid OFAC 

sanctions. These foreign companies were effectively controlled by trusted associates of the 

Cali Cartel. In addition, after their companies 

were sanctioned by OFAC, Gilberto and Miguel 

RODRIGUEZ OREJUELA and their criminal 

associates established “new” or “re-organized” 

companies from the previously sanctioned 

companies. These “new” companies simply assumed the assets and continued to perform the 

services of the previously sanctioned companies.” 

18 CALI CARTEL 
IMPACT REPORT  CALI CARTEL 

In Colombia, subsequent to OFAC designations, the authorities have seized the majority of the 

RODRIGUEZ OREJUELA organization’s assets in the course of a number of large operations. 

In September 2004, the Colombian Government finally seized the drugstore chain Drogas La 

Rebaja in what was considered the largest asset forfeiture operation in Colombian law enforcement history. A team of 465 Colombian prosecutors, accompanied by 3,000 police and 20 SECTION 2 

accountants, seized all Drogas La Rebaja drugstores across Colombia. According to Colombian 

offi cials, “This is the largest occupation of property linked to the drug trade in the history of the 

country.” The drugstore chain was valued by Colombian authorities at approximately $220 million. 

In August 2005, Colombian authorities followed up the September 2004 seizure of Drogas La 

Rebaja by seizing nearly all the RODRIGUEZ OREJUELA property on which the drugstores of 

the chain were located. 

In May 2006, Colombian authorities initiated a second follow up operation to the September 

2004 seizure of Drogas La Rebaja and seized the RODRIGUEZ OREJUELA company Prosalud, 

a 17-drugstore chain based in Cali, as well as numerous other affi liated companies, including 

Credirebaja, the credit card company used by Drogas La Rebaja. 

Also, in May 2006, a Colombian judge ordered the forfeiture of hundreds of assets belonging to 

Gilberto and Miguel RODRIGUEZ OREJUELA, including 74 properties located in Cali, Bogota, 

and San Andres, their shares in the professional soccer team America de Cali, and 17 companies. These property assets and companies, valued by Colombian authorities in excess of $45 

million, had been seized in operations since 1996. 

In September 2006, a major agreement was reached with Gilberto and Miguel RODRIGUEZ 

OREJUELA when they pled guilty to drug trafficking and money laundering charges. Th ey 

agreed to a forfeiture of up to $2.1 billion in assets to be levied against their narcotics-related 

assets found anywhere in the world, as well as all RODRIGUEZ OREJUELA business entities 

worldwide. These entities are mainly the 246 front companies already designated by OFAC over 

the past 11 years under at least 12 separate OFAC designation actions. In a separate agreement, 28 family members of the RODRIGUEZ OREJUELAs agreed to forfeit their right, title, 

and interest in all RODRIGUEZ OREJUELA business entities worldwide, including all those 

designated by OFAC since 1995. These family members also agreed to forfeit and/or divest 

themselves of all the businesses on the OFAC list, in addition to continuing to assist U.S. and 

Colombian Governments in any ongoing or later related forfeiture actions against their assets. 

If the RODRIGUEZ OREJUELA family members fully comply with the terms of the agreement, 

they will be eligible to be removed from OFAC’s SDNT list. These agreements resulted from a 

combination of the sanctions powers of the Department of the Treasury with the authorities of 

CALI CARTEL 19 
IMPACT REPORT  CALI CARTEL 

the U.S. Attorney’s Offices in Miami and New York, the Drug Enforcement Administration, the 

Departments of Homeland Security and State, and Colombian authorities. 

In November 2006, the RODRIGUEZ OREJUELA brothers entered their guilty pleas to money 

laundering charges in the U.S. District Court for the Southern District of New York. 

SECTION 2 

20 CALI CARTEL 
ORGANIZATION CHART 21

22 TIMELINE 
TIMELINE 23

 Cali Drug Cartel: Gilberto Jose & Miguel Angel 

RODRIGUEZ OREJUELA 

AgroIndustrial Construction Consulting Investment 

Bogota 

7 • Conage Ltda.)8 

Construcciones Colombo-Andinas Ltda.7 

• 

• 

-

10 

• 7 

Fiduser Ltda.8 

3 

4 

• 

• 

• 

• 

Cali 

Agricola Humyami 

Ltda.3 

fico Ltda.3 

Export Cafe Ltda.3 

• 

• 

• 

Andina de Construcciones 

3 

6 

3 

3 

4 

Inversiones y Construcciones 

7 

Inversiones y Construcciones 

Ltda.)5 

Inversiones y ConstruccioInversiones y Distribuciones 

Ltda.)4 

Ltda.)7 

3 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Asesorias de Ingenieria 

10 

Asesorias Economicas Mu10 

Asesorias Profesionales 

Especializadas en Negocios 10 

10 

• 

• 

• 

• 

10 

14 

3 

Asesorias Cosmos Ltda.3 

10 

3 

3 

Inversiones Capital Ltda.14 

Inversiones Jaer Ltda.6 

Inversiones La Sexta Ltda.3 

Inversiones Miguel Rodriguez e Hijo1 

3 

7 

3 

3 

3 

Inversiones San Jose Ltda.6 

8 

Cosmovalle Ltda.)3 

3 

3 

7 

6 

3 

Comisionista de Bolsa)11 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Outside of Colombia 

Bahamas 

12 

14 

13 

• 

• 

• 

British Virgin 

Islands 

13 

13 

• 

• 

13 

11 

12* 

• 

• 

• 

14 • 

Spain 

(1) 21-Oct-1995 

(2) 29-Nov-1995 

(5) 30-Jul-1997 

(6) 26-May-1998 

(7) 8-Jun-1999 

(9) 22-Dec-2000 

(12) 8-May-2003* 

(13) 17-Oct-2003 

(14) 17-Nov-2004 

REGION 

* Blocked Pending Investigation. 

T Y P E O F I N D U S T R Y 

Sharper S.A.

Construcciones Avendano 

Gutierrez y Cia. Ltda. (a.k.a. Direccion Comercial Y Mar

keting Consultoria Empresa 

Unipersonal (a.k.a. D.C.M. 

Consultoria E.U.)

Claudia Pilar Rodriguez y Cia. S.C.S. 

Inversiones Geele Ltda. (f.k.a. Ganadera Caqueta Ltda.)

Valores Corporativos S.A. (a.k.a. Valorcorp S.A.)

Comercializadora 

de Carnes del PaciS.A. (n.k.a. Interamericana de 

Construcciones S.A.)

Constructora Central del Valle 

Ltda. (a.k.a. C.C.V. Ltda.)

Constructora Gopeva Ltda.

Constructora Tremi Ltda.

Interamericana de Construcciones S.A. (f.k.a. Andina de 

Construcciones S.A.)

ABC S.A. (f.k.a. Inversiones 

Camino Real S.A.)

Atlas Ltda. (f.k.a. Inversiones 

Mompax Ltda.; f.k.a. Mompax 

nes Cosmovalle Ltda. (f.k.a. 

Compax Ltda; a.k.a. Compax 

Reparaciones y Construcciones Ltda. (a.k.a. Reconstruye 

Valores Mobiliarios de Occidente S.A.

Empresa Unipersonal (a.k.a. 

Asing E.U.)

noz Santacoloma E.U. (a.k.a. 

Asems E.U.)

E.U. (a.k.a. Aspen E.U.)

Prospectiva Empresa Unipersonal (a.k.a. Prospectiva 

E.U.)

2000 Dose E.U. (a.k.a. Doma E M)

A G Representaciones Ltda.

Amparo Rodriguez de Gil y Cia S. en C. 

Internacional de Divisas S.A.

Inversiones Ara Ltda.

Inversiones Camino Real S.A.

Inversiones Mompax Ltda. (a.k.a. Mompax Ltda)

Inversiones Mondragon y Cia. S.C.S. (f.k.a. Mariela de 

Rodriguez y Cia. S. en C.)

Inversiones Rodriguez Arbelaez y Cia S. en C. 

Inversiones Rodriguez Moreno y Cia S. en C. 

Inversiones Rodriguez Ramirez y Cia S.C.S.S. 

Inversiones y Comercializadora Ramirez y Cia. Ltda.

Inversiones y Distribuciones Compax Ltda. (a.k.a. 

Compax Ltda; n.k.a. Inversiones y Construcciones 

M. Rodriguez O. y Cia S. en C. 

Mariela de Rodriguez Y Cia S. en C. 

Mariela Mondragon de R. y Cia. S. en C. 

Marin Estrada y Cia. S. en C.S. 

Muñoz y Rodriguez y Cia. Ltda.

Obursatiles S.A. (a.k.a. Operaciones Bursatiles S.A. 

Ardila-Marmolejo, Ltd (f.k.a. Huyo-Giraldo, Ltd.)

Galaviz Corporation Ltd.

Sepulveda-Iragorri Ltd.

Kesman Overseas

Zaratan Corporation

Florida (U.S.) 

Ash Trading, Inc. 

Internacional de Divisas S.A., LLC 

Sepulveda-Iragerri, Inc. 

Panama Farfalla Investment S.A.

(3) 5-Mar-1996 

(4) 17-Apr-1997 

(8) 22-Feb-2000 

(10) 6-Feb-2003 

(11) 21-Mar-2003 

Footnotes indicate date of designation by OFAC. 

24 ORGANIZATION TABLE
Bahamas 

Florida (U.S.) 

Spain 

Radio/Sport Real Estate Other 

Bogota 

10 

10 

• 

• 

Cali 

14 

3 

11 

3 

8 

9 

7 

7 

3 

1 

13 

13 

3 

11 

7 

8 

7 

3 

10 

Occidental Comunicaciones Ltda.8 

6 

Producciones Carnaval del Norte y Compania Limitada8 

Recitec Ltda.8 

14 

9 

2 

3 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Outside of Colombia 

British Virgin 

Islands 

13 

10 

10 

Inversiones Inmobiliarias 10 

10 

10 

• 

• 

• 

• 

• 

• 

10 

10 

10 

10 

12 

10 

13 

• 

• 

• 

• 

• 

• 

• 

REGION 

T Y P E O F I N D U S T R Y 

Consultoria Santafe E.U. 

Servicios de la Sabana E.U. (a.k.a. Serbana E.U.)

Alero S.A.

Aspoir del Pacifico y Cia. Ltda.

Clinica Especializada del Valle S.A.

Comercializadora Orobanca S.A. (a.k.a. Socir S.A.)

Comteco Ltda. (a.k.a. Comunicaciones Tecnicas de Colombia Limitada)

Comunicacion Visual Ltda. (a.k.a. Comvis Ltda.)

Contactel Comunicaciones S.A.

D’Cache S.A.

Derecho Integral y Cia. Ltda.

Distribuidora Migil Cali S.A. (a.k.a. Migil; a.k.a. Distribuidora Migil Ltda; a.k.a. 

Gran Cadena de Almacenes S.A.; a.k.a. Gracadal S.A.; n.k.a. Dism)

Fundacion Vivir Mejor (a.k.a. F.V.M.)

Fundaser (a.k.a. Fundacion Para el Servicio del Ser Integral; a.k.a. Fundacion de Cali Para el Desarrollo Humano; a.k.a. Fundecali)

Haydee de Muñoz y Cia. S. en C. 

Hielo Cristal y Refrigeracion Ltda. (a.k.a. Cuatro Frio)

Industrial de Gestion de Negocios E.U. 

M C M y Cia. Ltda.

M.O.C. Echeverry Hermanos Ltda.

Maxitiendas Todo en Uno

Media Marketing E.U. 

Parque Industrial Las Delicias Ltda.

Representaciones Zatza Ltda.

Soraya y Haydee Ltda.

Supertiendas La Rebaja (a.k.a. Distribuidora Migil Cali S.A.)

Tobogon

Panama 

Inversiones Carfeni, S.L.

Inversiones Claupi S.L.

Inversiones Espanolas Femcar S.L.

Valeria S.L.

Jaromo Inversiones S.L.

Valores Corporativos Espanoles S.L.

2000-Dodge S.L.

Café Andino S.L.

CPV Sistemas Graficos S.L.

Customer Networks S.L.

Galeria de Portales, S.A.

Rodriguez Y Tolbanos S.A.

Sociedad Inversora en Proyectos de Internet, S.A.

•	 Color 89.5 FM Stereo (a.k.a. 

Radio Unidas FM S.A.)3 

• Corporacion Deportiva America 

(a.k.a. Club Deportiva America, 

Club America de Cali)7 

•	 Creaciones Deportivas Willington 

Ltda.3 

•	 Farallones Stereo 91.5 FM (a.k.a. 

Radio Unidas FM S.A.)3 

•	 Radio Unidas FM S.A. (a.k.a. 

Color 89.5 FM Stereo and 

Farallones Stereo 91.5 FM)3 

• Revista del America Ltda. 

•	 Sociedad Comercial y Deportiva 

Ltda.7 

• Sonar FM E.U. Dieter Murrle 

(a.k.a. Prisma Stereo 89.5 FM, 

Fiesta Stereo 91.5 FM)7 

•	 Sonar FM S.A. (f.k.a. Radio Unidas FM S.A., Color Stereo S.A., 

Color’s S.A.)7 

ORGANIZATION TABLE 25 
RODRIGUEZ OREJUELA Business Logos


26 Business Logos 
IMPACT REPORT  CALI CARTEL 

SANTACRUZ LONDOÑO ORGANIZATION 

Background: 

In the late 1970s, Jose SANTACRUZ LONDOÑO was first arrested by U.S. authorities on drug 

charges. After being released, he continued his drug trafficking activities and by April 1980, he SECTION 2 

had become a Drug Enforcement Administration (“DEA”) fugitive. SANTACRUZ LONDOÑO 

was ultimately the subject of four U.S. federal indictments for drug trafficking and money laundering. 

By 1990, Jose SANTACRUZ LONDOÑO was considered to be one of the highest ranking 

members of the Cali drug cartel leadership. He was also one of the most violent of the Cali 

drug cartel leaders—he was wanted for the 1989 assassination of the former governor of Antioquia, Colombia, Antonio Roldan Betancur, and ordered the 1992 slaying of a New York investigative journalist, Manuel de Dios Uname. 

Although his talent rested in managing international cocaine transportation networks, his organization was also involved in drug production, wholesale distribution, money laundering, and 

playing a key role in the Cali drug cartel’s intelligence collection effort. SANTACRUZ LONDOÑO’s major U.S. wholesale cocaine distribution and money laundering operations centered 

around the New York City metropolitan area, but his organization also operated in Miami, Los 

Angeles, San Francisco, Houston, Las Vegas, and Chicago. 

In June 1995, a federal grand jury in Miami, Florida issued a historic RICO indictment against 

the leaders of the Cali drug cartel, including Jose SANTACRUZ LONDOÑO, and charged the 

Cali drug cartel with the importation of 200,000 kilograms of cocaine and the laundering of $2 

billion from 1983 through 1995. On July 4, 1995, Jose SANTACRUZ LONDOÑO was arrested 

by Colombian authorities in Bogota. 

On October 24, 1995, SANTACRUZ LONDOÑO was designated by the President in the Annex to E.O. 12978. OFAC subsequently designated 20 businesses and 11 individuals involved 

with the Jose SANTACRUZ LONDOÑO organization—almost all located in Cali, Colombia. 

On January 11, 1996, Jose SANTACRUZ LONDOÑO escaped from La Picota prison in Bogota, 

Colombia. In March 1996, SANTACRUZ LONDOÑO was killed outside of Medellin, Colombia. 

As is often the case, family members and associates of SANTACRUZ LONDOÑO attempted to 

preserve his organization’s existing assets by changing the names of already designated companies. OFAC followed these attempted evasions and in July 1997, OFAC designated an additional 

five front companies and five individuals acting for or on behalf of the SANTACRUZ LONDOÑO organization. 

CALI CARTEL 27 
IMPACT REPORT  CALI CARTEL 

Related Impact: 

OFAC designations and economic sanctions played a key role in the commercial and fi nancial 

isolation of the SANTACRUZ LONDOÑO businesses in Colombia, in publicly exposing the 

SANTACRUZ LONDOÑO organization, and in increasing Colombian law enforcement pressure targeting SANTACRUZ LONDOÑO’s associates and fi nancial assets: 

SECTION 2 

Ø In October 2003, the Colombian Government proceeded with the forfeiture of 201 properties that were held in the name of two front companies designated by OFAC as SDNTs and 

controlled by Jose SANTACRUZ LONDOÑO and his family. 

Ø In April 2004, the Colombian Government announced that they had two ongoing asset forfeiture investigations against 644 properties of SANTACRUZ LONDOÑO. At the time of 

the announcement, the investigations had already resulted in the forfeiture of 295 of these 

properties. 

Ø In October 2005, the Colombian police seized 137 properties belonging to two front individuals for Jose SANTACRUZ LONDOÑO. 

The SANTACRUZ LONDOÑO organization was seriously impaired as a result of Jose SANTACRUZ LONDOÑO’s arrest, OFAC sanctions, Jose SANTACRUZ LONDOÑO’s subsequent 

death, and the Colombian Government’s subsequent seizure and forfeiture of the assets and 

companies belonging to the SANTACRUZ LONDOÑO organization, as recently as October 

2005. 

28 CALI CARTEL 
ORGANIZATION CHART 29

Cali Drug Cartel: Jose 

SANTACRUZ LONDOÑO 

Agro-Industrial Construction Investment/Real 

Estate Other Commercial 

Bogota 

Bogota 1 • 

Cali 

Cali 4 

Ganaderia)2 

3 

2 

calito Ltda)1 

Grupo Santa Ltda.1 

1 

1 

1 

• 

• 

• 

• 

• 

• 

• 

• 

• 

)

1 

1 

1 

3 

• 

• 

• 

• 

1 

Inversiones Santa Ltda. 

strucciones Santa Ltda.)1 

Ltda.)3 

Negocios Los Sauces Ltda. 2 

Samaria Ltda.)2 

1 

1 

Samaria Canas1 

1 

cios Los Sauces Ltda.)1 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

1 

1 

1 

Urbanizaciones y Construc­ 3 

• 

• 

• 

• 

BY REGION 

T Y P E O F I N D U S T R Y 

Aureal Inmobiliaria Ltda.

Caviedes Dileo y Cia S.C.S. 

Caucalito Ltda. (f.k.a. 

Ganadera Ltda.; f.k.a. 

Comercializacion y Financiacion de Automotores S.A. 

(a.k.a. Comfiautos S.A.)

Construcciones Astro S.A. 

(f.k.a. Sociedad Constructora La Cascada S.A.; f.k.a. 

Constructora Cascada)

Ganadera Ltda. (n.k.a. CauHacienda La Novillera (a.k.a. 

Novillera Ganadera)

Hacienda Sandrana (a.k.a. 

Sandrana; a.k.a. Sandrana 

Ganadera)

Inmobiliaria Aurora Ltda.

Inmobiliaria Samaria Ltda. & 

Cia. S. en C. (n.k.a. Negocios Los Sauces Ltda. y Cia 

S.C.S.

Intercreditos S.A. (a.k.a. 

Comercio Inversiones y 

Creditos Integral S.A.; a.k.a. 

Intercreditos Bogota; a.k.a. 

Intercreditos Cali.)

Inversiones El Paso Ltda. 

y Cia S.C.S.(n.k.a. Miraluna 

Ltda y Cia. S.C.S.; f.k.a. Inversiones Negoagricola S.A.)

Inversiones Integral Ltda.

Inversiones Integral y Cia 

S.C.A. 

(f.n.a. Inversiones y ConMiraluna Ltda. (f.k.a. El Paso 

(f.k.a. Samaria Ltda.)

Negocios Los Sauces Ltda. y 

Cia. S.C.S. (f.k.a. Inmobiliaria 

Prevencion y Analysis de 

Riesgos Previa S.A. (a.k.a. 

Previa S.A.)

Samaria Arrendamiento

Samaria Intereses

Samaria Ltda. (n.k.a. NegoSamaria Tierras

Sandrana Canas

Sociedad Constructora La 

Cascada S.A. (n.k.a. Construcciones Astro S.A.; f.k.a. 

Constructora La Cascada 

S.A.)

ciones Ltda. de Cali

Footnotes indicate the date of designation by OFAC. 

(1) 21-Oct-1995

(2) 30-Jul-1997

(3) 8-Jun-1999

(4) 7-Dec-2000

30 ORGANIZATION TABLE 
IMPACT REPORT  CALI CARTEL 

HERRERA BUITRAGO ORGANIZATION 

Background: 

Helmer HERRERA BUITRAGO (a.k.a. “Pacho” HERRERA), considered to be one of the highest 

ranking members of the Cali drug cartel leadership, started his criminal career selling relatively SECTION 2 

small amounts of cocaine in New York where he was arrested in the 1970s. By the early 1980s, 

Pacho HERRERA personally directed cocaine distribution and money laundering activities in 

the New York City area on behalf of the Gilberto and Miguel RODRIGUEZ OREJUELA organization. By 1990, Pacho HERRERA had established his own family-run cocaine traffi cking operations and had become a major supplier of cocaine for both the New York and South Florida 

illicit markets. Pacho HERRERA was the subject of two federal indictments for drug traffi cking 

issued by the U.S. Attorney’s Office for the Eastern District of New York. 

In June 1995, a federal grand jury in Miami, Florida issued a historic RICO indictment against 

the leaders of the Cali drug cartel, including Pacho HERRERA, and charged the Cali drug cartel 

with the importation of 200,000 kilograms of cocaine and the laundering of $2 billion from 

1983 through 1995. 

On October 21, 1995, Helmer HERRERA BUITRAGO was named an SDNT principal individual by the President in the Annex to Executive Order 12978 along with three other leaders of 

Colombia’s Cali drug cartel. On March 5, 1996, OFAC designated 19 companies and an additional 69 individuals acting for or on behalf of Pacho HERRERA. 

In September 1996, Pacho HERRERA surrendered to Colombian authorities and was incarcerated. 

During 1997 in three separate actions, an additional 24 entities and 58 individuals were designated by OFAC as fronts for the HERRERA BUITRAGO organization, which Pacho HERRERA 

continued to run from his Colombian prison cell. 

In November 1998, Pacho HERRERA BUITRAGO was murdered in a Colombian prison by 

rival drug cartel leaders. 

Family members and associates of HERRERA BUITRAGO attempted to preserve the organization’s existing assets by restructuring or changing the names of companies designated since 

March 1996. OFAC followed these attempted evasions and in June 1999, OFAC designated an 

additional nine front companies acting for or on behalf of the HERRERA BUITRAGO organization. 

Related Impact: 

The OFAC designations and economic sanctions played a key role in the commercial and fi nancial isolation of the HERRERA BUITRAGO businesses in Colombia, in helping publicly expose 

CALI CARTEL 31 
IMPACT REPORT  CALI CARTEL 

the HERRERA BUITRAGO organization, and in increased Colombian law enforcement pressure targeting HERRERA BUITRAGO’s associates and financial assets. Multiple companies, 

including many of those designated by OFAC, and other properties have been seized by Colombian authorities and are pending forfeiture. For example: 

Ø In November 2003, a Cali judge ordered the forfeiture of 1,256 Pacho HERRERA properSECTION 2 ties, including apartments, ranches, warehouses, and commercial real estate, which were 

estimated by Colombian authorities to be worth over $80 million. 

Ø In September 2005, Colombian authorities seized 411 additional Pacho HERRERA properties, estimated to be worth more than $14 million. 

Ø In May 2006, two front persons for Pacho HERRERA were being prosecuted in Colombia 

for unexplained income generated between 1998 and 2000 through their company, designated by OFAC as a Pacho HERRERA front in 1997. 

The HERRERA BUITRAGO organization was seriously impaired as a result of OFAC’s sanctions since March 1996, Pacho HERRERA’s incarceration in September 1996, his subsequent 

death in prison in November 1998, the Colombian Government’s subsequent seizure and forfeiture of the assets and companies belonging to the HERRERA BUITRAGO organization, and 

criminal prosecution of HERRERA BUITRAGO associates, as recently as May 2006. 

32 CALI CARTEL 
ORGANIZATION CHART 33

Cali Drug Cartel: Helmer 

HERRERA BUITRAGO 

Agro-Industrial Construction Investment Retail/Other 

Central Colombia 

5 

Ltda.)6 

Matadero Metropolitano Ltda.5 

• 

• 

• 

2 • 

Cali 

Cali 

Agropecuaria Betania Ltda. 1 

Agropecuaria La Robleda 2 

1 

Criadero de Pollos El Rosal 

4 

2 

1 

Ltda.2 

Inversiones Agricolas 

Carmelita Ltda.2 

1 

Inversiones y Construc1 

3 

2 

2 

Prohuevo de Colombia 

Ltda.2 

pecuaria Betania Ltda.)3 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

1 

1 

5 

1 

2 

5 

1 

• 

• 

• 

• 

• 

• 

• 

1 

5 

Compañia Adminis5 

Especializada Ltda.2 

Inmobiliaria Bolivar 

Ltda.2 

1 

2 

Inversiones Betania 

Ltda.1 

Inversiones Culzat Gue­ 2 

5 

Inversiones El Peñon 1 

Inversiones Invervalle 1 

Ltda.1 

2 

2 

versiones Betania Ltda., 

Inversiones Betania 5 

Inversiones Invervalle 5 

Servicios Inmobiliarios 

Ltda.1 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Ltda.)2 

Ltda.)2 

6 

1 

1 

• 

• 

• 

• 

• 

Bogota 

Bogota 

Ltda.2 

• Inmobiliaria Gales Ltda.2 • 

2 

2 

• 

• 

BY REGION 

(2) 15-Jan-1997 

(4) 30-Jul-1997 

(5) 8-Jun-1999 

Footnotes indicate the date of 

T Y P E O F I N D U S T R Y 

Pereira Colombiana de Cerdos Ltda. 

(a.k.a. Colcerdos Ltda.)

Comercializadora de Carnes 

Ltda. (a.k.a. Comecarnes 

Valle del Cauca 

Palmira Valle de Oro S.A.

(n.k.a. Valladares Ltda.)

S.A. (n.k.a. Manaure S.A.)

Agropecuaria y Reforestadora Herrebe Ltda (n.k.a. 

Inversiones Geminis S.A.)

S.A. (f.k.a. Industria Avicola 

Palmaseca S.A.)

Ganaderias del Valle S.A.

Industria Avicola Palmaseca S.A. (n.k.a. Criadero de 

Pollos El Rosal S.A.)

Industria Maderera Arca 

Avicolas y Ganaderas La 

Inversiones Geminis S.A. 

(f.k.a. Agropecuaria y Reforestadora Herrebe Ltda.)

ciones Valle S.A. (a.k.a. 

Incovalle S.A.)

Manaure S.A. (f.k.a. Agropecuaria La Robleda S.A.)

Mercavicola S.A.

Procesadora de Pollos Superior S.A. (f.k.a. Comercializadora Internacional Valle 

de Oro S.A.)

Valladares Ltda (f.k.a. AgroConcretos Cali S.A.

Constructora Dimisa S.A.

Constructora El Nogal S.A. 

(f.k.a. Construexito S.A., Cone 

S.A.)

Construexito S.A. (a.k.a. Cone 

S.A.)

Construvida S.A.

Distribuidora de Elementos 

Para La Construccion S.A. 

(a.k.a. D’elcon S.A.)

Sociedad Constructora y 

Administradora del Valle Ltda. 

(a.k.a. Socovalle Ltda.)

Adminstracion Inmobiliaria Bolivar S.A.

Alkala Asociados S.A. 

(f.k.a. Invheresa S.A.)

tradora de Vivienda 

S.A. (f.k.a. Inversiones 

Geminis S.A.)

Consultoria Empresarial 

Inmobiliaria U.M.V. S.A.

Inversiones Ario Ltda.

vara y Cia. S.C.S. 

Inversiones El Gran Crisol Ltda. (f.k.a. W Herrera 

y Cia. S. en C.)

S.A.

S.A.

Inversiones Herrebe 

Inversiones Villa Paz 

S.A.

Invheresa S.A.

San Mateo S.A. (f.k.a. InS.A.)

San Vicente S.A. (f.k.a. 

S.A., Invervalle S.A.)

Importadora y Comercializadora Ltda. (a.k.a. Imcomer 

Interventoria, Consultoria y 

Estudios Ltda. (a.k.a. Incoes 

Serviautos Uno A 1A Limitada 

(a.k.a. Diagnosticentro La 

Garantia)

Valle Communicaciones Ltda. 

(a.k.a. Vallecom Ltda.)

Viajes Mercurio Ltda.

Constructora Altos del Retiro 

Comercial de Negocios 

Claridad y Cia. S. en C. 

Comercializadora Experta y 

Cia. S. en C. 

(1) 5-Mar-1996 

(3) 17-Apr-1997 (6) 22-Feb-2000 

designation by OFAC. 

34 ORGANIZATION TABLE 
IMPACT REPORT  CALI CARTEL 

VALENCIA TRUJILLO ORGANIZATION 

Background: 

Since 1979, Joaquin Mario VALENCIA TRUJILLO and Guillermo VALENCIA TRUJILLO 

have been active in narcotics traffi cking. The VALENCIA TRUJILLO organization has had a SECTION 2 

close relationship with other Cali drug cartel leaders, such as Helmer HERRERA BUITRAGO. 

Joaquin Mario VALENCIA TRUJILLO and his brother Guillermo VALENCIA TRUJILLO have 

also worked with other drug trafficking organizations led by Juan Carlos RAMIREZ ABADIA, 

and Ivan URDINOLA GRAJALES. 

In August 2002, Joaquin Mario VALENCIA TRUJILLO was indicted by a federal grand jury in 

Middle District of Florida for allegedly moving more than 100 tons of cocaine, estimated to be 

as much as 20 percent of the cocaine entering the United States each year. 

On January 31, 2003, Joaquin Mario VALENCIA TRUJILLO was arrested in Bogota, Colombia 

on U.S. drug trafficking and money laundering charges, based upon his control of a large-scale 

maritime drug trafficking operation centered in Colombia that threaded through Chile, Ecuador, Mexico, and Panama to the U.S. cities of Tampa, Miami, Houston, New York and Los 

Angeles. 

On March 27, 2003, seven weeks after the arrest of Joaquin Mario VALENCIA TRUJILLO, 

OFAC designated Joaquin Mario and Guillermo VALENCIA TRUJILLO as SDNT principal 

individuals along with 28 individuals involved with supporting their financial network. In addition, 28 front companies in the VALENCIA TRUJILLO’s financial network were named, including a prominent paso fi no horse farm, Criadero La Luisa, an industrial paper manufacturer, 

Unipapel S.A., a plastics company, Geoplasticos S.A., a maritime services provider, Gran Muelle 

S.A., and fi ve fi nancial fi rms, Compania de Fomento Mercantil S.A., Credisa S.A., Finve S.A., 

Gestora Mercantil S.A., and Unidas S.A., all located in Colombia. OFAC worked closely with 

the U.S. Attorney’s Office for the Middle District of Florida and “Operation Panama Express,” a 

multi-agency drug task force based out of Tampa, Florida, in connection with the designation of 

Joaquin Mario VALENCIA TRUJILLO and his financial network. 

In March 2004, Joaquin Mario VALENCIA TRUJILLO was extradited to the United States 

to stand trial. In October 2006, he was found guilty by a federal grand jury in Tampa of drug 

trafficking and money laundering charges. On February 1, 2007, the court sentenced Joaquin 

Mario VALENICA TRUJILLO to 40 years in prison and ordered him to forfeit $110 million. 

Related Impact: 

OFAC designations of March 27, 2003, helped identify the VALENCIA TRUJILLO business 

empire. The following are examples of how some members and entities of the VALENCIA 

TRUJILLO organization were isolated commercially: 

CALI CARTEL 35 
IMPACT REPORT  CALI CARTEL 

Ø Criadero La Luisa E.U. , an internationally-recognized breeder of paso fi no horses, maintained an average of approximately 300 horses, some of which are worth more than $1 

million. Criadero La Luisa sold highly-valued horse sperm for breeding to overseas clients, 

especially in the United States, which accounted for the majority of the horse sales and 

breeding service business. After the OFAC designation, these commercial and fi nancial 

relationships with U.S. persons were shut down. 

SECTION 2 

Ø Unipapel S.A., a large industrial paper company located in the Yumbo area outside of Cali, 

Colombia was principally run by Guillermo VALENCIA TRUJILLO. Unipapel S.A. was 

forced to close after the OFAC action and was unsuccessful in its attempts to find a buyer. 

Ø The arrest in Colombia and subsequent OFAC designation of Joaquin Mario VALENCIA 

TRUJILLO shocked the public who knew him as a prominent breeder of paso fi no horses 

and his wife, Luz Mery TRISTAN GIL, as a national skating champion in Colombia (see 

“VALENCIA TRUJILLO ORGANIZATION: EXAMPLES OF FAMILY MEMBERS INVOLVEMENT” box on the next page). 

OFAC designations helped publicly expose the VALENCIA TRUJILLO organization and played 

a key role in increased Colombian law enforcement pressure targeting VALENCIA TRUJILLO’s 

associates and financial assets. The Colombian Government has seized approximately $25 

million in assets of the VALENCIA TRUJILLO organization, including many of the companies 

already designated by OFAC. The Colombian Government is moving these seizures to forfeiture proceeding: 

Ø In February 2003, the Colombian Government seized the paso fi no horse breeding farm 

Criadero La Luisa and more than 300 paso fi nos horses belonging to Joaquin Mario VALENCIA TRUJILLO. In addition, they seized his residence in Cali, Colombia (valued at over 

$7 million) in which they discovered over 54 valuable works of art and armored vehicles. 

Ø In March 2003, the Colombian Government seized an additional 35 properties belonging to 

Joaquin Mario VALENCIA TRUJILLO, including 8 companies designated by OFAC. 

Ø In August 2003, Colombian authorities seized three large farms belonging to the VALENCIA TRUJILLO organization valued at approximately $500 thousand. 

Ø In June 2005, Colombian prosecutors requested forfeiture of over $13 million in previously 

seized assets belonging to Joaquin Mario VALENCIA TRUJILLO, including more than 300 

paso fi no horses, 10 companies, over 20 properties, vehicles and works of art located in the 

cities of Cali, Jamundi, Buenaventura, Candelaria, Calima and Yumbo in the Valle region of 

Colombia. 

36 CALI CARTEL 
IMPACT REPORT  CALI CARTEL 

,

). 

.

, 

, 

. ., a 

VALENCIA TRUJILLO ORGANIZATION: 

EXAMPLES OF FAMILY MEMBERS INVOLVEMENT 

Prior to designation, Joaquin Mario VALENCIA TRUJILLO, by all appearances was a prominent and 

respected businessman. However, his substantial business empire was created using illicit drug proceeds 

and was run by trusted family and friends (see underlined names below These businesses burnished his 

reputation locally and internationally and gave him ready and immediate financial and commercial access 

around the world. He used this access in part to facilitate his drug trafficking operations. OFAC’s designations not only helped dismantle his businesses, but also struck at these key managers of his businesses, who 

are now isolated in the Colombian business and financial communities. The following are examples of how 

he involved family and friends in his operations: 

Unipapel S.A Joaquin Mario and Guillermo VALENCIA TRUJILLO’s main joint fi nancial holdings 

centered around the company Unipapel S.A., a large industrial paper company located in the Yumbo area 

outside of Cali, Colombia. Unipapel S.A. managed the payroll for a large security contingent that protected 

Joaquin Mario VALENCIA TRUJILLO’s family and corporate network. Agueda VALENCIA TRUJILLO

Joaquin Mario’s sister managed the day-to-day operations of Unipapel S.A. from Cali and is also involved in 

the corporate management of several other front companies. 

Criadero La Luisa E.U. The crown jewel of Joaquin Mario VALENCIA TRUJILLO’s fi nancial investments 

is his paso fi no horse breeding farm. Juan Pablo GAVIRIA PRICE, who has worked more than a decade for 

Joaquin Mario VALENCIA TRUJILLO, managed Criadero La Luisa E.U. Some reports suggest that the 

farm maintained about 300 horses. At the time, some of these horses were worth more than $1 million a 

piece, and Criadero La Luisa E.U. sold highly-valued horse sperm for breeding to overseas clients. 

Gestora Mercantil S.A. Carmen VALENCIA TRUJILLO, another sister of Joaquin Mario and Guillermo

managed the financial aspects of the real estate company Gestora Mercantil S.A. 

Unidas S.A Agueda, Adela, and Carmen VALENCIA, sisters of Mario VALENCIA, ran Unidas S.A

financial loan company. Mario VALENCIA provided the start-up money for this fi rm. 

Gran Muelle S.A. Guillermo VALENCIA TRUJILLO ran this Buenaventura-based maritime agency. 

Luz Mery Tristan E.U. Luz Mery TRISTAN GIL, Joaquin Mario VALENCIA TRUJILLO’s wife and former 

roller skating star, owns Luz Mery Tristan E.U., a roller skating promotion and merchandise company which 

includes the Club Deportivo Luz Mery Tristan, a large skating complex in Cali, Colombia. 

SECTION 2


CALI CARTEL 37

38 ORGANIZATION CHART 
 Cali Drug Cartel: Joaquin Mario & Guillermo 

VALENCIA TRUJILLO 

Agricultural Financial Maritime Other 

North Coast

 Santa Marta • 

Bogota 

siones Ltda.) 

• • • 

• 

Cali 

Criadero La Luisa 

Agropecuaria Santa 

Elena Ltda.) 

• 

• 

• 

• 

• 

• 

• 

Coempaques Ltda.) 

Occidental de 

Occipapel Ltda.) 

• 

• 

• 

Ltda. 

World Class) 

Novapinski Ltda. 

• 

• 

• 

• 

• 

Gaviota Ltda. 

• 

• 

• 

• 

• 

Southwestern Colombia

• Construcciones

•

 Popayan • 

BY REGION 

T Y P E O F I N D U S T R Y 

Paper 

Bananera Agricola 

S.A. 

Finve S.A. (f.k.a. 

Financiera de InverTodobolsas y Colsobres (f.k.a. Rodriguez 

Carreno Ltda. Todo 

Bolsas y Colsobres) 

Cia. Minera Dapa S.A. 

Servicios Aereo de 

Santander E.U. (a.k.a. 

S.A.S. E.U.) 

E.U. (f.k.a. Industria 

Granja La Sierra Ltda. 

Compania de Fomento Mercantil S.A. 

Credisa S.A. (f.k.a. 

Comercializadora 

Automotriz S.A.) 

Gestora Mercantil 

S.A. 

J. Freddy Mafla y Cia. 

S.C.S. 

Unidas S.A. 

Cia. Andina de Empaques Ltda. (a.k.a. 

Geoplasticos S.A. 

(f.k.a. Colombiana de 

Bolsas S.A.) 

Papeles Ltda. (a.k.a. 

Constructora Pynzar 

Luz Mery Tristan E.U. 

(a.k.a. Club Deportivo Luz Mery Tristan 

Mira E.U. 

Pyza E.U. 

Valle de Cauca

 Buenaventura Dragados y Muelles 

Gran Muelle S.A. 

Trinidad Ltda. y Cia. 

S.C.S. 

Yumbo 

Bolsak E.U. (a.k.a. 

Bolsak S.A.) 

Unipapel S.A. 

 Puerto Tejada 

Progreso del Puerto 

S.A. (a.k.a. Conpuerto 

S.A.) 

Parque Industrial 

Progreso S.A. 

Valor Ltda. S.C.S. 

All Designated by OFAC as SDNTs on 27-Mar-2003. 

ORGANIZATION TABLE 39
40 MAP OF COLOMBIA Cities in bold mark locations of North Valle drug cartel businesses.
IMPACT REPORT  NORTH VALLE CARTEL 

NORTH VALLE CARTEL


The North Valle drug cartel, so named because its leaders are from the northern part of the 

Valle del Cauca region in Colombia, is considered one of Colombia’s most powerful cocaine 

trafficking organizations. U.S. and Colombian law enforcement have investigated the assets 

of Colombia’s North Valle drug cartel since the early 1990s. It began as a splinter group of 

the Cali drug cartel following the arrest and surrender of several Cali drug cartel leaders in 

the mid-1990s. The North Valle drug cartel has now overshadowed the Cali drug cartel. Th e 

North Valle drug cartel uses brutality and violence to further its goals. Members of the drug 

cartel have murdered rival drug traffickers, buyers who failed to pay for cocaine, and drug cartel SECTION 3 

members whose loyalty was suspect. Today, the North Valle drug cartel is a loose confederation of various drug traffi cking families. 

The North Valle drug cartel’s criminal activities led to a May 2004 U.S. federal RICO indictment against its leaders in the U.S. District Court for the District of Columbia. The 2004 RICO 

indictment claims that the North Valle drug cartel is responsible for one-third to one-half of 

the cocaine that reaches the shores of the United States. According to the indictment, the 

cartel worked together with various Colombian drug transportation specialists to transport 

multi-ton loads of cocaine from Peru, Colombia, and other locations within South America to 

Colombia. From Colombia, they shipped the cocaine loads to Mexico via speed boats, fi shing 

vessels, and other maritime conveyances for ultimate delivery to the United States. Since 1990, 

the North Valle drug cartel has been able to export more than one million pounds of cocaine 

worth more than $10 billion to the United States via Mexico. 

In order to protect its distribution routes and cocaine laboratories, the drug cartel employs the 

services of the Autodefenses Unidas de Colombia (“AUC”),11 a paramilitary group in Colombia 

that has been listed as a Foreign Terrorist Organization by the U.S. Department of State and 

a Tier I drug kingpin by the President pursuant to the Foreign Narcotics Kingpin Designation 

Act. The AUC also provides personal protection for North Valle drug cartel members and associates. 

OFAC investigations in recent years have documented the extensive network of agricultural, 

aviation, cattle, commercial fruit production, investment, mining, pharmaceutical, and retail 

companies set up by North Valle drug cartel leaders and their front individuals. 

11. The AUC was also designated by the Department of State as a Foreign Terrorist Organization (“FTO”) in 2001, as 

a Specially Designated Global Terrorist (“SDGT”) under E.O. 13224 in 2001, and as a drug kingpin by the President in June 2003 pursuant to the Foreign Narcotics Kingpin Designation Act. 

NORTH VALLE CARTEL 41 
IMPACT REPORT  NORTH VALLE CARTEL 

URDINOLA GRAJALES ORGANIZATION 

Background: 

In the 1980s, Ivan URDINOLA GRAJALES became involved in narcotics trafficking. By 1989, 

Ivan URDINOLA GRAJALES was managing a major drug trafficking operation that initially 

focused on cocaine, but would eventually include heroin. 

The URDINOLA GRAJALES organization was associated with the groups that would become 

known as the North Valle drug cartel. With Ivan at the helm, the URDINOLA GRAJALES SECTION 3 

organization increased its power through violence and close ties to other powerful traffi ckers from the Valle del Cauca region. For example, Ivan URDINOLA GRAJALES was married 

to Lorena HENAO MONTOYA, the sister of SDNT principal individual Arcangel de Jesus 

HENAO MONTOYA. 

In 1991, Ivan URDINOLA GRAJALES was indicted on drug trafficking charges in the Southern 

District of Florida. Julio Fabio URDINOLA GRAJALES, Ivan’s brother, was also a signifi cant 

drug trafficker twice indicted on drug trafficking charges in the Southern District of Florida in 

the early 1990s. Colombian authorities arrested Ivan URDINOLA GRAJALES in April 1992. 

Julio Fabio URDINOLA GRAJALES surrendered to Colombian authorities in 1994. However, 

they continued to control their organization from prison. 

Although, Julio Fabio URDINOLA GRAJALES, who confessed to drug traffi cking, was sentenced to 17 1⁄2 years prison in Colombia, he received a sentence reduction and was released in 

1998. 

On February 22, 2000, OFAC designated Ivan URDINOLA GRAJALES and Julio Fabio URDINOLA GRAJALES as SDNT principal individuals, along with two associated individuals, 

including Lorena HENAO MONTOYA, Ivan URDINOLA’s wife, and six companies. 

In February 2002, Ivan URDINOLA GRAJALES died in a Colombian prison. His brother, Julio 

Fabio URDINOLA GRAJALES, was murdered in October 2004 in Bogota, Colombia. 

On May 11, 2005, OFAC designated a group of companies associated with the GRAJALES 

LEMOS organization that had close ties with Lorena HENAO MONTOYA. 

Related Impact: 

OFAC designations and economic sanctions have played a key role in financially isolating the 

URDINOLA GRAJALES businesses, in publicly exposing the URDINOLA GRAJALES organization, and in increased Colombian law enforcement pressure targeting URDINOLA GRAJALES’ associates and fi nancial assets: 

Ø In April 2001, a little more than a year after the OFAC designation of Ivan URDINOLA 

NORTH VALLE CARTEL 43 
IMPACT REPORT  NORTH VALLE CARTEL 

GRAJALES and his organization, a major Colombian daily reported the Colombian Attorney General’s office initiated an asset forfeiture case against Ivan URDINOLA GRAJALES 

and seized five of the six companies designated in 2000 and 116 of his other properties and 

holdings. 

Ø In January 2005, Lorena HENAO MONTOYA, an SDNT individual, pled guilty to bribing 

Colombian officials charged with seizing the assets of her deceased husband Ivan URDINOLA GRAJALES, who had been named as an SDNT principal in February 2000. She was 

sentenced by a Bogota judge to a prison term of four years and nine months, which she is 

currently serving. SECTION 3 

Ø In May 2005, OFAC designated Raul Alberto GRAJALES LEMOS, a cousin of Ivan URDINOLA GRAJALES. It was discovered that in the 1990s Ivan URDINOLA GRAJALES obtained silent ownership of agricultural companies, which were managed by the indicted 

trafficker Raul Alberto GRAJALES LEMOS. Lorena HENAO MONTOYA inherited these 

companies following Ivan’s death. Approximately one month after the designation, Colombian authorities seized these agricultural companies, which were estimated to be worth 

more than $100 million. 

Ø In May 2005, Raul Alberto GRAJALES LEMOS was arrested by Colombian authorities on 

charges of money laundering related to the URDINOLA GRAJALES organization. 

The URDINOLA GRAJALES organization was seriously impaired as a result of OFAC’s sanctions, Ivan URDINOLA’s death, the death of his brother Fabio URDINOLA, and the Colombian Government’s subsequent seizure and forfeiture of assets and companies belonging to the 

URDINOLA GRAJALES organization. 

44 NORTH VALLE CARTEL 
ORGANIZATION CHART 45

 North Valle Drug Cartel: Ivan & Julio Fabio 

URDINOLA GRAJALES 

Agro-Industrial Construction Hotel Investment 

La Union 

2 

Frutas Exoticas Colombia- 2 

2 

• 

• 

• 2 

• 

2 

2 

Inversiones Los Posso Ltda. 2 

Inversiones Santa Cecilia 2 

Inversiones Santa Monica 

Ltda.2 

Sociedad De Negocios San 

Augustin Ltda.2 

• 

• 

• 

• 

• 

• 

Ibadan Ltda.2 • 

Cali 

Cali 

1 

1 

1 

1 

• 

• 

• 

• 

1 

Ltda.1 

• 

• 

2 • 

BY REGION 

T Y P E O F I N D U S T R Y 

Valle del Cauca 

Casa Grajales S.A.

nos S.A. (a.k.a. Frexco S.A.)

Grajales S.A.

Los Vinedos De Getsemani 

S.A. (a.k.a. Hotel Lost Vinedos; a.k.a. Valle Lindo Hostal 

Restaurante)

Inversiones Aguila Ltda.

Inversiones Grame Ltda.

S.C.S.

S.C.S.

Tulua 

Agroinversora Urdinola 

Henao y Cia. S.C.S. 

Explotaciones Agricolas y 

Ganaderas La Lorena S.C.S. 

Industrias Agropecuarias del 

Valle Ltda.

Inversiones El Eden S.C.S. 

Constructora e Inmobiliaria 

Urvalle Cia. Ltda.

Constructora Universal Panamericana Ltda.

Footnotes indicate date of designation by OFAC. 

(1) 22-Feb-2000 

(2) 11-May-2005

46 ORGANIZATION TABLE
IMPACT REPORT  NORTH VALLE CARTEL 

HENAO MONTOYA ORGANIZATION 

Background: 

The North Valle drug cartel was founded as a splinter group by Jose Orlando HENAO MON 

TOYA, the older brother to SDNT principal Arcangel de Jesus HENAO MONTOYA, after the 

arrest of Cali drug cartel leaders Miguel and Gilberto RODRIGUEZ OREJUELA. 

Until his 1998 murder in a maximum security wing of a Colombian prison, Jose Orlando 

HENAO MONTOYA was the head of the North Valle drug cartel. After Jose Orlando’s death, SECTION 3 

Arcangel de Jesus HENAO MONTOYA took control of the organization and assumed a leadership role in the North Valle drug cartel. 

On August 18, 2000, OFAC designated Arcangel de Jesus HENAO MONTOYA as an SDNT 

principal along with five agricultural and industrial companies and one individual, his wife. 

On October 25, 2002, OFAC designated an additional seven individuals, including some family 

members, and two companies associated with the HENAO MONTOYA organization. 

In January 2004, Arcangel de Jesus HENAO MONTOYA was arrested in Panama. Four days 

after his arrest, Panama extradited him to the United States. Upon arriving in New York, the 

U.S. Attorney’s Office for the Eastern District of New York unsealed a 25-count superseding indictment that charged him with drug trafficking and money laundering conspiracy along with 

other cocaine related off enses. 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of Colombia’s North Valle drug cartel, including Arcangel de Jesus HENAO MONTOYA, with RICO 

violations. The U.S. federal indictment charged the North Valle drug cartel with drug traffi cking, money laundering, and the kidnapping, torture, and murder of informants and other drug 

traffi ckers. 

In October 2004, OFAC designated Piedad VELEZ RENGIFO, the wife of Jose Orlando 

HENAO MONTOYA. Jose Orlando HENAO MONTOYA, who had been killed in a Colombian prison in 1998 before the organization he helped form came under OFAC sanctions, had 

willed his properties and investments to his wife upon his death. 

Currently, Arcangel de Jesus HENAO MONTOYA is in a New York federal prison. In September 2005, he pled guilty in a New York court to drug traffi cking charges. 

Related Impact: 

OFAC designations and economic sanctions played a key role in the commercial and fi nancial 

isolation of the HENAO MONTOYA businesses, in publicly exposing the HENAO MONTOYA 

organization, and in increasing Colombian law enforcement pressure targeting HENAO MONTOYA’s associates and fi nancial assets: 

NORTH VALLE CARTEL 47 
IMPACT REPORT  NORTH VALLE CARTEL 

Ø In June 2004, the Colombian Government initiated an asset forfeiture investigation of 98 

properties belonging to Arcangel de Jesus HENAO MONTOYA. The properties included 

farms, apartments, houses, vacant lots and commercial buildings. 

Ø In October 2004, the Colombian Government seized 101 properties belonging to Arcangel 

de Jesus HENAO MONTOYA. They were located in Bogota, Cartagena, Tolima, Valle, 

Risaralda, Caldas, Quindio, and Boyaca in Colombia. 

SECTION 3 Ø OFAC designated the Colombian airline, Intercontinental de Aviacion, in October 2004. 

The airline had been bought by Jose Orlando HENAO MONTOYA before his death (and 

willed to his wife), along with SDNT principal individuals Gabriel PUERTA PARRA and 

Luis HERNANDEZ ZEA. The Colombian Government seized the airline four months later, in February 2005. (See also the Gabriel PUERTA PARRA and Luis HERNANDEZ ZEA 

organization). 

The HENAO MONTOYA organization was seriously impaired as a result of OFAC’s sanctions, 

the arrest of Arcangel HENAO MONTOYA, and the Colombian Government’s subsequent 

seizure of assets and companies belonging to the HENAO MONTOYA organization. 

48 NORTH VALLE CARTEL 
ORGANIZATION CHART 49

North Valle Drug Cartel: Arcangel de Jesus 

HENAO MONTOYA 

Agro-Industrial 

Cartago 1 

2 

2 

1 

1 

1 

1 

• 

• 

• 

• 

• 

• 

• 

BY REGION 

T Y P E O F I N D U S T R Y 

Valle del Cauca 

Agricola Ganadera Henao Gonzalez y Cia. S.C.S. 

Agropecuaria Miralindo S.A.

Arizona S.A.

Compañia Agroinversora Henagro Ltda.

Desarrollos Comerciales e Industriales Henao Gonzalez y Cia. S.C.S. 

Maquinaria Tecnica y Tierras Ltda. (a.k.a. M.T.T. Ltda.)

Organizacion Empresarial A de J Henao M E Hijos y Cia. S.C.S. 

Footnotes indicate date of designation by OFAC. 

(1) 18-Aug-2000

(2) 25-Oct-2002

50 ORGANIZATION TABLE 
IMPACT REPORT  NORTH VALLE CARTEL 

RAMIREZ ABADIA ORGANIZATION 

Background: 

In the late 1980s, Juan Carlos RAMIREZ ABADIA (a.k.a. “Chupeta”) began his drug traffi cking 

career with the Cali drug cartel. As that group’s power faltered, RAMIREZ ABADIA became 

a force amongst the group of drug traffickers collectively referred to as the North Valle drug 

cartel. In Colombia, he has been charged with multiple homicides, including the alleged execution of several drug traffi ckers. 

SECTION 3 

In 1994 and 1995, RAMIREZ ABADIA was indicted on U.S. federal narcotics traffi cking charges in Colorado and New York, respectively. 

In March 1996, RAMIREZ ABADIA surrendered to Colombian authorities, allegedly fearing 

for his personal safety and seeking a lenient sentence. By his own admission, RAMIREZ ABADIA had shipped 30 tons of cocaine through Mexico to the United States. After a plea bargain, 

a judge in Cali, Colombia sentenced him to more than 20 years in prison. 

On August 18, 2000, OFAC named Juan Carlos RAMIREZ ABADIA as an SDNT principal 

individual. No associated individuals, family members, or companies were named. At the time 

of his designation, RAMIREZ ABADIA continued to run his organization from jail. 

In 2002, after serving approximately seven years of his sentence, RAMIREZ ABADIA was released early from Colombian prison and has continued to manage his drug routes. 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of 

Colombia’s North Valle drug cartel, including Juan Carlos RAMIREZ ABADIA, with RICO 

violations. The U.S. federal indictment charged the North Valle drug cartel with drug traffi cking, money laundering, and the kidnapping, torture, and murder of informants and other drug 

traffi ckers. The U.S. Department of State simultaneously offered a reward of up to $5 million 

for information leading to the arrest of any of the individuals in the indictment. 

On August 29, 2006, OFAC designated four individuals and two entities associated with 

RAMIREZ ABADIA. The designated individuals included both of RAMIREZ ABADIA’s parents, two trusted business associates, and two front companies, including the pharmaceutical 

distributor Disdrogas Ltda. 

Related Impact: 

OFAC designations helped publicly identify Juan Carlos RAMIREZ ABADIA as an important 

Colombian drug cartel leader and played a role in increased Colombian law enforcement pressure targeting RAMIREZ ABADIA’s fi nancial assets: 

Ø Two months after OFAC’s designation of Juan Carlos RAMIREZ ABADIA in August 2000, 

NORTH VALLE CARTEL 51 
IMPACT REPORT  NORTH VALLE CARTEL 

Colombian authorities seized approximately 40 of his properties in Cali, Colombia. Th ese 

properties, including apartments, houses, and parking lots, were valued at approximately 

$3.5 million. 

Ø In June 2005, Colombian authorities seized 91 assets of Juan Carlos RAMIREZ ABADIA, 

including houses, apartments, and ranches located in or near the cities of Cali and Armenia. 

SECTION 3 

Ø In January 2007, Colombian authorities seized from stash houses in Cali, Colombia over 

$60 million in currency, mostly U.S. dollars, belonging to Juan Carlos RAMIREZ ABADIA. 

This is believed to be the largest cash seizure in the history of Colombia. 

52 NORTH VALLE CARTEL 
ORGANIZATION CHART 53

 North Valle Cartel: Juan Carlos 

RAMIREZ ABADIA 

Investment Pharmaceutical 

• Disdrogas Ltda.

Cali 

Cali 

•

BY REGION 

I N D U S T R Y T Y P E 

Valle del Cauca 

Yumbo 

Ramirez Abadia y Cia. S.C.S. 

All Designated by OFAC as SDNTs on 29-Aug-2006. 

54 ORGANIZATION TABLE
IMPACT REPORT  NORTH VALLE CARTEL 

PATIÑO FOMEQUE ORGANIZATION 

Background: 

There is evidence that Victor Julio PATIÑO FOMEQUE became involved in narcotics traffi cking sometime around 1992. PATIÑO FOMEQUE worked as a bodyguard for deceased North 

Valle drug cartel kingpin, Orlando HENAO MONTOYA, and quickly rose in signifi cance 

within the North Valle drug cartel leadership. PATIÑO FOMEQUE was head of one of the 

operational arms of the North Valle drug cartel by the mid-1990s. 

SECTION 3 

In the 1990s, Victor Julio PATIÑO FOMEQUE was considered one of the most successful 

maritime transporters out of the Pacific port of Buenaventura and is estimated to have moved 

at least 20 tons of cocaine to Mexico and the United States. 

In June 1995, Victor Julio PATIÑO FOMEQUE was named as a defendant in a U.S. federal 

indictment in the Southern District of Florida. He was charged with a RICO violation for drug 

trafficking and money laundering along with other high-level members of Colombia’s Cali 

drug cartel and several Mexican drug traffi ckers. The 1995 indictment stated that PATIÑO 

FOMEQUE, “ from 1992 through 1995, agreed to assist the Enterprise [Cali drug cartel] by 

providing fishing vessels to transport large amounts of cocaine from Buenaventura, Colombia 

to large ocean-going freighters off the coast of Colombia for transport into Mexico and eventual 

importation into the United States.” 

On June 24, 1995, Victor Julio PATIÑO FOMEQUE surrendered to Colombian authorities at a 

Colombian military base in Bogota, Colombia. In February 1996, he confessed to drug traffi cking and illicit enrichment. However, PATIÑO FOMEQUE continued to control his operation 

from jail. 

A February 2000 raid by Colombian authorities, nearly four years after Victor Julio PATIÑO 

FOMEQUE’s imprisonment, uncovered a drug trafficking command center in a luxury apartment in Cali, Colombia that belonged to the PATIÑO FOMEQUE organization. 

On April 24, 2001, OFAC designated Victor Julio PATIÑO FOMEQUE as an SDNT principal individual under E.O. 12978. Twenty-six individuals were named together with PATIÑO 

FOMEQUE, including key family members, business associates, and other front individuals in 

Colombia. In addition, three front companies, including two holding companies in Cali, Colombia, and the maritime company Industria de Pesca Sobre El Pacifi co S.A. in Buenaventura, 

Colombia, were named. 

In August 2001, PATIÑO FOMEQUE was released from a Colombian prison for time served. 

In August 2002, PATIÑO FOMEQUE was re-arrested in Bogota, Colombia under a new U.S. 

arrest warrant for federal charges of drug trafficking and money laundering out of the Southern District of Florida. In December 2002, PATIÑO FOMEQUE was extradited to the United 

States. 

NORTH VALLE CARTEL 55 
IMPACT REPORT  NORTH VALLE CARTEL 

Related Impact: 

In April 2001, several key family members were designated by OFAC. These individuals were 

not only key front persons for several companies, but also were considered by Colombian authorities to be important money launderers for the organization. 

Subsequent to OFAC designations on April 24, 2001, the Colombian Government also took action to apply law enforcement pressure targeting PATIÑO FOMEQUE’s associates and fi nancial 

assets: 

SECTION 3 

Ø In April 2005, the Colombian police seized 299 properties in Colombia that belonged to 

PATIÑO FOMEQUE. The properties, located in Bogota, Cali, Buenaventura, Cartagena, 

Palmira, and throughout the Valle del Cauca region, were valued at approximately $65 million. According to the Colombian authorities, PATIÑO FOMEQUE had placed these assets 

in the names of different front individuals, including many family members and employees 

who were designated as SDNTs, and who did not have the economic means to actually afford them. 

56 NORTH VALLE CARTEL 
ORGANIZATION CHART 57

 North Valle Cartel: Victor Julio 

PATIÑO FOMEQUE 

Investment Maritime 

• 

Cali 

Cali 

• 

• 

BY REGION 

I N D U S T R Y T Y P E 

Valle del Cauca 

Buenaventura Industria de Pesca Sobre El Pacifico S.A. (a.k.a. Inpesca S.A.) 

Galapagos S.A. 

Taura S.A. 

All designated by OFAC as SDNTs on 24-Apr-2001. 

58 ORGANIZATION TABLE
IMPACT REPORT  NORTH VALLE CARTEL 

MONTOYA SANCHEZ ORGANIZATION 

Background: 

Diego Leon MONTOYA SANCHEZ’s active involvement in the narcotics traffi cking trade 

began around 1996. As with other leaders of Colombia’s North Valle drug cartel, Diego Leon 

MONTOYA SANCHEZ rose to prominence as an independent drug traffi cker following the 

decline of the Cali drug cartel. He quickly became one of Colombia’s most powerful cocaine 

traffickers by orchestrating multi-ton shipments of cocaine to Mexico and the United States. 

SECTION 3 

With the help of the ARELLANO FELIX drug cartel,12 the MONTOYA SANCHEZ organization was able to ship massive quantities of drugs to the United States. U.S. and Colombian 

authorities have jointly estimated that the MONTOYA SANCHEZ organization shipped nearly 

30 tons of cocaine a month, or about 6 percent of the cocaine smuggled into the United States 

each year. 

The MONTOYA SANCHEZ organization has also been closely linked with the Colombian 

paramilitary group, Autodefenses Unidas de Colombia (“AUC”), forming an alliance with them 

to protect the drug cartel’s drug routes, laboratories, and associates. 

In 1999, a U.S. grand jury charged Diego Leon MONTOYA SANCHEZ with drug traffi cking 

and money laundering in the Southern District of Florida under an FBI criminal investigation. 

On October 25, 2002, OFAC designated Diego Leon MONTOYA SANCHEZ as an SDNT principal individual. Also named by OFAC were three companies, including Ladrillera La Candelaria Ltda., an industrial brick factory outside Cali, Colombia. In addition, OFAC designated 

Diego Leon’s two brothers, Juan Carlos and Eugenio MONTOYA SANCHEZ, key members of 

the MONTOYA SANCHEZ drug trafficking organization. Eugenio MONTOYA SANCHEZ 

ran the daily operational management of the organization. Juan Carlos MONTOYA SANCHEZ was responsible for overseeing the cocaine laboratories for the organization. OFAC’s 

October 2002 action was coordinated with a simultaneous criminal asset forfeiture action by 

the FBI Miami Field Division against several million dollars in property in South Florida owned 

by the MONTOYA SANCHEZ organization. 

In December 2003, Juan Carlos MONTOYA SANCHEZ was arrested by the Colombian National Police. 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of 

Colombia’s North Valle drug cartel, including Diego Leon MONTOYA SANCHEZ, with RICO 

violations. The U.S. federal indictment charged the North Valle drug cartel with drug traffi ck12. On June 1, 2000, Benjamin ARELLANO FELIX and Ramon ARELLANO FELIX were named drug kingpins by the 

President pursuant to the Foreign Narcotics Kingpin Designation Act. In June 2004, the President also named Javier ARELLANO FELIX and Eduardo ARELLANO FELIX as well as the ARELLANO FELIX organization as drug 

kingpins. See discussion on page one, footnote three regarding the Kingpin Act sanctions program. 

NORTH VALLE CARTEL 59 
IMPACT REPORT  NORTH VALLE CARTEL 

ing, money laundering, and the kidnapping, torture, and murder of informants and other drug 

traffi ckers. The U.S. Department of State simultaneously offered a reward of up to $5 million 

for information leading to the arrest of any of the individuals in the indictment. 

In May 2005, Diego Leon’s brother, Juan Carlos MONTOYA SANCHEZ, a designated SDNT 

individual, was extradited to the United States where he pled guilty to charges of conspiring 

to import cocaine into the United Sates and was sentenced in February 2006 to 262 months in 

prison. 

Related Impact: SECTION 3 

In concert with OFAC designations, the U.S. Government authorities also took action to apply 

law enforcement pressure targeting MONTOYA SANCHEZ’s associates and fi nancial assets: 

Ø In a coordinated action, simultaneous to the October 2002 OFAC designation, FBI agents 

seized several millions of dollars in property belonging to the MONTOYA SANCHEZ organization in South Florida. This included an 80-foot yacht worth over $3 million, two 

luxury cars, and two condominiums with a combined value of $1.7 million. 

Ø On May 6, 2004, the FBI named Diego Leon MONTOYA SANCHEZ to the FBI’s “Ten Most 

Wanted Fugitive List,” citing his OFAC designation as part of U.S. efforts against this Colombian drug lord. In addition, the U.S. Department of State has issued a $5 million reward 

for information leading to his capture. 

OFAC designations helped publicly expose the MONTOYA SANCHEZ organization and 

played a key role in increased Colombian law enforcement pressure targeting MONTOYA 

SANCHEZ’s associates and fi nancial assets: 

Ø On April 15, 2004, Colombian authorities conducted a nation-wide enforcement operation 

against the companies and property previously identified by OFAC as part of the MONTOYA SANCHEZ operation, seizing $73 million and real estate assets belonging to Diego 

Leon MONTOYA SANCHEZ, including the SDNT company Ladrillera La Candelaria 

Ltda. 

60 NORTH VALLE CARTEL 
ORGANIZATION CHART 61

North Valle Drug Cartel:Diego Leon 

MONTOYA SANCHEZ 

Industrial Investment 

Cali 

Cali 

• • 

•

BY REGION 

T Y P E O F I N D U S T R Y 

Ladrillera La Candelaria Ltda. Inversiones La Quinta y Cia. Ltda. 

Montoya Luna E Hijos y Cia. S.C.S. 

All Designated by OFAC as SDNTs on 25-Oct-2002. 

62 ORGANIZATION TABLE 
IMPACT REPORT  NORTH VALLE CARTEL 

GOMEZ BUSTAMANTE ORGANIZATION 

Background: 

From the 1990s until his detention in Cuba in 2004, Luis Hernando GOMEZ BUSTAMAN 

TE (a.k.a. “Rasguno”) was a leader in the North Valle drug cartel. Luis Hernando GOMEZ 

BUSTAMANTE’s drug trafficking organization moved cocaine via aircraft, “go-fast” vessels 

(small, powerful speedboats), and maritime cargo vessels. The organization also operated cocaine laboratories in the Valle del Cauca region of Colombia—many of which were concealed 

on his farms—as well as cocaine distribution cells in the United States. SECTION 3 

In 1997, the U.S. Attorney’s Office for the Southern District of Virginia indicted GOMEZ 

BUSTAMANTE on drug trafficking and money laundering charges as well as for operating a 

continuing criminal enterprise. Later, in October 2002, the U.S. Attorney’s Office for the Eastern District of New York also indicted GOMEZ BUSTAMANTE on charges of drug traffi cking 

and money laundering. 

On October 25, 2002, OFAC designated Luis Hernando GOMEZ BUSTAMANTE as a principal SDNT individual. OFAC also named eight businesses and nine individuals acting as fronts 

for GOMEZ BUSTAMANTE. 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of 

Colombia’s North Valle drug cartel, including Luis Hernandez GOMEZ BUSTAMANTE, with 

RICO violations. The U.S. federal indictment charged the North Valle drug cartel with drug 

trafficking, money laundering, and the kidnapping, torture, and murder of informants and 

other drug traffi ckers. The U.S. Department of State simultaneously announced a reward of up 

to $5 million for information leading to the arrest of GOMEZ BUSTAMANTE or any of the 

individuals in the indictment. Recently, the Colombian Government has issued new charges 

against Luis Hernando GOMEZ BUSTAMANTE for illicit enrichment and drug violations. 

On July 2, 2004, Luis Hernando GOMEZ BUSTAMANTE was arrested while trying to enter 

Cuba on a false passport. He is currently in a Cuban prison. 

On October 25, 2006, OFAC designated two of GOMEZ BUSTAMANTE’s brothers along with 

several key associates in a related action against two new North Valle drug cartel leaders. 

Related Impact: 

OFAC designations helped publicly expose the GOMEZ BUSTAMANTE organization and 

played a key role in increased Colombian law enforcement pressure targeting GOMEZ BUSTAMANTE’s associates and fi nancial assets: 

Ø In March 2004, the Government of Colombia seized properties belonging to Luis Hernando 

GOMEZ BUSTAMANTE valued at approximately $111 million.

NORTH VALLE CARTEL 63 
64 ORGANIZATION CHART 
 North Valle Drug Cartel: Luis Hernando 

GOMEZ BUSTAMANTE 

Agro-Industrial Investment Real Estate 

Cartago 

Ltda. 

Ganaderias Bilbao Ltda. 

Gomez Marin Ltda. 

• 

• 

• 

• 

• 

• • Inmobiliaria El Escorial Ltda.

• 

•

BY REGION 

T Y P E O F I N D U S T R Y 

Valle del Cauca 

Agricola Doima Del Norte Del Valle 

Ganaderia El Vergel Ltda. 

Viscaya Ltda. (a.k.a Vizcaya Ltda.) 

Organizacion Luis Hernando Gomez 

Bustamante y Cia. S.C.S. Inmobiliaria Linares Ltda. 

Inmobiliaria Pasadena Ltda. 

All Designated by OFAC as SDNTs on 25-Oct-2002. 

ORGANIZATION TABLE 65
IMPACT REPORT  NORTH VALLE CARTEL 

PUERTA PARRA & HERNANDEZ ZEA 


ORGANIZATION


Background: 

Before his October 7, 2004, arrest in Colombia, Gabriel PUERTA PARRA (a.k.a. “El Doctor”) 

was considered a respected elder statesman by various members of the North Valle drug cartel. In this role, PUERTA PARRA served as a conduit between the traffickers and leaders of the 

paramilitary group, the AUC, and he also resolved disputes between rival drug cartel members. 

SECTION 3 

Luis Antonio HERNANDEZ ZEA is the former pilot and business advisor for deceased North 

Valle drug cartel leader Jose Orlando HENAO MONTOYA. 

In 1985, HERNADEZ ZEA, PUERTA PARRA and HENAO MONTOYA purchased Intercontinental de Aviacion, a small Colombian airline. 

In 1998, the shares of Intercontinental de Aviacion owned by Jose Orlando HENAO MON 

TOYA—following his death—were transferred to his widow, Piedad VELEZ RENGIFO. Th is 

airline, purchased with narcotics trafficking proceeds, was a front company, used by the North 

Valle drug cartel to launder money and was used to transport narcotics and bulk currency. 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of 

Colombia’s North Valle drug cartel, including Gabriel PUERTA PARRA, with RICO violations. 

The U.S. federal indictment charged the North Valle drug cartel with drug traffi cking, money 

laundering, and the kidnapping, torture, and murder of informants and other drug traffi ckers. The U.S. Department of State simultaneously announced a reward of up to $5 million for 

information leading to the arrest of PUERTA PARRA or any of the individuals in the indictment. Additional drug trafficking charges were filed in the U.S. District Court for the Southern 

District of Florida. 

On October 14, 2004, OFAC designated Gabriel PUERTA PARRA and Luis Antonio HER 

NANDEZ ZEA as principal SDNT individuals. OFAC also added 15 of their business fronts, 

including Intercontinental de Aviacion S.A. and other aviation front companies in Colombia, 

the Cayman Islands and Vanuatu, as well as 15 front individuals to the list of SDNTs. 

In May 2006, Colombia extradited PUERTA PARRA to the United States. 

Related Impact: 

OFAC designations helped publicly expose the PUERTA PARRA and HERNADEZ ZEA organization and played a key role in increased Colombian law enforcement pressure targeting 

PUERTA PARRA and HERNADEZ ZEA’s associates and fi nancial assets: 

NORTH VALLE CARTEL 67 
IMPACT REPORT  NORTH VALLE CARTEL 

Ø In February 2005, Colombian authorities seized Intercontinental de Aviación, including its 

fleet of 6 airplanes and a hangar at Bogotá’s El Dorado airport. According to a Colombian 

source very familiar with the airline, Intercontinental de Aviacion is worth approximately 

$21 million. 

SECTION 3 

68 NORTH VALLE CARTEL 
ORGANIZATION CHART 69

North Valle Drug Cartel: Gabriel PUERTA PARRA 

& Luis Antonio HERNANDEZ ZEA 

Agro-Industrial Construction Investment Other (Hotel/ 

Mining) 

North Coast 

Aerovias Atlantico 

AeroAtlantico Ltda.) 

• 

Bogota 

Bogota 

Desarrollos 

• 

• 

de Colombia Ltda. 

INTER) 

• 

• 

• 

• 

• 

COSUR) 

• 

• 

• 

• 

Cali 

Cali • Inversiones y ComOutside of Colombia 

Cayman Islands • 

Leasing Limited 

• 

BY REGION 

T Y P E O F I N D U S T R Y 

Aviation 

Barranquilla 

Ltda. (a.k.a. 

Comercializadora 

Andino Brasilera S.A. 

(a.k.a. CABRASA) 

Agroindustriales S.A. 

Aerocomercial Alas 

Intercontinental de 

Aviacion S.A. (a.k.a. 

Intercontinental de 

Financiacion Aerea 

S.A. (a.k.a. INTERFIAR) 

Accirent S.A. 

La Frontera Union 

Galvez y Cia. S. en C. 

Asociacion Turistica 

Internacional S.C.S. 

Green Island S.A. 

Industrial Minera y 

Pecuaria S.A. (a.k.a. 

IMPECUA) 

Cia. Constructora y 

Comercializadora 

del Sur Ltda. (a.k.a. 

ercializadora Incom 

Ltda. (f.k.a. Constructora Hena Ltda.) 

Largo Leasing Ltd. 

Vanuatu Trans Pacific World 

All designated by OFAC as SDNTs on 14-Oct-2004. 

70 ORGANIZATION TABLE 
IMPACT REPORT  NORTH VALLE CARTEL 

RENTERIA MANTILLA ORGANIZATION 

Background: 

As early as the 1980s, Carlos Alberto RENTERIA MANTILLA (a.k.a. “Beto” RENTERIA)

started trafficking narcotics by selling precursor chemicals to members of the Cali drug cartel. 

Beto RENTERIA maintains a low profile and is considered by other drug cartel leaders to be an 

important and respected figure in the drug underworld. Some consider Beto RENTERIA to be 

one of the more powerful and influential drug traffickers in Colombia today. 

SECTION 3 

Since at least the early 1990s, Beto RENTERIA has been a business partner with Raul GRA 

JALES LEMOS (discussed in the following section) in various business ventures, including the 

Colombian department store Casa Estrella (formerly known as Casa Grajales). 

In 1995, the U.S. Attorney’s Office for the Southern District of Florida indicted Beto RENT 

ERIA on narcotics trafficking charges together with Raul GRAJALES LEMOS. In May 2004, 

the U.S. Attorney’s Office for the District of Columbia charged the leaders of Colombia’s North 

Valle drug cartel, including Carlos Alberto RENTERIA MANTILLA, with RICO violations. 

The U.S. federal indictment charged the North Valle drug cartel with drug traffi cking, money 

laundering, and the kidnapping, torture, and murder of informants and other drug traffi ckers. 

The U.S. Department of State simultaneously announced a reward of up to $5 million for information leading to the arrest of any of the indicted individuals. 

On March 17, 2005, OFAC named Beto RENTERIA as a principal SDNT individual. OFAC 

also designated seven individuals and four entities working for or on behalf, or owned or controlled by Beto RENTERIA. 

On November 30, 2005, OFAC designated two individuals involved in managing the already 

designated Casa Estrella department store chain on behalf of Beto RENTERIA and Raul Alberto GRAJALES LEMOS. In addition, three companies were also named, including one located 

in the United States. 

On June 13, 2006, OFAC designated five individuals involved in managing the Casa Estrella department store chain on behalf of Beto RENTERIA and Raul Alberto GRAJALES LEMOS. An 

additional 20 companies were named as SDNTs, including off-shore companies in Panama and 

the British Virgin Islands and six companies located in the United States. 

On October 31, 2006, OFAC designated ten entities associated with Beto RENTERIA, including four sugar companies, a soccer team, an accounting firm, a hotel, and two medical clinics. 

Seven individuals were also named for acting as front persons on behalf of Beto RENTERIA in 

the named companies. 

On November 28, 2006, OFAC designated fi ve off-shore companies associated with the RENTERIA MANTILLA and the GRAJALES LEMOS organizations. SDNT associates Moises Abdal 

NORTH VALLE CARTEL 71 
IMPACT REPORT  NORTH VALLE CARTEL 

SAIEH MUVDI, Carlos Ernesto SAIEH JAMIS, and Abdala SAIEH JASSIR have all played key 

management roles in Casa Estrella on behalf of the RENTERIA MANTILLA and the GRAJALES LEMOS organizations and run these fi ve off-shore companies located in Barbados, the 

British Virgin Islands, the Cayman Islands, and Panama. 

Related Impact: 

Simultaneous to Beto RENTERIA’s designation in March 2005, OFAC blocked approximately 

$1 million worth of assets belonging to RENTERIA MANTILLA and his associates. Th is action included blocking accounts, cars, and real estate in Boston, Massachusetts and Miami, SECTION 3 Florida. 

In November 2006, within 72 hours of the designation of the soccer team Cortulua, the team’s 

president and three of its five board members resigned, sponsors withdrew their support, and 

key business partners publicly announced the severing of all commercial ties with the team. 

OFAC designations helped publicly expose the Beto RENTERIA organization and played a key 

role in increased Colombian law enforcement pressure targeting Beto RENTERIA’s associates 

and fi nancial assets; 

Ø In June 2006, Colombian authorities arrested additional SDNT associates of Beto RENTERIA and Raul GRAJALES LEMOS on charges of money laundering. 

Ø In August 2006, Colombian authorities seized the department store chain Casa Estrella 

along with other companies and properties. The properties alone were estimated to be 

worth approximately $38.5 million. 

Ø On August 30, 2006, Colombian authorities seized 41 properties associated with Beto RENTERIA. The properties were located throughout Colombia, including in Bogota, Cali, the 

Valle del Cauca region and Cartagena. Included in the seizure were a multi-million dollar 

apartment in an exclusive Bogota neighborhood and an armored luxury vehicle. Th e total 

estimated value of the seizures was $18 million. 

Ø On November 30, 2006, Colombian authorities initiated an additional seizure operation 

against the assets of Beto RENTERIA. This seizure action targeted recently designated 

SDNTs, including Clinica San Francisco S.A., a hospital in Tulua, Colombia. Th e Colombian enforcement action also resulted in the seizure of properties in Bogotá and the Colombian island of San Andres. Of that which was seized, the value of the real property alone 

was estimated to be $16 million. 

72 NORTH VALLE CARTEL 
ORGANIZATION CHART 73

North Valle Drug Cartel: Carlos Alberto 

RENTERIA MANTILLA 

Agro-Industrial Investment Retail Other 

North Coast 

5 

• 

3 

4 

Ltda.)4 

4 

4 

4 

• 

• 

• 

• 

• 

• 

2 • 4 

Urbavista)4 

• 

• 

Bogota 

Bogota 

1 

1 

Inagroccidente)1 

5 

• 

• 

• 

• 

2 

1 

1 

cidente)1 

• 

• 

• 

• 

La Union 

2 

• 

2 

2 

Macedonia Ltda.2 

2 

• 

• 

• 

• 

2 

• 

2 • 

Apoyos Diagnosticos De Occidente 

5 

5 

5 

• 

• 

• 

Cali 

Cali 5 

5 

5 

• 

• 

• 5 

• 

BY REGION 

(2) 11-May-2005 

(3) 30-Nov-2005 

(4) 13-Jun-2006 

(5) 31-Oct-2006 

(6) 28-Nov-2006 

Footnotes indicate date of 

T Y P E O F I N D U S T R Y 

San Andres 

Corporacion Hotelera Del Caribe 

Limitada (a.k.a.. Apartahotel Tres 

Casitas; a.k.a. “Tres Casitas”)

Barranquilla Armando Jaar Y Cia. S.C.S

Carlos Saieh Y Cia. S.C.S. 

Finanzas Del Norte Luis Saieh Y Cia. 

S.C.A. (F.K.A. Finanzas Del Norte 

Inversiones Del Prado Abdala Saieh 

Y Cia. S.C.A.

Moises Saieh Y Cia. S.C. A.

Ricardo Jaar Y Cia. S.C.S. 

Confecciones Lord S.A.

Constructora Altavista Internacional 

S.A. (a.k.a. Conasa S.A.)

Urbanizadora Altavista Internacional S.A. (f.k.a. Telnet S.A.; a.k.a. 

Colombo Andina Commercial Ltda. 

(a.k.a. Coalsa)

Compania Agropecuaria del Sur 

Ltda. (a.k.a. Coagrosur)

Inversiones Agroindustriales del 

Occidente Ltda. (a.k.a. 

Inversiones Brasilar S.A. (f.k.a. Inversiones Rivera Caicedo Y Cia S.C.S.; 

f.k.a. “Inrica”)

Agropecuaria El Nilo S.A. (a.k.a. 

Agronilo S.A.)

Colombo Andina Commercial Ltda. 

(a.k.a. Coalsa)

Compania Agropecuaria del Sur 

Ltda. (a.k.a. Coagrosur)

Inversiones Agroindustriales del 

Occidente Ltda. (a.k.a. InagrocValle del Cauca 

Agropecuaria El Nilo S.A. (a.k.a. 

Agronilo S.A.)

Agustin Grajales Y Cia. Ltda.

Armagedon S.A.

Salim S.A.

Toro Agropecuaria El Nilo S.A. (a.k.a. 

Agronilo S.A.)

Tulua 

Josafat S.A.

Apoyos Diagnosticos S.A. (a.k.a. 

S.A.; f.k.a. Unidad De Diagnostico 

Medico Especializado Ltda.; f.k.a. 

“Unides Ltda.”)

Clinica San Francisco S.A. (f.k.a. 

Clinica De Occidente Tulua S.A.; 

f.k.a. Clinica Nuestra Senora De 

Fatima S.A.)

Corporacion Club Deportivo Tulua 

(a.k.a. Cortulua)

Agropecuaria Lindaraja S.A.

Canaduz S.A.

Tarritos S.A.

Camacho Vallejo Asesores E.U. 

(a.k.a. Camacho Vallejo Contadores)

(1) 17-Mar-2005 

designation by OFAC. 

74 ORGANIZATION TABLE 
North Valle Drug Cartel: Carlos Alberto 

RENTERIA MANTILLA Continued 

Agro-Industrial Investment Retail Other 

Outside of Columbia 

Aruba 2 • 

Florida (USA) 4 

Jacaria Florida3 

4 

4 

4 

4 

4 

• 

• 

• 

• 

• 

• 

• 

Barbados 6 • 

Cayman 

Islands Brunello Ltd.6 

Jamce Investments Ltd. 

• 

• 

4 

4 

4 

5 

4 

6 

• 

• 

• 

• 

• 

• 

2 • 

Islands 

Gimber Investing 4 

6 

• 

• (2) 11-May-2005 

(3) 30-Nov-2005 

(4) 13-Jun-2006 

(5) 31-Oct-2006 

(6) 28-Nov-2006 

Footnotes indicate date of 

BY REGION 

T Y P E O F I N D U S T R Y 

Blackmore Investments A.V.V. 

Granada Associates, Inc. 

Karen Overseas Florida, Inc. 

Marc Llc. 

Sunset & 97th Holdings, Llc. 

Villarosa Investments Florida, Inc. 

Alm Investment Florida, Inc., 

Kattus Corporation

Panama Cipe Investments Corporation

Elizabeth Oversaeas, Inc. 

Karen Overseas, Inc. 

Kutry Management Inc. 

Rixford Investment 

Corporation

Villarosa Investments Corporation

Kattus Ii Corporation

British Virgin 

Corporation

MLA Investments Inc. 

(1) 17-Mar-2005 

designation by OFAC. 

ORGANIZATION TABLE 75

IMPACT REPORT  NORTH VALLE CARTEL 

GRAJALES LEMOS ORGANIZATION 

Background: 

Raul Alberto GRAJALES LEMOS began his drug trafficking activities as early as 1985. For 

many years, Raul Alberto GRAJALES LEMOS maintained significant business relationships 

with other narcotics traffickers of the North Valle drug cartel, including SDNT principal individuals Ivan URDINOLA GRAJALES and Carlos Alberto RENTERIA MANTILLA. 

In 1994, Raul Alberto GRAJALES LEMOS was indicted on cocaine trafficking charges in the SECTION 3 

Southern District of Florida. In 1995, the indictment against Raul Alberto GRAJALES LEMOS 

was superseded to include Beto RENTERIA. 

On May 11, 2005, OFAC designated Raul Alberto GRAJALES LEMOS as an SDNT principal 

individual and also named 32 companies and 30 other individuals as SDNTs. Th e fi nancial 

network managed by Raul Alberto GRAJALES LEMOS, known as Grupo Grajales, consists of 

agricultural companies, a winery, a hotel, a department store chain (Casa Estrella), and multiple 

holding companies in Colombia and Aruba. Most of the other individuals designated are family members and associates of Raul Alberto GRAJALES LEMOS who assist in the management 

of this fi nancial network. 

On November 30, 2005, OFAC designated two individuals involved in managing the already 

designated Casa Estrella department store chain on behalf of Raul Alberto GRAJALES LEMOS 

and Beto RENTERIA. In addition, three companies were also named, including one located in 

the United States. 

On June 13, 2006, OFAC designated five individuals involved in managing the Casa Estrella department store chain on behalf of Raul Alberto GRAJALES LEMOS and Beto RENTERIA. An 

additional 20 companies were named as SDNTs, including off-shore companies in Panama and 

the British Virgin Islands and six companies located in the United States. 

On November 28, 2006, OFAC designated 17 companies controlled directly by Raul GRAJALES 

LEMOS or indirectly through his family members and close associates. These companies, all 

located in Colombia, are involved in various economic sectors, including consulting, telecommunications, construction, and agriculture. Four additional associates of Raul GRAJALES 

LEMOS were also named as SDNTs. 

Also on November 28, 2006, OFAC designated fi ve off-shore companies associated with the 

RENTERIA MANTILLA and the GRAJALES LEMOS organizations, located in Barbados, the 

British Virgin Islands, the Cayman Islands, and Panama.13 

13. SDNT associates Moises Abdal SAIEH MUVDI, Carlos Ernesto SAIEH JAMIS, and Abdala SAIEH JASSIR run 

these fi ve off-shore companies on behalf of the RENTERIA MANTILLA and the GRAJALES LEMOS organizations and have also played key management roles in Casa Estrella. See also “RENTERIA MANTILLA Organization” chart. 

NORTH VALLE CARTEL 77 
IMPACT REPORT  NORTH VALLE CARTEL 

OFAC continues to investigate front persons and companies that are acting for or on behalf of 

Raul Alberto GRAJALES LEMOS and Beto RENTERIA. 

Related Impact: 

OFAC designations since May 2005 helped publicly expose the GRAJALES LEMOS organization and played a key role in increased Colombian law enforcement pressure targeting GRAJALES LEMOS’s associates and fi nancial assets. 

SECTION 3 Ø In the days following the designation of Raul GRAJALES LEMOS on May 11, 2005, Colombian authorities arrested him and several of his SDNT associates on charges of money 

laundering. 

Ø In June 2005, one month after OFAC’s designation of the Grupo Grajales companies, Colombian authorities seized many of the designated companies, including the winery and 

fruit companies, as well as real estate and other assets, estimated to be valued at well over 

$100 million. 

Ø In October 2005, additional properties belonging to Grupo Grajales were seized. 

Ø In June 2006, additional SDNT associates of Raul GRAJALES LEMOS and Beto RENTERIA were arrested by Colombian authorities on charges of money laundering. 

Ø In August 2006, Colombian authorities seized the SDNT department store chain Casa Estrella along with other companies and properties. The properties alone were estimated to 

be worth approximately $38.5 million 

78 NORTH VALLE CARTEL 
ORGANIZATION CHART 79

North Valle Drug Cartel: Raul Alberto 

GRAJALES LEMOS 

Agro-Industrial Investment Retail Other 

North Coast 

2 

3 

Ltda.)3 

3 

3 

3 

• 

• 

• 

• 

• 

• 

3 

3 

Urbavista)3 

• 

• 

• 

Malambo 1 • 

Bogota 

Bogota 

1 

• 

1 

1 

1 

1 

1 

• 

• 

• 

• 

• 

Ltda.2 

4 

1 

• 

• 

• 

La Union 

1 

Construcciones E Inversiones Ltda.4 

4 

4 

1 

1 

1 

• 

• 

• 

• 

• 

• 

• 

1 

1 

1 

1 

1 

1 

1 

1 

Inversiones Santa Monica Ltda.1 

Macedonia Ltda.1 

1 

Ltda. 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Citicar Ltda.4 

Confecciones Lina Maria Ltda.4 

1 

• 

• 

• 

1 

• 

1 

Ibadan Ltda.1 

1 

• 

• 

• 

Jehova Ltda.4 • 

Cali 

Cali 

4 

4 

• 

• 1 • 

4 

4 

Ltda.4 

4 

Melon Ltda.4 

Plaza Real Ltda.4 

• 

• 

• 

• 

• 

• 

Outside of Colombia 

Florida 2 

3 

3 

3 

3 

3 

3 

• 

• 

• 

• 

• 

• 

• 

BY REGION 

Footnotes indicate date of 

(3) 13-Jun-2006

 (4) 28-Nov-2006

 (1) 11-May-2005

 (2) 30-Nov-2005 

T Y P E O F I N D U S T R Y 

Barranquilla Armando Jaar Y Cia. S.C.S. 

Carlos Saieh Y Cia. S.C.S. 

Finanzas Del Norte Luis Saieh Y 

Cia. S.C.A. (f.k.a. Finanzas Del Norte 

Inversiones Del Prado Abdala Saieh 

Y Cia. S.C.A.,

Moises Saieh Y Cia. S.C.A.

Ricardo Jaar Y Cia. S.C.S. 

Confecciones Lord S.A.

Constructora Altavista Internacional 

S.A. (a.k.a. Conasa S.A.)

Urbanizadora Altavista Internacional S.A. (f.k.a. Telnet S.A.; a.k.a. 

Industrias Del Espiritu Santo S.A.

International Freeze Dried S.A. (a.k.a. 

IFD S.A.)

Almacaes S.A.

Corporacion De Almacenes Por Departamentos S.A. (a.k.a. C.A.D. S.A.)

G.L.G. S.A. (a.k.a. Casa Estrella)

Ilovin S.A.

Ramal S.A.

Comercializadora Pelissier Ospina 

Manufacturas Real S.A. (f.k.a. Manufacturas Real Ltda.)

Salome Grajales Y Cia. Ltda.

Valle del Cauca 

Casa Grajales S.A.

Doxa S.A.

Fundacion Centro Fruticola Andino

Frutas Exoticas Colombianos S.A. 

(a.k.a. Frexco S.A.)

Grajales S.A.

Transportes Del Espiritu Santo S.A.

Agustin Grajales Y Cia. Ltda.

Armagedon S.A.

Creta S.A.

GAD S.A.

Inversiones Aguila Ltda.

Inversiones Grame Ltda.

Inversiones Los Posso Ltda. S.C.S. 

Inversiones Santa Cecilia S.C.S. 

Salim S.A.

Sociedad De Negocios San Augustin 

Los Vinedos De Getsemani S.A. 

(a.k.a. Hotel Los Vinedos)

Toro Agropecuaria El Nilo S.A. (a.k.a. 

Agronilo S.A.)

Tulua Hebron S.A.

Josafat S.A.

GBS Trading S.A.

World Working Comercializadora 

Internacional S.A. (f.k.a. C.I. Glos’s 

International S.A.; a.k.a. World Working C.I.)

Panamericana Ltda.

Asesores Consultores Asociados 

Ltda. (a.k.a. Aca Ltda.)

Cali @ Tele.Com Ltda. (a.k.a. Hola 

Telecomunicaciones)

Comunicaciones Abiertas Camary 

L.GR. E.U. (a.k.a. Plateria L.Gr. E.U.)

Jacaria Florida, Inc. (Miami, Florida)

Alm Investment Florida, Inc. 

Granada Associates, Inc. 

Karen Overseas Florida, Inc. 

Sunset & 97th Holdings, Llc. 

Villarosa Investments Florida, Inc. 

Marc Llc. 

designation by OFAC.

80 ORGANIZATION TABLE 
North Valle Drug Cartel: Raul Alberto 

GRAJALES LEMOS 

Agro-Industrial Investment Retail Other 

1 

• 

Cipe Investments 3 

4 

3 

3 

3 

3 

• 

• 

• 

• 

• 

• 

Gimber Investing 3 • 

Aruba 3 • 

Footnotes indicate date of 

(3) 13-Jun-2006

 (4) 28-Nov-2006

 (1) 11-May-2005

 (2) 30-Nov-2005 

T Y P E O F I N D U S T R Y 

Panama 

Industrias Agropecuarias El Eden 

S.A.

Corporation

Eagle Communication Brokers Inc. 

Elizabeth Overseas Inc. 

Karen Overseas, Inc. 

Rixford Investment 

Corporation

Kattus Ii Corporation

Corporation

Blackmore Investments A.V.V. 

designation by OFAC. British Virgin 

Islands 

ORGANIZATION TABLE 81 
IMPACT REPORT  NORTH VALLE CARTEL 

VARELA ORGANIZATION 

Background: 

Wilber VARELA is a leader in the North Valle drug cartel, responsible for, among his other responsibilities, the oversight of security and enforcement for the drug cartel. This former police 

officer began as the lead assassin working for Jose Orlando HENAO MONTOYA,14 who until 

his death in 1998, was the undisputed head of the North Valle drug cartel. After Jose Orlando 

HENAO MONTOYA’s death, VARELA rose in the drug cartel ranks by killing, one after another, rival drug cartel leaders. SECTION 3 

In May 2004, the U.S. Attorney’s Office for the District of Columbia charged the leaders of 

Colombia’s North Valle drug cartel, including Wilber VARELA, with RICO violations. Th e U.S. 

federal indictment charged the North Valle drug cartel with drug traffi cking, money laundering, and the kidnapping, torture, and murder of informants and other drug traffi ckers. Th e 

U.S. Department of State simultaneously announced a reward of up to $5 million for information leading to the arrest of any of the individuals on the indictment. Additionally, the U.S. 

Attorney’s Office for the Eastern District of New York separately indicted VARELA on narcotics 

traffi cking charges. 

On November 9, 2005, OFAC named Wilber VARELA (a.k.a. “Jabon”) as a principal SDNT 

individual of the North Valle drug cartel. OFAC also designated 10 associates and four entities, 

including a front company in Mexico, connected with VARELA’s drug traffi cking organization. 

On October 25, 2006, OFAC designated Carlos Arturo PATIÑO RESTREPO (a.k.a. “Patemuro”), a rising North Valle drug cartel trafficker, who has been tied to SDNT principal individuals Luis Hernando GOMEZ BUSTAMANTE as well as Wilber VARELA. Two PATIÑO 

RESTREPO companies, located in Pereira, Colombia—Comercializadora de Café del Occidente 

Codecafe Ltda. and Inversiones Macarnic Patiño y Cia S.C.S.—were also named. 

Related Impact: 

OFAC designations since November 2005 helped publicly expose the VARELA organization 

and played a key role in increased Colombian law enforcement pressure targeting VARELA’s 

associates and fi nancial assets: 

Ø In November 2005, VARELA associate and SDNT individual Julio Cesar LOPEZ PEÑA was 

arrested in Colombia. He was extradited to the Southern District of New York in March 

2006, where he has been indicted on narcotics traffi cking charges.

Ø In May 2006, Colombian law enforcement arrested VARELA associate Luis Enrique CALLE 

14. Older brother of SDNT principal Arcangel de Jesus HENAO MONTOYA. 

NORTH VALLE CARTEL 83 
IMPACT REPORT  NORTH VALLE CARTEL 

SERNA, who was named an SDNT individual in the November 2005 action. 

Ø In June 2006, the Colombian National Police raided the offices of key VARELA associate 

Roberto LONDOÑO VELEZ, who was named an SDNT individual in the November 2005 

OFAC action. 

SECTION 3 

Ø In September 2006, Colombian authorities seized properties and companies belonging to 

SDNT individual Eduardo RESTREPO VICTORIA (a.k.a. “El Socio”), who is a key associate 

of the VARELA organization. Colombian authorities valued the seized assets at more than 

$22 million. 

84 NORTH VALLE CARTEL 
ORGANIZATION CHART 85

 North Valle Drug Cartel: Wilber 

VARELA 

Agro-Industrial Investment Other/Commercial 

Central Colombia-Armenia 

Armenia Asesorias Profesionales Ltda. 

Plastec Ltda. 

• 

• 

Ibague • 

• • 

Outside of Colombia 

Mexico • 

BY REGION 

I N D U S T R Y T Y P E 

Agropecuaria Palma del Rio S.A. 

Pereira Comercializadora De Café Del Occidente 

Codecafe Ltda. (a.k.a. Codecafe) 

Inversiones Macarnic Patiño y Cia. 

S.C.S. 

RR Tour S.A. de C.V. 

All Designated by OFAC as SDNTs on 9-Nov-2005. 

86 ORGANIZATION TABLE
IMPACT REPORT  NORTH VALLE CARTEL 

CANO CORREA ORGANIZATION 

Background: 

Jhonny CANO CORREA worked as a key lieutenant in the drug trafficking organization led by 

SDNT principal Luis Hernandez GOMEZ BUSTAMANTE, designated by OFAC in October 

2002. A violent drug trafficker, Jhonny CANO CORREA is allegedly responsible for multiple 

murders. Following GOMEZ BUSTAMANTE’s arrest in 2004, CANO CORREA rose within 

the North Valle drug cartel to become a leader of his own drug traffi cking organization. 

SECTION 3 

In July 2003, Jhonny CANO CORREA was indicted on drug trafficking and money laundering 

charges in the District Court for the Eastern District of New York. 

In October 2005, Colombian authorities arrested Jhonny CANO CORREA. He was extradited 

to the United States on September 22, 2006. 

On October 25, 2006, OFAC designated Jhonny CANO CORREA as a principal leader in the 

North Valle drug cartel. The designation included Jhonny CANO CORREA’s principal holding 

company, Cano Agudelo S. en C., and three business associates. 

Related Impact: 

OFAC’s recent designations in October 2006 helped identify and expose the CANO CORREA 

organization. CANO CORREA businesses in Colombia now face the prospect of commercial 

and financial isolation. 

NORTH VALLE CARTEL 87 
88 ORGANIZATION CHART 
 North Valle Cartel: Jhon Eidelber 

CANO CORREA 

Hotel Investment 

Alcala • 

Cartago 

•

BY REGION 

I N D U S T R Y T Y P E 

Valle del Cauca 

Cano Agudelo S. en C. 

Gaviotas Ltda. (a.k.a. Hotel Sin Pecados; a.k.a. Motel Campo 

Amor; a.k.a. “Hotel Sin Pk2”) 

All Designated by OFAC as SDNTs on 25-Oct-2006. 

ORGANIZATION TABLE 89
IMPACT REPORT  NORTH VALLE CARTEL 

SABOGAL ZULUAGA ORGANIZATION 

Background: 

Orlando SABOGAL ZULUAGA served as a lieutenant in the Luis Hernando GOMEZ BUSTAMANTE drug trafficking organization. GOMEZ BUSTAMANTE, designated by OFAC in 

October 2002, was one of North Valle’s top leaders until his arrest in 2004. With GOMEZ 

BUSTAMANTE’s organization now impaired, SABOGAL ZULUAGA became one of the 

North Valle drug cartel’s most powerful leaders, forming his own drug traffi cking organization. 

Press reports have called SABOGAL ZULUAGA the second-in-command of the North Valle SECTION 3 

drug cartel. 

In July 2003, Orlando SABOGAL ZULUAGA was indicted on drug trafficking and money laundering charges in the District Court for the Eastern District of New York. 

On October 25, 2006, OFAC named Orlando SABOGAL ZULUAGA as a principal leader in 

the North Valle drug cartel. Included in this designation were several key family members of 

SABOGAL ZULUAGA and their principal holding company, Orlando Sabogal Zuluaga e Hijos 

& Cia. S. en C. in Colombia. Orlando SABOGAL ZULUAGA and his family members all had 

alternative forms of identification from Venezuela. 

On October 26, 2006, Orlando SABOGAL ZULUAGA was arrested by Spanish authorities 

outside of Madrid, Spain. He awaits extradition to the United States. 

Related Impact: 

OFAC’s recent designations in October 2006 helped identify and expose the SABOGAL ZULUAGA organization. SABOGAL ZULUAGA businesses in Colombia now face the prospect of 

commercial and financial isolation. 

Shortly after his designation, SABOGAL ZULUAGA was arrested by Spanish police outside of 

Madrid, Spain. 

NORTH VALLE CARTEL 91 
92 ORGANIZATION CHART 
 North Valle Cartel: Orlando 

SABOGAL ZULUAGA 

Investment 

Ansermanuevo 

•

BY REGION 

I N D U S T R Y T Y P E 

Valle del Cauca 

Orlando Sabogal Zuluaga E Hijos & Cia. S. en C. 

Designated by OFAC as an SDNT on 25-Oct-2006. 

ORGANIZATION TABLE 93
94 MAP OF COLOMBIA City in bold marks location of North Coast drug cartel businesses.
IMPACT REPORT  NORTH COAST CARTEL 

NORTH COAST CARTEL


On May 27, 1998, OFAC expanded its list of SDNT principal individuals beyond the Cali drug 

cartel to include Julio Cesar NASSER DAVID, a long-time leader of Colombia’s North Coast 

drug cartel. Drug traffickers along Colombia’s northern coast originally operated as maritime 

transporters for the Cali and Medellin drug cartels. Although smaller and more de-centralized 

than both the Cali and North Valle drug cartels, the more autonomous networks of independent maritime drug traffickers, such as Julio Cesar NASSER DAVID, are both highly profi table 

and powerful. 

To date, DEA has identified several drug trafficking organizations based on the North Coast of 

Colombia that use maritime shipping routes in the Caribbean to funnel tons of cocaine to the 

United States each year. These organizations direct networks of transporters that oversee the SECTION 4 

importation, storage, exportation, and wholesale distribution of cocaine destined for the United 

States. In the 1990s, the North Coast of Colombia also became a major embarkation zone 

for “go-fast” vessels laden with multi-ton quantities of cocaine destined for the United States 

through Caribbean and Central American countries. According to DEA testimony, it is estimated that several hundred “go-fast” boats leave the North Coast annually and each “go-fast” 

has the capability to transport between 1.5 and 2 metric tons of cocaine. 

Maritime drug trafficking from the North Coast of Colombia continues to present a major 

threat and several U.S. law enforcement operations have targeted the activity. “Operation Panama Express,” an Organized Crime Drug Enforcement Task Force (“OCDETF”) investigation 

under the U.S. Attorney’s Office for the Middle District of Florida (Tampa Division) includes 

the participation of the Department of Homeland Security’s Immigration and Customs Enforcement (“ICE”), the Drug Enforcement Administration, the Federal Bureau of Investigation 

(“FBI”), the Internal Revenue Service (“IRS”) and state and local law enforcement. Since the late 

1990s, “Operation Panama Express” has investigated cocaine smuggling organizations that are 

responsible for the transportation of cocaine through the Caribbean Sea (via vessel) to transshipment locations, such as Mexico, for later distribution in the United States. As of January 

2006, “Operation Panama Express” has been responsible for the seizure and/or destruction at 

sea of approximately 469.4 tons of cocaine and the arrest of over 1,085 persons involved in drug 

trafficking from Colombia’s North Coast. 

Julio Cesar NASSER DAVID, now deceased, smuggled multi-ton quantities of cocaine and 

marijuana to the United States via commercial shipments and maritime vessels from the northern coast of Colombia. Relying on the use of containerized cargo, he transported the narcotics 

through national and international waters. 

NORTH COAST CARTEL 95 
IMPACT REPORT  NORTH COAST CARTEL 

NASSER DAVID ORGANIZATION 

Background: 

In 1976, Julio Cesar NASSER DAVID first became involved in narcotics trafficking. Based out 

of Colombia’s North Coast region, Julio Cesar NASSER DAVID started a major drug traffi cking 

and money laundering organization that eventually smuggled multi-ton quantities of cocaine 

and marijuana into the United States. 

In 1989, Julio Cesar NASSER DAVID was indicted on narcotics trafficking and money laundering charges in the Western District of Louisiana. He was later indicted in 1995 on narcotics 

trafficking and money laundering charges by the U.S. Attorney’s Office for the Southern District of Florida. In 1997, Julio Cesar NASSER DAVID was arrested by Colombian authorities. 

Arrests of several key family members followed. SECTION 4 

On May 27, 1998, OFAC designated Julio Cesar NASSER DAVID as an SDNT principal individual and also named four associated individuals and 14 companies as SDNTs. A total of 12 

additional companies were named as SDNTs in June 1999 and December 2000. Most of the 

designated companies were involved in hotels and real estate in Barranquilla, Colombia. 

Julio Cesar NASSER DAVID remained incarcerated in Colombia until his death in 2001. 

Related Impact: 

The May 1998 OFAC designation of NASSER DAVID as an SDNT principal individual, coming 

a year after his arrest in Colombia, disrupted his ability to effectively manage his fi nancial network from jail. After OFAC designation, Colombian businessmen in Barranquila avoided doing 

business with NASSER DAVID’s companies for fear that they, too, would face designation. 

OFAC designations since May 1998 helped publicly expose the NASSER DAVID organization 

and played a key role in increased Colombian law enforcement pressure targeting NASSER 

DAVID’s associates and fi nancial assets: 

Ø The majority of NASSER DAVID’s assets were tied to several hotels and real estate management companies in Barranquilla, Colombia. Hotel del Prado, the only four-star hotel in 

Barranquilla for many years, was wholly owned by the NASSER DAVID front companies 

designated by OFAC. The Colombian Government seized Hotel del Prado in March 1997 

along with many other assets. The forfeiture proceedings following the seizure were fi nalized in January 2007. The forfeited assets, valued at approximately $44 million, included 20 

NASSER DAVID companies, most of which were designated by OFAC.

This organization was seriously impaired as a result of NASSER DAVID’s arrest, OFAC sanctions, and NASSER DAVID’S subsequent death. 

NORTH COAST CARTEL 97 
98 ORGANIZATION CHART 
North Coast Drug Cartel: Julio Cesar 

NASSER DAVID 

Agro-Industrial Hotel Management Real Estate Other 

North Coast 

Agricola Songo Ltda.1 

2 

• 

• 

1 

Hoteles e Inmuebles de 

Hotincol)1 

Inmobiliaria del Caribe 

Ltda.1 

1 

1 

ribe)1 

quilla Ltda.1 

1 

• 

• 

• 

• 

• 

• 

• 

• 

lar Ltda.)1 

Edificaciones del Caribe 1 

Inversiones Namos y Cia. 

Ltda.2 

Negocios y Propiedades del 

Ltda.)1 

Promociones y Construcciones del Caribe Ltda.1 

Promociones y Construccio1 

2 

2 

• 

• 

• 

• 

• 

• 

• 

• 

2 

3 

2 

2 

3 

Villa D’arte)2 

• 

• 

• 

• 

• 

BY REGION 

•

T Y P E O F I N D U S T R Y 

Barranquilla 

Campo Verde Ltda.

Gran Compañia de Hoteles 

Ltda. (a.k.a. Granco)

Colombia Ltda. (a.k.a. 

Inmobiliaria Hotelera del 

Caribe Ltda. (a.k.a. Inhocar)

Inversiones Hoteleras del 

Litoral Ltda. (a.k.a. Inhotel)

Inversiones Prado Trade 

Center Ltda. (a.k.a. IpracaPromotora Hotel BarranSuramericana de Hoteles 

Ltda. (a.k.a. Suratel)

Desarrollos Urbanos “Desarrollar” Ltda. (a.k.a. DesarrolLtda. (a.k.a. Edificar)

Caribe Ltda. (f.k.a. Negociar 

nes del Caribe Ltda. y Cia. 

S.C.A. (a.k.a. Promocon)

Proyectos J.A.M. Ltda.

Proyectos J.A.M. Ltda. Y Cia. 

S. en C. 

C.N.A. Publicidad Ltda.

Happy Days S. de H.

K. P. To Jeans Wear S. de H.

Titos Bolo Club

Vestimenta J y J S. de H.

Villa de Arte S. de H. (a.k.a. 

Footnotes indicate date of designation by OFAC. 

(1) 26-May-1998

(2) 8-Jun-1999

(3) 7-Dec-2000

ORGANIZATION TABLE 99 
APPENDIX 

APPENDIX

100 IMPACT REPORT 
APPENDIX 

A. AUTHORITIES 

International Emergency Economic Powers Act (“IEEPA”).................................................................................................... 102 

Executive Order 12978 .................................................................................................................................................................... 107

Code of Federal Regulations- Title 31, Part 536 (31 CFR 536) .............................................................................................. 110

18 U.S.C. § 3571 ................................................................................................................................................................................ 123

B. DESIGNATION ANNOUNCEMENTS AND CHARTS 

Treasury Press Release 05-Mar-96 ....................................................................................................................... 124

....................................................................................................................... 125

....................................................................................................................... 126

....................................................................................................................... 127

....................................................................................................................... 128

....................................................................................................................... 130

....................................................................................................................... 131

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....................................................................................................................... 134

....................................................................................................................... 135

....................................................................................................................... 136

....................................................................................................................... 137

....................................................................................................................... 138

....................................................................................................................... 139

....................................................................................................................... 140

....................................................................................................................... 141

....................................................................................................................... 142

....................................................................................................................... 143

....................................................................................................................... 144

....................................................................................................................... 145

....................................................................................................................... 147

....................................................................................................................... 148

....................................................................................................................... 150

....................................................................................................................... 151

....................................................................................................................... 153

....................................................................................................................... 154

....................................................................................................................... 156

....................................................................................................................... 157

....................................................................................................................... 159

....................................................................................................................... 160

....................................................................................................................... 162

....................................................................................................................... 163

....................................................................................................................... 164

....................................................................................................................... 165

....................................................................................................................... 167

....................................................................................................................... 168

....................................................................................................................... 170

....................................................................................................................... 171

....................................................................................................................... 173

....................................................................................................................... 174

....................................................................................................................... 175

Southern District of New York

....................................................................................................................... 176

....................................................................................................................... 179

....................................................................................................................... 181

White House Press Release 15-Jan-97 

Treasury Press Release 17-Apr-97 

Treasury Press Release 30-Jul-97 

Treasury Press Release 26-May-98 

Treasury Press Release 08-Jun-99 

Treasury Press Release 23-Feb-00 

Treasury Press Release 18-Aug-00 

Treasury Press Release 22-Dec-00 

Treasury Press Release 24-Apr-01 

Treasury Press Release 25-Oct-02 

Designation Chart Oct-02 

Treasury Press Release 06-Feb-03 

Designation Chart Feb-03 

Treasury Press Release 21-Mar-03 

Designation Chart Mar-03 

Treasury Press Release 27-Mar-03 

Designation Chart Mar-03 

Treasury Press Release 17-Oct-03 

Designation Chart Oct-03 

Treasury Press Release 14-Sep-04 

Designation Chart Sep-04 

Treasury Press Release 14-Oct-04 

Designation Chart Oct-04 

Treasury Press Release 17-Nov-04 

Designation Chart Nov-04 

Treasury Press Release 17-Mar-05 

Designation Chart Mar-05 

Treasury Press Release 11-May-05 

Designation Chart Apr-05 

Treasury Press Release 09-Nov-05 

Designation Chart Nov-05 

Treasury Press Release 30-Nov-05 

Designation Chart Nov-05 

Treasury Press Release 13-Jun-06 

Designation Chart Jun-06 

Treasury Press Release 29-Aug-06 

Designation Chart Aug-06 

Treasury Press Release 25-Oct-06 

Designation Chart Oct-06 

Treasury Press Release 31-Oct-06 

Designation Chart Oct-06 

 Press Release 16-Nov-06 

Treasury Press Release 28-Nov-06 

Designation Chart Nov-06 

IMPACT REPORT 

APPENDIX 

101 
APPENDIX A  AUTHORITIES 

International Emergency Economic Powers Acts (“IEEPA”) 

UNITED STATES CODE 

TITLE 50. WAR AND NATIONAL DEFENSE 

CHAPTER 35. INTERNATIONAL EMERGENCY ECONOMIC POWERS 

§ 1701. Unusual and extraordinary threat; declaration of national emergency; exercise of 

Presidential authorities 

(a) Any authority granted to the President by section 1702 of this title may be exercised to deal 

with any unusual and extraordinary threat, which has its source in whole or substantial part 

outside the United States, to the national security, foreign policy, or economy of the United 

States, if the President declares a national emergency with respect to such threat. 

(b) The authorities granted to the President by section 1702 of this title may only be exercised to 

deal with an unusual and extraordinary threat with respect to which a national emergency has 

been declared for purposes of this chapter and may not be exercised for any other purpose. Any 

exercise of such authorities to deal with any new threat shall be based on a new declaration of 

national emergency which must be with respect to such threat. 

§ 1702. Presidential authorities 

(a)(1) At the times and to the extent specified in section 1701 of this title, the President may, 

under such regulations as he may prescribe, by means of instructions, licenses, or otherwise-- 

(A) investigate, regulate, or prohibit-- 

(i) any transactions in foreign exchange, 

(ii) transfers of credit or payments between, by, through, or to any 

banking institution, to the extent that such transfers or payments involve 

any interest of any foreign country or a national thereof, 

(iii) the importing or exporting of currency or securities,

by any person, or with respect to any property, subject to the jurisdiction 

of the United States; 

(B) investigate, block during the pendency of an investigation, regulate, direct 

and compel, nullify, void, prevent or prohibit, any acquisition, holding, 

withholding, use, transfer, withdrawal, transportation, importation or exportation 

of, or dealing in, or exercising any right, power, or privilege with respect to, or 

transactions involving, any property in which any foreign country or a national 

thereof has any interest by any person, or with respect to any property, subject to 

the jurisdiction of the United States; and 

(C) when the United States is engaged in armed hostilities or has been attacked 

by a foreign country or foreign nationals, confiscate any property, subject to the 

jurisdiction of the United States, of any foreign person, foreign organization, or 

foreign country that he determines has planned, authorized, aided, or engaged in 

such hostilities or attacks against the United States; and all right, title, and 

interest in any property so confiscated shall vest, when, as, and upon the terms 

directed by the President, in such agency or person as the President may 

designate from time to time, and upon such terms and conditions as the President 

102 IMPACT REPORT 
APPENDIX A  AUTHORITIES

may prescribe, such interest or property shall be held, used, administered, 

liquidated, sold, or otherwise dealt with in the interest of and for the benefit of 

the United States, and such designated agency or person may perform any and all 

acts incident to the accomplishment or furtherance of these purposes. 

(2) In exercising the authorities granted by paragraph (1), the President may require any 

person to keep a full record of, and to furnish under oath, in the form of reports or 

otherwise, complete information relative to any act or transaction referred to in paragraph 

(1) either before, during, or after the completion thereof, or relative to any interest in 

foreign property, or relative to any property in which any foreign country or any national 

thereof has or has had any interest, or as may be otherwise necessary to enforce the 

provisions of such paragraph. In any case in which a report by a person could be required 

under this paragraph, the President may require the production of any books of account, 

records, contracts, letters, memoranda, or other papers, in the custody or control of such 

person. 

(3) Compliance with any regulation, instruction, or direction issued under this chapter 

shall to the extent thereof be a full acquittance and discharge for all purposes of the 

obligation of the person making the same. No person shall be held liable in any court for 

or with respect to anything done or omitted in good faith in connection with the 

administration of, or pursuant to and in reliance on, this chapter, or any regulation, 

instruction, or direction issued under this chapter. 

(b) The authority granted to the President by this section does not include the authority to regulate 

or prohibit, directly or indirectly-- 

(1) any postal, telegraphic, telephonic, or other personal communication, which does not 

involve a transfer of anything of value; 

(2) donations, by persons subject to the jurisdiction of the United States, of articles, such 

as food, clothing, and medicine, intended to be used to relieve human suffering, except to 

the extent that the President determines that such donations (A) would seriously impair 

his ability to deal with any national emergency declared under section 1701 of this title, 

(B) are in response to coercion against the proposed recipient or donor, or (C) would 

endanger Armed Forces of the United States which are engaged in hostilities or are in a 

situation where imminent involvement in hostilities is clearly indicated by the 

circumstances; or 

(3) the importation from any country, or the exportation to any country, whether 

commercial or otherwise, regardless of format or medium of transmission, of any 

information or informational materials, including but not limited to, publications, films, 

posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, 

CD ROMs, artworks, and news wire feeds. The exports exempted from regulation or 

prohibition by this paragraph do not include those which are otherwise controlled for 

export under section 2404 of the Appendix to this title, or under section 2405 of the 

Appendix to this title to the extent that such controls promote the nonproliferation or 

antiterrorism policies of the United States, or with respect to which acts are prohibited by 

chapter 37 of Title 18; 

(4) any transactions ordinarily incident to travel to or from any country, including 

importation of accompanied baggage for personal use, maintenance within any country 

IMPACT REPORT 

APPENDIX A AUTHORITIES

103 
APPENDIX A  AUTHORITIES 

including payment of living expenses and acquisition of goods or services for personal 

use, and arrangement or facilitation of such travel including nonscheduled air, sea, or 

land voyages. 

(c) Classified information.--In any judicial review of a determination made under this section, if 

the determination was based on classified information (as defined in section 1(a) of the Classified 

Information Procedures Act) such information may be submitted to the reviewing court ex parte 

and in camera. This subsection does not confer or imply any right to judicial review. 

§ 1703. Consultation and reports 

(a) Consultation with Congress 

The President, in every possible instance, shall consult with the Congress before exercising any of 

the authorities granted by this chapter and shall consult regularly with the Congress so long as 

such authorities are exercised. 

(b) Report to Congress upon exercise of Presidential authorities 

Whenever the President exercises any of the authorities granted by this chapter, he shall 

immediately transmit to the Congress a report specifying-- 

(1) the circumstances which necessitate such exercise of authority; 

(2) why the President believes those circumstances constitute an unusual and 

extraordinary threat, which has its source in whole or substantial part outside the United 

States, to the national security, foreign policy, or economy of the United States; 

(3) the authorities to be exercised and the actions to be taken in the exercise of those 

authorities to deal with those circumstances; 

(4) why the President believes such actions are necessary to deal with those 

circumstances; and 

(5) any foreign countries with respect to which such actions are to be taken and why such 

actions are to be taken with respect to those countries. 

(c) Periodic follow-up reports 

At least once during each succeeding six-month period after transmitting a report pursuant to 

subsection (b) of this section with respect to an exercise of authorities under this chapter, the 

President shall report to the Congress with respect to the actions taken, since the last such report, 

in the exercise of such authorities, and with respect to any changes which have occurred 

concerning any information previously furnished pursuant to paragraphs (1) through (5) of 

subsection (b) of this section. 

(d) Supplemental requirements 

The requirements of this section are supplemental to those contained in title IV of the National 

Emergencies Act [50 U.S.C.A. § 1641]. 

§ 1704. Authority to issue regulations 

The President may issue such regulations, including regulations prescribing definitions, as may be 

necessary for the exercise of the authorities granted by this chapter. 

104 IMPACT REPORT 
APPENDIX A  AUTHORITIES

§ 1705. Penalties 

(a) A civil penalty of not to exceed $50,000 may be imposed on any person who violates, or 

attempts to violate, any license, order, or regulation issued under this chapter. 

(b) Whoever willfully violates, or willfully attempts to violate, any license, order, or regulation 

issued under this chapter shall, upon conviction, be fined not more than $50,000, or, if a natural 

person, may be imprisoned for not more than twenty years, or both; and any officer, director, or 

agent of any corporation who knowingly participates in such violation may be punished by a like 

fine, imprisonment, or both. 

§ 1706. Savings provisions 

(a) Termination of national emergencies pursuant to National Emergencies Act 

(1) Except as provided in subsection (b) of this section, notwithstanding the termination 

pursuant to the National Emergencies Act [50 U.S.C.A. § 1601 et seq.] of a national 

emergency declared for purposes of this chapter, any authorities granted by this chapter, 

which are exercised on the date of such termination on the basis of such national 

emergency to prohibit transactions involving property in which a foreign country or 

national thereof has any interest, may continue to be so exercised to prohibit transactions 

involving that property if the President determines that the continuation of such 

prohibition with respect to that property is necessary on account of claims involving such 

country or its nationals. 

(2) Notwithstanding the termination of the authorities described in section 101(b) of this 

Act, any such authorities, which are exercised with respect to a country on the date of 

such termination to prohibit transactions involving any property in which such country or 

any national thereof has any interest, may continue to be exercised to prohibit 

transactions involving that property if the President determines that the continuation of 

such prohibition with respect to that property is necessary on account of claims involving 

such country or its nationals. 

(b) Congressional termination of national emergencies by concurrent resolution 

The authorities described in subsection (a)(1) of this section may not continue to be 

exercised under this section if the national emergency is terminated by the Congress by 

concurrent resolution pursuant to section 202 of the National Emergencies Act [50 

U.S.C.A § 1622] and if the Congress specifies in such concurrent resolution that such 

authorities may not continue to be exercised under this section. 

(c) Supplemental savings provisions; supersedure of inconsistent provisions 

(1) The provisions of this section are supplemental to the savings provisions of 

paragraphs (1), (2), and (3) of section 101(a) [50 U.S.C.A. § 1601(a)(1), (2), (3)] and of 

paragraphs (A), (B), and (C) of section 202(a) [50 U.S.C.A. § 1622(a)(A), (B), and (C)] 

of the National Emergencies Act. 

(2) The provisions of this section supersede the termination provisions of section 101(a) 

[50 U.S.C.A. § 1601(a)] and of title II [50 U.S.C.A. § 1621 et seq.] of the National 

IMPACT REPORT 

APPENDIX A AUTHORITIES

105 
APPENDIX A  AUTHORITIES 

Emergencies Act to the extent that the provisions of this section are inconsistent with 

these provisions. 

(d) Periodic reports to Congress 

If the President uses the authority of this section to continue prohibitions on transactions 

involving foreign property interests, he shall report to the Congress every six months on 

the use of such authority. 

106 IMPACT REPORT 
APPENDIX A 

 AUTHORITIES

federal register
Tuesday 

October 24, 1995 

Part III 

The President 

Executive Order 12978—Blocking Assets 

and Prohibiting Transactions With 

Significant Narcotics Traffickers 

IMPACT REPORT 

APPENDIX A AUTHORITIES

107 
APPENDIX A  AUTHORITIES 

54579 

Federal Register Presidential Documents 

Vol. 60, No. 205 

Tuesday, October 24, 1995 

Title 3—


The President


Executive Order 12978 of October 21, 1995 

Blocking Assets and Prohibiting Transactions With Significant Narcotics Traffickers 

By the authority vested in me as President by the Constitution and the 

laws of the United States of America, including the International Emergency 

Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), and section 301 of title 3, United 

States Code, 

I, WILLIAM J. CLINTON, President of the United States of America, find 

that the actions of significant foreign narcotics traffickers centered in Colombia, and the unparalleled violence, corruption, and harm that they cause 

in the United States and abroad, constitute an unusual and extraordinary 

threat to the national security, foreign policy, and economy of the United 

States, and hereby declare a national emergency to deal with that threat. 

Section 1. Except to the extent provided in section 203(b) of IEEPA (50 

U.S.C. 1702(b)) and in regulations, orders, directives, or licenses that may

be issued pursuant to this order, and notwithstanding any contract entered 

into or any license or permit granted prior to the effective date, I hereby 

order blocked all property and interests in property that are or hereafter 

come within the United States, or that are or hereafter come within the 

possession or control of United States persons, of: 

(a) the foreign persons listed in the Annex to this order;

(b) foreign persons determined by the Secretary of the Treasury, in consultation with the Attorney General and the Secretary of State: 

(i) to play a significant role in international narcotics trafficking centered

in Colombia; or 

(ii) materially to assist in, or provide financial or technological support

for or goods or services in support of, the narcotics trafficking activities 

of persons designated in or pursuant to this order; and 

(c) persons determined by the Secretary of the Treasury, in consultation

with the Attorney General and the Secretary of State, to be owned or controlled by, or to act for or on behalf of, persons designated in or pursuant 

to this order. 

Sec. 2. Further, except to the extent provided in section 203(b) of IEEPA 

and in regulations, orders, directives, or licenses that may be issued pursuant 

to this order, and notwithstanding any contract entered into or any license 

or permit granted prior to the effective date, I hereby prohibit the following: 

(a) any transaction or dealing by United States persons or within the United

States in property or interests in property of the persons designated in 

or pursuant to this order; 

(b) any transaction by any United States person or within the United States

that evades or avoids, or has the purpose of evading or avoiding, or attempts 

to violate, any of the prohibitions set forth in this order. 

Sec. 3. For the purposes of this order: 

(a) the term ‘‘person’’ means an individual or entity;

(b) the term ‘‘entity’’ means a partnership, association, corporation, or other

organization, group or subgroup; 

108 IMPACT REPORT 
APPENDIX A  AUTHORITIES

54580 Federal Register / Vol. 60, No. 205 / Tuesday, October 24, 1995 / Presidential Documents 

Billing code 3195–01–P


[FR Doc. 95–26569


Filed 10–23–95; 11:21 am]


Billing code 4810–31–P


(c) the term ‘‘United States person’’ means any United States citizen or

national, permanent resident alien, entity organized under the laws of the 

United States (including foreign branches), or any person in the United 

States: 

(d) the term ‘‘foreign person’’ means any citizen or national of a foreign

state (including any such individual who is also a citizen or national of 

the United States) or any entity not organized solely under the laws of 

the United States or existing solely in the United States, but does not 

include a foreign state; and 

(e) the term ‘‘narcotics trafficking’’ means any activity undertaken illicitly

to cultivate, produce, manufacture, distribute, sell, finance or transport, or 

otherwise assist, abet, conspire, or collude with others in illicit activities 

relating to, narcotic drugs, including, but not limited to, cocaine. 

Sec. 4. The Secretary of the Treasury, in consultation with the Attorney 

General and the Secretary of State, is hereby authorized to take such actions, 

including the promulgation of rules and regulations, and to employ all 

powers granted to the President by IEEPA as may be necessary to carry 

out this order. The Secretary of the Treasury may redelegate any of these 

functions to other officers and agencies of the United States Government. 

All agencies of the United States Government are hereby directed to take 

all appropriate measures within their authority to carry out this order. 

Sec. 5. Nothing contained in this order shall create any right or benefit, 

substantive or procedural, enforceable by any party against the United States, 

its agencies or instrumentalities, its officers or employees, or any other 

person. 

Sec. 6. (a) This order is effective at 12:01 a.m. Eastern Daylight Time on 

October 22, 1995. 

(b) This order shall be transmitted to the Congress and published in the

Federal Register. 

THE WHITE HOUSE, 

October 21, 1995. 

œ–

ANNEX 

Gilberto Rodriguez Orejuela 

Miguel Angel Rodriguez Orejuela 

Jose ́ Santacruz London ̃ o 

Helmer Herrera Buitrago 

IMPACT REPORT 

APPENDIX A AUTHORITIES

109 
APPENDIX A  AUTHORITIES 

“Code of Federal Regulations- Title 31, Part 536” 

Office of Foreign Assets Control, Treasury 

name of a non-Iranian bank located in 

a foreign country, provided such nonIranian foreign bank is not a person 

subject to the jurisdiction of the 

United States. 

§ 535.902 Set-offs by U.S. owned or con- trolled firms abroad. 

(a) Branches and subsidiaries in foreign countries of persons subject to the 

jurisdiction of the United States are licensed to set-off their claims against 

Iran or Iranian entities by debit to 

blocked accounts held by them for Iran 

or Iranian entities. 

(b) The general license in paragraph 

(a) of this section is revoked as of January 19, 1981. 

(c) For purposes of this section, setoffs include combinations of accounts 

and any similar actions. 

(Secs. 201–207, 91 Stat. 1626, 50 U.S.C. 1701– 

1706; E.O. 12170, 44 FR 65729; E.O. 12205, 45 FR 

24099; E.O. 12211, 45 FR 26685; E.O. 12276, 46 FR 

7913; E.O. 12279, 46 FR 7919; E.O. 12280, 46 FR 

7921; E.O. 12281, 46 FR 7923; E.O. 12282, 46 FR 

7925; E.O. 12283, 46 FR 7927, and E.O. 12294, 46 

FR 14111) 

[46 FR 14337, Feb. 26, 1981] 

§ 535.904 Payment by Iranian entities 

of obligations to persons within the 

United States. 

The transfer of funds after the effective date by, through or to any U.S. 

banking institution or other person 

within the United States solely for purposes of payment of obligations by Iranian entities owed to persons within 

the United States is authorized: Provided, That there is no debit to a 

blocked account. Property is not 

blocked by virtue of being transferred 

or received pursuant to this section. 

[44 FR 66591, Nov. 20, 1979] 

§ 535.905 Paperwork Reduction Act notice. 

For approval by the Office of Management and Budget (‘‘OMB’’) under 

the Paperwork Reduction Act of information collections relating to recordkeeping and reporting requirements, to 

licensing procedures (including those 

pursuant to statements of licensing 

policy), and to other procedures, see 

§ 501.901 of this chapter. An agency may 

not conduct or sponsor, and a person is 

not required to respond to, a collection 

Pt. 536 

of information unless it displays a 

valid control number assigned by OMB. 

[62 FR 45107, Aug. 25, 1997] 

PART 536—NARCOTICS TRAFFICKING SANCTIONS REGULATIONS 

Subpart A—Relation of This Part to Other 

Laws and Regulations 

Sec. 

536.100 Licensing procedures. 

536.101 Relation of this part to other laws 

and regulations. 

Subpart B—Prohibitions 

536.201 Prohibited transactions involving 

blocked property. 

536.202 Effect of transfers violating the provisions of this part. 

536.203 Holding of certain types of blocked 

property in interest-bearing accounts. 

536.204 Evasions; attempts; conspiracies. 

536.205 Exempt transactions. 

Subpart C—General Definitions 

536.301 Blocked account; blocked property. 

536.302 Effective date. 

536.303 Entity. 

536.304 Foreign person. 

536.305 General license. 

536.306 Information and informational materials. 

536.307 Interest. 

536.308 License. 

536.309 Person. 

536.310 Property; property interest. 

536.311 Narcotics trafficking. 

536.312 Specially designated narcotics trafficker. 

536.313 Specific license. 

536.314 Transfer. 

536.315 United States. 

536.316 United States person; U.S. person. 

536.317 U.S. financial institution. 

Subpart D—Interpretations 

536.401 Reference to amended sections. 

536.402 Effect of amendment. 

536.403 Termination and acquisition of an 

interest in blocked property. 

536.404 Setoffs prohibited. 

536.405 Transactions incidental to a licensed 

transaction. 

536.406 Provision of services. 

536.407 Offshore transactions. 

536.408 Alleged change in ownership or control of an entity designated as a specially 

designated narcotics trafficker. 

536.409 Credit extended and cards issued by 

U.S. financial institutions. 

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§ 536.100 

Subpart E—Licenses, Authorizations, and 

Statements of Licensing Policy 

536.501 Effect of license or authorization. 

536.502 Exclusion from licenses and authorizations. 

536.503 Payments and transfers to blocked 

accounts in U.S. financial institutions. 

536.504 Investment and reinvestment of certain funds. 

536.505 Entries in certain accounts for normal service charges authorized. 

536.506 Provision of certain legal services 

authorized. 

536.507 Authorization of emergency medical 

services. 

Subpart F—Reports 

536.601 Records and reports. 

Subpart G—Penalties 

536.701 Penalties. 

536.702 Prepenalty notice. 

536.703 Response to prepenalty notice. 

536.704 Penalty notice. 

536.705 Administrative collection; referral 

to United States Department of Justice. 

Subpart H—Procedures 

536.801 Procedures. 

536.802 Delegation by the Secretary of the 

Treasury. 

Subpart I—Paperwork Reduction Act 

536.901 Paperwork Reduction Act notice. 

AUTHORITY: 3 U.S.C. 301; 31 U.S.C. 321(b); 50 

U.S.C. 1601–1641, 1701–1706; Pub. L. 101–410, 104 

Stat. 890 (28 U.S.C. 2461 note); E.O. 12978, 60 

FR 54579; 3 CFR, 1995 Comp., p. 415; E.O. 

13224, 66 FR 49079; 3 CFR, 2001 Comp., p. 786; 

E.O. 13286, 68 FR 10619, March 5, 2003; Pub. L. 

109–177, 120 Stat. 192. 

SOURCE: 62 FR 9960, Mar. 5, 1997, unless otherwise noted. 

Subpart A—Relation of This Part to

Other Laws and Regulations 

§ 536.100 Licensing procedures. 

For provisions relating to licensing 

procedures, see part 501, subpart E, of 

this chapter. Licensing actions taken 

pursuant to part 501 of this chapter 

with respect to the prohibitions contained in this part are considered actions taken pursuant to this part. 

[68 FR 53657, Sept. 11, 2003] 

31 CFR Ch. V (7–1–06 Edition) 

§ 536.101 Relation of this part to other

laws and regulations. 

(a) This part is separate from, and 

independent of, the other parts of this 

chapter with the exception of part 501 

of this chapter, the recordkeeping and 

reporting requirements and license application and other procedures of which 

apply to this part. Differing foreign 

policy and national security contexts 

may result in differing interpretations 

of similar language among the parts of 

this chapter. No license or authorization contained in or issued pursuant to 

those other parts authorizes any transaction prohibited by this part. No license or authorization contained in or 

issued pursuant to any other provision 

of law or regulation authorizes any 

transaction prohibited by this part. 

(b) No license or authorization contained in or issued pursuant to this 

part relieves the involved parties from 

complying with any other applicable 

laws or regulations. 

[62 FR 9960, Mar. 5, 1997, as amended at 62 FR 

45107, Aug. 25, 1997] 

Subpart B—Prohibitions 

§ 536.201 Prohibited transactions involving blocked property. 

(a) Except as authorized by regulations, orders, directives, rulings, instructions, licenses, or otherwise, and 

notwithstanding any contract entered 

into or any license or permit granted 

prior to the effective date, no property 

or interests in property of a specially 

designated narcotics trafficker that are 

in the United States, that hereafter 

come within the United States, or that 

are or hereafter come within the possession or control of U.S. persons, including their overseas branches, may 

be transferred, paid, exported, withdrawn or otherwise dealt in. 

(b) When a transaction results in the 

blocking of funds at a financial institution pursuant to this section and a 

party to the transaction believes the 

funds have been blocked due to mistaken identity, that party may seek to 

have such funds unblocked pursuant to 

the administrative procedures set forth 

in § 501.806 of this chapter. 

[62 FR 9960, Mar. 5, 1997, as amended at 62 FR 

45107, Aug. 25, 1997] 

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Office of Foreign Assets Control, Treasury 

§ 536.202 Effect of transfers violating

the provisions of this part. 

(a) Any transfer after the effective 

date, which is in violation of any provision of this part or of any regulation, 

order, directive, ruling, instruction, license, or other authorization hereunder and involves any property held 

in the name of a specially designated 

narcotics trafficker or in which a specially designated narcotics trafficker 

has or has had an interest since such 

date, is null and void and shall not be 

the basis for the assertion or recognition of any interest in or right, remedy, power or privilege with respect to 

such property. 

(b) No transfer before the effective 

date shall be the basis for the assertion 

or recognition of any right, remedy, 

power, or privilege with respect to, or 

interest in, any property held in the 

name of a specially designated narcotics trafficker or in which a specially 

designated narcotics trafficker has an 

interest, or has had an interest since 

such date, unless the person with 

whom such property is held or maintained, prior to such date, had written 

notice of the transfer or by any written 

evidence had recognized such transfer. 

(c) Unless otherwise provided, an appropriate license or other authorization issued by or pursuant to the direction or authorization of the Director of 

the Office of Foreign Assets Control before, during, or after a transfer shall 

validate such transfer or render it enforceable to the same extent that it 

would be valid or enforceable but for 

the provisions of the International 

Emergency Economic Powers Act, this 

part, and any regulation, order, directive, ruling, instruction, or license 

issued hereunder. 

(d) Transfers of property which otherwise would be null and void or unenforceable by virtue of the provisions of 

this section shall not be deemed to be 

null and void or unenforceable as to 

any person with whom such property 

was held or maintained (and as to such 

person only) in cases in which such person is able to establish to the satisfaction of the Director of the Office of 

Foreign Assets Control each of the following: 

(1) Such transfer did not represent a 

willful violation of the provisions of 

§ 536.203 

this part by the person with whom such 

property was held or maintained; 

(2) The person with whom such property was held or maintained did not 

have reasonable cause to know or suspect, in view of all the facts and circumstances known or available to such 

person, that such transfer required a license or authorization by or pursuant 

to this part and was not so licensed or 

authorized, or if a license or authorization did purport to cover the transfer, 

that such license or authorization had 

been obtained by misrepresentation of 

a third party or the withholding of material facts or was otherwise fraudulently obtained; and 

(3) The person with whom such property was held or maintained filed with 

the Office of Foreign Assets Control a 

report setting forth in full the circumstances relating to such transfer 

promptly upon discovery that: 

(i) Such transfer was in violation of 

the provisions of this part or any regulation, ruling, instruction, license, or 

other direction or authorization hereunder; or 

(ii) Such transfer was not licensed or 

authorized by the Director of the Office 

of Foreign Assets Control; or 

(iii) If a license did purport to cover 

the transfer, such license had been obtained by misrepresentation of a third 

party or the withholding of material 

facts or was otherwise fraudulently obtained. 

NOTE TO PARAGRAPH (d)(3): The filing of a 

report in accordance with the provisions of 

this paragraph (d)(3) shall not be deemed evidence that the terms of paragraphs (d)(l) and 

(2) of this section have been satisfied. 

(e) Unless licensed or authorized pursuant to this part, any attachment, 

judgment, decree, lien, execution, garnishment, or other judicial process is 

null and void with respect to any property which, on or since the effective 

date, was held in the name of a specially designated narcotics trafficker 

or in which there existed an interest of 

a specially designated narcotics trafficker. 

§ 536.203 Holding of certain types of 

blocked property in interest-bearing accounts. 

(a)(1) Any person, including a U.S. financial institution, currently holding 

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§ 536.204 

property subject to § 536.201 which, as of 

the effective date or the date of receipt 

if subsequent to the effective date, is 

not being held in an interest-bearing 

account, or otherwise invested in a 

manner authorized by the Office of 

Foreign Assets Control (e.g., § 536.504), 

shall transfer such property to, or hold 

such property or cause such property 

to be held in, an interest-bearing account or interest-bearing status in a 

U.S. financial institution as of the effective date or the date of receipt if 

subsequent to the effective date of this 

section, unless otherwise authorized or 

directed by the Office of Foreign Assets 

Control. 

(2) The requirement set forth in paragraph (a)(1) of this section shall apply 

to currency, bank deposits, accounts, 

obligations, and any other financial or 

economic resources or assets, and any 

proceeds resulting from the sale of tangible or intangible property. If interest 

is credited to an account separate from 

that in which the interest-bearing 

asset is held, the name of the account 

party on both accounts must be the 

same and must clearly indicate the 

specially designated narcotics trafficker having an interest in the accounts. If the account is held in the 

name of a specially designated narcotics trafficker, the name of the account to which interest is credited 

must be the same. 

(b) For purposes of this section, the 

term interest-bearing account means a 

blocked account in a U.S. financial institution earning interest at rates that 

are commercially reasonable for the 

amount of funds in the account. Except 

as otherwise authorized, the funds may 

not be invested or held in instruments 

the maturity of which exceeds 90 days. 

(c) This section does not apply to 

blocked tangible property, such as 

chattels, nor does it create an affirmative obligation on the part of the holder of such blocked tangible property to 

sell or liquidate the property and put 

the proceeds in a blocked account. 

However, the Office of Foreign Assets 

Control may issue licenses permitting 

or directing sales of tangible property 

in appropriate cases. 

31 CFR Ch. V (7–1–06 Edition) 

§ 536.204 Evasions; attempts; conspiracies. 

Any transaction for the purpose of, 

or which has the effect of, evading or 

avoiding, or which facilitates the evasion or avoidance of, any of the prohibitions set forth in this part, is hereby 

prohibited. Any attempt to violate the 

prohibitions set forth in this part is 

hereby prohibited. Any conspiracy 

formed for the purpose of engaging in a 

transaction prohibited by this part is 

hereby prohibited. 

§ 536.205 Exempt transactions. 

(a) Personal communications. The prohibitions contained in this part do not 

apply to any postal, telegraphic, telephonic, or other personal communication, which does not involve the transfer of anything of value. 

(b) Information and informational materials. (1) The importation from any 

country and the exportation to any 

country of information or informational materials as defined in § 536.306, 

whether commercial or otherwise, regardless of format or medium of transmission, are exempt from the prohibitions and regulations of this part. 

(2) This section does not authorize 

transactions related to information 

and informational materials not fully 

created and in existence at the date of 

the transactions, or to the substantive 

or artistic alteration or enhancement 

of informational materials, or to the 

provision of marketing and business 

consulting services by a U.S. person. 

Such prohibited transactions include, 

without limitation, payment of advances for informational materials not 

yet created and completed, provision of 

services to market, produce or coproduce, create or assist in the creation of information and informational 

materials, and payment of royalties to 

a specially designated narcotics trafficker with respect to income received 

for enhancements or alterations made 

by U.S. persons to information or informational materials imported from a 

specially designated narcotics trafficker. 

(3) This section does not authorize 

transactions incident to the exportation of technology that is not informational material as defined in 

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Office of Foreign Assets Control, Treasury 

§ 536.306(b)(1) or incident to the exportation of goods for use in the transmission of any information. 

(c) Travel. The prohibitions contained 

in this part do not apply to transactions ordinarily incident to travel to 

or from any country, including importation of accompanied baggage for personal use, maintenance within any 

country including payment of living 

expenses and acquisition of goods or 

services for personal use, and arrangement or facilitation of such travel including non-scheduled air, sea, or land 

voyages. Any transactions entered into 

by a specially designated narcotics 

trafficker while traveling in the United 

States that are outside the scope of 

those set forth in this paragraph are in 

violation of § 536.201. 

Subpart C—General Definitions 

§ 536.301 Blocked account; blocked 

property. 

The terms blocked account and blocked 

property shall mean any account or 

property subject to the prohibition in 

§ 536.201 held in the name of a specially 

designated narcotics trafficker or in 

which a specially designated narcotics 

trafficker has an interest, and with respect to which payments, transfers, exportations, withdrawals, or other dealings may not be made or effected except pursuant to an authorization or license from the Office of Foreign Assets 

Control authorizing such action. 

§ 536.302 Effective date. 

The term effective date refers to the 

effective date of the applicable prohibitions and directives contained in this 

part which is 12:01 a.m. EDT, October 

22, 1995, or, in the case of specially designated narcotics traffickers designated after that date, the earlier of 

the date on which a person receives actual or constructive notice of such designation. 

§ 536.303 Entity. 

The term entity means a partnership, 

association, corporation, or other organization, group or subgroup. 

§ 536.304 Foreign person. 

The term foreign person means any 

citizen or national of a foreign state 

§ 536.308 

(including any such individual who is 

also a citizen or national of the United 

States), or any entity not organized 

solely under the laws of the United 

States or existing solely in the United 

States, but does not include a foreign 

state. 

§ 536.305 General license. 

The term general license means any license or authorization the terms of 

which are set forth in this part. 

§ 536.306 Information and informational materials. 

(a) For purposes of this part, the 

term information and informational materials means: 

(1) Publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact 

disks, CD ROMs, artworks, and news 

wire feeds, and other information and 

informational articles. 

(2) To be considered informational 

materials, artworks must be classified 

under chapter subheading 9701, 9702, or 

9703 of the Harmonized Tariff Schedule 

of the United States. 

(b) The terms information and informational materials with respect to U.S. 

exports do not include items: 

(1) That were, as of April 30, 1994, or 

that thereafter become, controlled for 

export pursuant to section 5 of the Export Administration Act of 1979, 50 

U.S.C. App. 2401–2420 (the ‘‘EAA’’), or 

section 6 of the EAA to the extent that 

such controls promote nonproliferation 

or antiterrorism policies of the United 

States, including software as defined in 

15 CFR part 772 that is not publicly 

available (see 15 CFR parts 734 and 772); 

or 

(2) With respect to which acts are 

prohibited by 18 U.S.C. chapter 37. 

§ 536.307 Interest. 

Except as otherwise provided in this 

part, the term interest when used with 

respect to property (e.g., ‘‘an interest 

in property’’) means an interest of any 

nature whatsoever, direct or indirect. 

§ 536.308 License. 

Except as otherwise specified, the 

term license means any license or authorization contained in or issued pursuant to this part. 

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§ 536.309 

§ 536.309 Person. 

The term person means an individual 

or entity. 

§ 536.310 Property; property interest. 

The terms property and property interest include, but are not limited to, 

money, checks, drafts, bullion, bank 

deposits, savings accounts, debts, indebtedness, obligations, notes, guarantees, debentures, stocks, bonds, coupons, any other financial instruments, 

bankers acceptances, mortgages, 

pledges, liens or other rights in the nature of security, warehouse receipts, 

bills of lading, trust receipts, bills of 

sale, any other evidences of title, ownership or indebtedness, letters of credit 

and any documents relating to any 

rights or obligations thereunder, powers of attorney, goods, wares, merchandise, chattels, stocks on hand, ships, 

goods on ships, real estate mortgages, 

deeds of trust, vendors sales agreements, land contracts, leaseholds, 

ground rents, real estate and any other 

interest therein, options, negotiable instruments, trade acceptances, royalties, book accounts, accounts payable, 

judgments, patents, trademarks or 

copyrights, insurance policies, safe deposit boxes and their contents, annuities, pooling agreements, services of 

any nature whatsoever, contracts of 

any nature whatsoever, and any other 

property, real, personal, or mixed, tangible or intangible, or interest or interests therein, present, future or contingent. 

§ 536.311 Narcotics trafficking. 

The term narcotics trafficking means 

any activity undertaken illicitly to 

cultivate, produce, manufacture, distribute, sell, finance or transport, or 

otherwise assist, abet, conspire, or 

collude with others in illicit activities 

relating to narcotic drugs, including, 

but not limited to, cocaine. 

§ 536.312 Specially designated nar- cotics trafficker. 

The term specially designated narcotics 

trafficker means: 

(a) Persons listed in the annex to Executive Order 12978 (3 CFR, 1995 Comp., 

p.415); 

(b) Foreign persons designated by the 

Secretary of Treasury, in consultation 

31 CFR Ch. V (7–1–06 Edition) 

with the Attorney General and the Secretary of State, because they are 

found: 

(1) To play a significant role in international narcotics trafficking centered 

in Colombia; or 

(2) Materially to assist in, or provide 

financial or technological support for 

or goods or services in support of, the 

narcotics trafficking activities of specially designated narcotics traffickers; 

and 

(c) Persons determined by the Secretary of the Treasury, in consultation 

with the Attorney General and the Secretary of State, to be owned or controlled by, or to act for or on behalf of, 

any other specially designated narcotics trafficker. 

NOTE TO § 536.312: Please refer to the appendices at the end of this chapter for listings of 

persons determined to fall within this definition who have been designated pursuant to 

this part. Section 501.807 of this chapter 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 the designation are no longer applicable. 

[62 FR 9960, Mar. 5, 1997, as amended at 62 FR 

45107, Aug. 25, 1997] 

§ 536.313 Specific license. 

The term specific license means any license or authorization not set forth in 

this part but issued pursuant to this 

part. 

§ 536.314 Transfer. 

The term transfer means any actual 

or purported act or transaction, whether or not evidenced by writing, and 

whether or not done or performed within the United States, the purpose, intent, or effect of which is to create, 

surrender, release, convey, transfer, or 

alter, directly or indirectly, any right, 

remedy, power, privilege, or interest 

with respect to any property and, without limitation upon the foregoing, 

shall include the making, execution, or 

delivery of any assignment, power, conveyance, check, declaration, deed, deed 

of trust, power of attorney, power of 

appointment, bill of sale, mortgage, receipt, agreement, contract, certificate, 

gift, sale, affidavit, or statement; the 

making of any payment; the setting off 

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Office of Foreign Assets Control, Treasury 

of any obligation or credit; the appointment of any agent, trustee, or fiduciary; the creation or transfer of any 

lien; the issuance, docketing, filing, or 

levy of or under any judgment, decree, 

attachment, injunction, execution, or 

other judicial or administrative process or order, or the service of any garnishment; the acquisition of any interest of any nature whatsoever by reason 

of a judgment or decree of any foreign 

country; the fulfillment of any condition; the exercise of any power of appointment, power of attorney, or other 

power; or the acquisition, disposition, 

transportation, importation, exportation, or withdrawal of any security. 

§ 536.315 United States. 

The term United States means the 

United States, its territories and possessions, and all areas under the jurisdiction or authority thereof. 

§ 536.316 United States person; U.S. 

person. 

The term United States person or U.S. 

person means any United States citizen 

or national; permanent resident alien; 

entity organized under the laws of the 

United States or any jurisdiction within the United States (including foreign 

branches); or any person in the United 

States. 

§ 536.317 U.S. financial institution. 

The term U.S. financial institution 

means any U.S. person (including foreign branches) that is engaged in the 

business of accepting deposits, making, 

granting, transferring, holding, or 

brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, 

or procuring purchasers and sellers 

thereof, as principal or agent; including, but not limited to, depository institutions, banks, savings banks, trust 

companies, securities brokers and dealers, commodity futures and options 

brokers and dealers, forward contract 

and foreign exchange merchants, securities and commodities exchanges, 

clearing corporations, investment companies, employee benefit plans, and 

U.S. holding companies, U.S. affiliates, 

or U.S. subsidiaries of any of the foregoing. This term includes those 

branches, offices and agencies of for-

§ 536.403 

eign financial institutions which are 

located in the United States, but not 

such institutions’ foreign branches, offices, or agencies. 

Subpart D—Interpretations 

§ 536.401 Reference to amended sec- tions. 

Except as otherwise specified, reference to any section of this part or to 

any regulation, ruling, order, instruction, direction, or license issued pursuant to this part shall be deemed to 

refer to the same as currently amended. 

§ 536.402 Effect of amendment. 

Any amendment, modification, or 

revocation of any section of this part 

or of any order, regulation, ruling, instruction, or license issued by or under 

the direction of the Director of the Office of Foreign Assets Control shall 

not, unless otherwise specifically provided, be deemed to affect any act done 

or omitted to be done, or any civil or 

criminal suit or proceeding commenced 

or pending prior to such amendment, 

modification, or revocation. All penalties, forfeitures, and liabilities under 

any such order, regulation, ruling, instruction, or license shall continue and 

may be enforced as if such amendment, 

modification, or revocation had not 

been made. 

§ 536.403 Termination and acquisition

of an interest in blocked property. 

(a) Whenever a transaction licensed 

or authorized by or pursuant to this 

part results in the transfer of property 

(including any property interest) away 

from a specially designated narcotics 

trafficker, such property shall no 

longer be deemed to be property in 

which a specially designated narcotics 

trafficker has or has had an interest, or 

which is held in the name of a specially 

designated narcotics trafficker, unless 

there exists in the property another interest of a specially designated narcotics trafficker, the transfer of which 

has not been effected pursuant to license or other authorization. 

(b) Unless otherwise specifically provided in a license or authorization 

issued pursuant to this part, if property (including any property interest) 

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§ 536.404 

is transferred or attempted to be transferred to a specially designated narcotics trafficker, such property shall be 

deemed to be property in which there 

exists an interest of the specially designated narcotics trafficker. 

§ 536.404 Setoffs prohibited. 

A setoff against blocked property (including a blocked account), whether by 

a U.S. bank or other U.S. person, is a 

prohibited transfer under § 536.201 if effected after the effective date. 

§ 536.405 Transactions incidental to a 

licensed transaction. 

Any transaction ordinarily incident 

to a licensed transaction and necessary 

to give effect thereto is also authorized, except a transaction by an unlicensed, specially designated narcotics 

trafficker or involving a debit to a 

blocked account or a transfer of 

blocked property not explicitly authorized within the terms of the license. 

§ 536.406 Provision of services. 

(a) Except as provided in §536.205, the 

prohibitions contained in § 536.201 apply 

to services performed by U.S. persons, 

wherever located: 

(1) On behalf of, or for the benefit of, 

a specially designated narcotics trafficker; or 

(2) With respect to property interests 

of a specially designated narcotics trafficker. 

(b) Example: U.S. persons may not, 

except as authorized by the Office of 

Foreign Assets Control by or pursuant 

to this part, provide legal, accounting, 

financial, brokering, freight forwarding, transportation, public relations, educational, or other services to 

a specially designated narcotics trafficker. See § 536.506, with respect to certain authorized legal services. 

§ 536.407 Offshore transactions. 

The prohibitions contained in 

§ 536.201 apply to transactions by U.S. 

persons in locations outside the United 

States with respect to property which 

the U.S. person knows, or has reason to 

know, is held in the name of a specially 

designated narcotics trafficker, or in 

which the U.S. person knows, or has 

reason to know, a specially designated 

31 CFR Ch. V (7–1–06 Edition) 

narcotics trafficker has or has had an 

interest since the effective date. 

§ 536.408 Alleged change in ownership

or control of an entity designated 

as a specially designated narcotics 

trafficker. 

(a) A change or alleged change in 

ownership or control of an entity designated as a specially designated narcotics trafficker shall not be the basis 

for removal of that entity from the list 

of specially designated narcotics traffickers unless, upon investigation by 

the Office of Foreign Assets Control 

and submission of evidence by the entity, it is demonstrated to the satisfaction of the Director of the Office of 

Foreign Assets Control that the transfer to a bona fide purchaser at arm’s 

length is legitimate and that the entity no longer meets the criteria for designation under § 536.312. Evidence submitted must conclusively demonstrate 

that all ties with other specially designated narcotics traffickers have been 

completely severed, and may include, 

but is not limited to, articles of incorporation; identification of new directors, officers, shareholders, and sources 

of capital; and contracts evidencing the 

sale of the entity to its new owners. 

(b) Any continuing substantial financial obligations on the part of the new 

owners to any specially designated narcotics traffickers, including long-term 

payment plans, leases, or rents, will be 

considered as evidence of continuing 

control of the entity by the specially 

designated narcotics trafficker. Purchase of a designated entity without 

ongoing substantial financial obligations to a specially designated narcotics trafficker may nonetheless be a 

basis for subsequent designation of the 

purchaser, if the transaction is determined materially to assist in or provide financial support for the narcotics 

trafficking activities of specially designated narcotics traffickers for purposes of § 536.312(b)(2). For example, any 

acquisition transaction resulting in a 

direct cash transfer to or other enrichment of a specially designated narcotics trafficker could lead to designation of the purchaser. Mere change in 

name of an entity will not be considered as constituting a change of the entity’s status. 

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APPENDIX A  AUTHORITIES 

Office of Foreign Assets Control, Treasury 

§ 536.409 Credit extended and cards 

issued by U.S. financial institutions. 

The prohibition in § 536.201 on dealing 

in property in which a specially designated narcotics trafficker has an interest prohibits U.S. financial institutions from performing under any existing credit agreements, including, but 

not limited to, charge cards, debit 

cards, or other credit facilities issued 

by a U.S. financial institution to a person designated under this part. 

Subpart E—Licenses, Authorizations, and Statements of Licensing Policy 

§ 536.501 Effect of license or authorization. 

(a) No license or other authorization 

contained in this part, or otherwise 

issued by or under the direction of the 

Director of the Office of Foreign Assets 

Control, shall be deemed to authorize 

or validate any transaction effected 

prior to the issuance of the license, unless specifically provided in such license or authorization. 

(b) No regulation, ruling, instruction, 

or license authorizes any transaction 

prohibited under this part unless the 

regulation, ruling, instruction, or license is issued by the Office of Foreign 

Assets Control and specifically refers 

to this part. No regulation, ruling, instruction, or license referring to this 

part shall be deemed to authorize any 

transaction prohibited by any provision of this chapter unless the regulation, ruling, instruction or license specifically refers to such provision. 

(c) Any regulation, ruling, instruction, or license authorizing any transaction otherwise prohibited under this 

part has the effect of removing a prohibition or prohibitions contained in this 

part from the transaction, but only to 

the extent specifically stated by its 

terms. Unless the regulation, ruling, 

instruction, or license otherwise specifies, such an authorization does not 

create any right, duty, obligation, 

claim, or interest in, or with respect 

to, any property which would not otherwise exist under ordinary principles 

of law. 

§ 536.504 

§ 536.502 Exclusion from licenses and 

authorizations. 

The Director of the Office of Foreign 

Assets Control reserves the right to exclude any person, property, or transaction from the operation of any license, or from the privileges therein 

conferred, or to restrict the applicability thereof with respect to particular persons, property, transactions, 

or classes thereof. Such action shall be 

binding upon all persons receiving actual or constructive notice of such exclusion or restriction. 

§ 536.503 Payments and transfers to 

blocked accounts in U.S. financial 

institutions. 

(a) Any payment of funds or transfer 

of credit or other financial or economic 

resources or assets into a blocked account in a U.S. financial institution is 

authorized, provided that a transfer 

from a blocked account pursuant to 

this authorization may only be made 

to another blocked account held in the 

same name on the books of the same 

U.S. financial institution. 

(b) This section does not authorize 

any transfer from a blocked account 

within the United States to an account 

held outside the United States. 

NOTE TO § 536.503: Please refer to § 501.603 of 

this chapter for mandatory reporting requirements regarding financial transfers. 

[62 FR 9960, Mar. 5, 1997, as amended at 62 FR 

45107, Aug. 25, 1997] 

§ 536.504 Investment and reinvestment 

of certain funds. 

(a) U.S. financial institutions are 

hereby authorized and directed to invest and reinvest assets held in blocked 

accounts in the name of a specially 

designated narcotics trafficker, subject 

to the following conditions: 

(1) The assets representing such investments and reinvestments are credited to a blocked account or sub-account which is in the name of the specially designated narcotics trafficker 

and which is located in the United 

States or within the possession or control of a U.S. person; and 

(2) The proceeds of such investments 

and reinvestments are not credited to a 

blocked account or sub-account under 

any name or designation which differs 

from the name or designation of the 

173 

118 IMPACT REPORT 
APPENDIX A  AUTHORITIES

§ 536.505 

specific blocked account or sub-account in which such funds or securities 

were held; and 

(3) No immediate financial or economic benefit or access accrues (e.g., 

through pledging or other use) to the 

specially designated narcotics trafficker. 

(b)(1) U.S. persons seeking to avail 

themselves of this authorization must 

register with the Office of Foreign Assets Control, Blocked Assets Division, 

before undertaking transactions authorized under this section. 

(2) Transactions conducted pursuant 

to this section must be reported to the 

Office of Foreign Assets Control, 

Blocked Assets Division, in a report 

filed no later than 10 business days following the last business day of the 

month in which the transactions occurred. 

§ 536.505 Entries in certain accounts 

for normal service charges authorized. 

(a) U.S. financial institutions are 

hereby authorized to debit any blocked 

account with such U.S. financial institution in payment or reimbursement 

for normal service charges owed to 

such U.S. financial institution by the 

owner of such blocked account. 

(b) As used in this section, the term 

normal service charge shall include 

charges in payment or reimbursement 

for interest due; cable, telegraph, or 

telephone charges; postage costs; custody fees; small adjustment charges to 

correct bookkeeping errors; and, but 

not by way of limitation, minimum 

balance charges, notary and protest 

fees, and charges for reference books, 

photostats, credit reports, transcripts 

of statements, registered mail, insurance, stationery and supplies, check 

books, and other similar items. 

§ 536.506 Provision of certain legal 

services authorized. 

(a) The provision to or on behalf of a 

specially designated narcotics trafficker of the legal services set forth in 

paragraph (b) of this section is authorized, provided that all receipt of payment therefor must be specifically licensed. 

(b) Specific licenses may be issued, 

on a case-by-case basis, authorizing re31 CFR Ch. V (7–1–06 Edition) 

ceipt of payment of professional fees 

and reimbursement of incurred expenses for the following legal services 

by U.S. persons to a specially designated narcotics trafficker: 

(1) Provision of legal advice and 

counseling on the requirements of and 

compliance with the laws of any jurisdiction within the United States, provided that such advice and counseling 

is not provided to facilitate transactions that would violate any of the 

prohibitions contained in this part; 

(2) Representation of a specially designated narcotics trafficker when 

named as a defendant in or otherwise 

made a party to domestic United 

States legal, arbitration, or administrative proceedings; 

(3) Initiation of domestic United 

States legal, arbitration, or administrative proceedings in defense of property interests subject to U.S. jurisdiction of a specially designated narcotics 

trafficker; 

(4) Representation before any federal 

or state agency with respect to the imposition, administration, or enforcement of United States sanctions 

against significant narcotics traffickers centered in Colombia or specially designated narcotics traffickers; 

and 

(5) Provision of legal services in any 

other context in which prevailing 

United States law requires access to 

legal counsel at public expense. 

(c) The provision of any other legal 

services to a specially designated narcotics trafficker, not otherwise authorized in or exempted by this part, requires the issuance of a specific license. 

(d) Entry into a settlement agreement affecting property or interests in 

property of a specially designated narcotics trafficker or the enforcement of 

any lien, judgment, arbitral award, decree, or other order through execution, 

garnishment or other judicial process 

purporting to transfer or otherwise 

alter or affect a property interest of a 

specially designated narcotics trafficker is prohibited unless specifically 

licensed in accordance with § 536.202(e). 

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Office of Foreign Assets Control, Treasury 

§ 536.507 Authorization of emergency

medical services. 

The provision of nonscheduled emergency medical services to a specially 

designated narcotics trafficker located 

in the United States is authorized, provided that any payment for such services requires prior authorization by 

specific license. 

Subpart F—Reports 

§ 536.601 Records and reports. 

For provisions relating to records 

and reports, see subpart C of part 501 of 

this chapter. 

[62 FR 45107, Aug. 25, 1997] 

Subpart G—Penalties 

§ 536.701 Penalties. 

(a) Attention is directed to section 

206 of the International Emergency 

Economic Powers Act (50 U.S.C. 1705— 

the ‘‘Act’’), which is applicable to violations of the provisions of any license, 

ruling, regulation, order, direction or 

instruction issued by or pursuant to 

the direction or authorization of the 

Secretary of the Treasury pursuant to 

this part or otherwise under the Act. 

Section 206 of the Act, as adjusted pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990 (Pub. L. 

101–410, as amended, 28 U.S.C. 2461 

note), provides that: 

(1) A civil penalty of not to exceed 

$50,000 per violation may be imposed on 

any person who violates any license, 

order, or regulation issued under the 

Act; 

(2) Whoever willfully violates any license, order, or regulation issued under 

the Act shall, upon conviction, be fined 

not more than $50,000, or, if a natural 

person, may be imprisoned for not 

more than twenty years, or both; and 

any officer, director, or agent of any 

corporation who knowingly participates in such violation may be punished by a like fine, imprisonment or 

both. 

(b) The criminal penalties provided 

in the Act are subject to increase pursuant to 18 U.S.C. 3571. 

(c) Attention is also directed to 18 

U.S.C. 1001, which provides that whoever, in any matter within the jurisdic-

§ 536.703 

tion of any department or agency of 

the United States, knowingly and willfully falsifies, conceals or covers up by 

any trick, scheme, or device a material 

fact, or makes any false, fictitious or 

fraudulent statements or representations or makes or uses any false writing or document knowing the same to 

contain any false, fictitious or fraudulent statement or entry, shall be fined 

under title 18, United States Code, or 

imprisoned not more than five years, 

or both. 

(d) Violations of this part may also 

be subject to relevant provisions of 

other applicable laws. 

[62 FR 9960, Mar. 5, 1997, as amended at 71 FR 

29252, May 22, 2006] 

§ 536.702 Prepenalty notice. 

(a) When required. If the Director of 

the Office of Foreign Assets Control 

has reasonable cause to believe that 

there has occurred a violation of any 

provision of this part or a violation of 

the provisions of any license, ruling, 

regulation, order, direction or instruction issued by or pursuant to the direction or authorization of the Secretary 

of the Treasury pursuant to this part 

or otherwise under the International 

Emergency Economic Powers Act, and 

the Director determines that further 

proceedings are warranted, he shall 

issue to the person concerned a notice 

of his intent to impose a monetary penalty. The prepenalty notice may be 

issued whether or not another agency 

has taken any action with respect to 

this matter. 

(b) Contents—(1) Facts of violation. 

The prepenalty notice shall describe 

the violation, specify the laws and regulations allegedly violated, and state 

the amount of the proposed monetary 

penalty. 

(2) Right to respond. The prepenalty 

notice also shall inform the respondent 

of respondent’s right to respond to the 

notice within 30 days of its mailing as 

to why a monetary penalty should not 

be imposed, or, if imposed, why it 

should be in a lesser amount than proposed. 

§ 536.703 Response to prepenalty notice. 

(a) Time within which to respond. The 

respondent shall have 30 days from the 

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§ 536.704 

date of mailing of the prepenalty notice to respond in writing to the Director of the Office of Foreign Assets Control. 

(b) Form and contents of written response. The written response need not 

be in any particular form, but shall 

contain information sufficient to indicate that it is in response to the 

prepenalty notice. It should respond to 

the allegations in the prepenalty notice and set forth the reasons why the 

person believes the penalty should not 

be imposed or, if imposed, why it 

should be in a lesser amount than proposed. 

(c) Informal settlement. In addition or 

as an alternative to a written response 

to a prepenalty notice pursuant to this 

section, the respondent or respondent’s 

representative may contact the Office 

of Foreign Assets Control as advised in 

the prepenalty notice to propose the 

settlement of allegations contained in 

the prepenalty notice and related matters. In the event of settlement at the 

prepenalty stage, the prepenalty notice 

will be withdrawn, the respondent is 

not required to take a written position 

on allegations contained in the 

prepenalty notice, and the Office of 

Foreign Assets Control will make no 

final determination as to whether a 

violation occurred. The amount accepted in settlement of allegations in a 

prepenalty notice may vary from the 

civil penalty that might finally be imposed in the event of a formal determination of violation. In the event no 

settlement is reached, the 30–day period specified in paragraph (a) of this 

section for written response to the 

prepenalty notice remains in effect unless additional time is granted by the 

Office of Foreign Assets Control. 

§ 536.704 Penalty notice. 

(a) No violation. If, after considering 

any written response to the prepenalty 

notice and any relevant facts, the Director of the Office of Foreign Assets 

Control determines that there was no 

violation by the respondent named in 

the prepenalty notice, the Director 

promptly shall notify the respondent in 

writing of that determination and that 

no monetary penalty will be imposed. 

(b) Violation. If, after considering any 

written response to the prepenalty no31 CFR Ch. V (7–1–06 Edition) 

tice and any relevant facts, the Director of the Office of Foreign Assets Control determines that there was a violation by the respondent named in the 

prepenalty notice, the Director 

promptly shall issue a written notice of 

the imposition of the monetary penalty 

or other available disposition on the 

respondent. 

§ 536.705 Administrative collection; referral to United States Department 

of Justice. 

In the event that the respondent does 

not pay the penalty imposed pursuant 

to this part or make payment arrangements acceptable to the Director of the 

Office of Foreign Assets Control within 

30 days of the mailing of the written 

notice of the imposition of the penalty, 

the matter may be referred for administrative collection measures or to the 

United States Department of Justice 

for appropriate action to recover the 

penalty in a civil suit in a Federal district court. 

Subpart H—Procedures 

§ 536.801 Procedures. 

For license application procedures 

and procedures relating to amendments, modifications, or revocations of 

licenses; administrative decisions; 

rulemaking; and requests for documents pursuant to the Freedom of Information and Privacy Acts (5 U.S.C. 

552 and 552a), see part 501, subpart E, of 

this chapter. 

[62 FR 45107, Aug. 25, 1997, as amended at 68 

FR 53657, Sept. 11, 2003] 

§ 536.802 Delegation by the Secretary 

of the Treasury. 

Any action which the Secretary of 

the Treasury is authorized to take pursuant to Executive Order 12978 or any 

further executive orders relating to the 

national emergency declared in Executive Order 12978 may be taken by the 

Director of the Office of Foreign Assets 

Control, or by any other person to 

whom the Secretary of the Treasury 

has delegated authority so to act. 

[62 FR 9960, Mar. 5, 1997. Redesignated at 62 

FR 45108, Aug. 25, 1997] 

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FROM THE OFFICE OF PUBLIC AFFAIRS 

June 8, 1999 

RR-3192 

TREASURY NAMES MORE FRONTS OF COLOMBIAN DRUG CARTELS 

The Treasury Department on Monday added 41 businesses and eight individuals to 

its list of Specially Designated Narcotics Traffickers (SDNTs), a list designated for 

economic sanctions against Colombian drug cartels. 

Treasury's Office of Foreign Assets Control (OFAC) has determined that these 49 

new SDNTs are acting as fronts for the Cali and North Coast cartels. Among the 

notable drug cartel owned or controlled businesses on the list is the América soccer 

team, determined to be owned or controlled by Cali cartel leader Miguel Rodriguez 

Orejuela and other named SDNTs. Other named drug cartel owned or controlled 

businesses include several pharmaceutical and drug companies, a radio 

broadcasting company, as well as investment, construction and real estate firms. 

"Today's action sends a clear message that we will not allow corporate sleight-ofhand to enable the cartels to profit by using the U.S. financial system and by 

engaging in American business transactions," said James E. Johnson, Treasury 

Under Secretary for Enforcement. "This list of companies shows the extent to which 

narcotics traffickers' illicit proceeds have infiltrated various commercial sectors as 

the traffickers attempt to legitimize their drug profits." 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out President Clinton's Executive Order 12978, signed 

on October 21, 1995, which applies economic sanctions against the Colombian 

drug cartels. With the addition of names released today, a total of 496 businesses 

and individuals whose assets are blocked under the 1995 Executive Order are also 

prohibited from American financial and business dealings. 

The list of SDNTs includes the four Cali cartel drug kingpins named in the Executive 

Order, North Coast narcotics trafficker Julio Cesar Nasser David, and 491 other 

SDNTs that have been determined to be owned or controlled by, or to act for or on 

behalf of, persons designated in or pursuant to the Order. 

Nine of the newly designated companies are successors or "transformers," using 

new company names to firms previously designated as SDNTs because they were 

owned or controlled by the kingpins or agents of the cartels. A total of 27 

transformer companies have been named as SDNTs to date. The U.S. Government 

will continue to identify businesses owned or controlled by drug cartels and expand 

the SDNT list to include additional Colombian drug trafficking organizations. 

The list of businesses and individuals named by Treasury today as SDNTs is 

available at www.treas.gov/ofac. The list will be published in the Federal Register at 

a later date. 

130 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

February 23, 2000 

LS-413 

TREASURY NAMES COLOMBIAN DRUG KINGPINS TO TRAFFICKERS LIST 

The Treasury Department today added the names of Ivan and Julio Fabio Urdinola 

Grajales, among the most wealthy and powerful drug kingpins operating in 

Colombia today, their fronts from the North Valle drug cartel, and additional fronts 

belonging to Cali cartel kingpins Gilberto and Miguel Rodriguez Orejuela to the list 

of Specially Designated Narcotics Traffickers (SDNTs). 

The Treasury action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, further exposing, isolating, and 

incapacitating Colombian drug cartels and their agents. The two drug kingpins 

named to the SDNT list today by Treasury have risen to prominence with the 

decline of the Cali cartel and are responsible for huge volumes of drugs that have 

entered the United States. In addition to the two drug kingpins, Treasury added 20 

businesses and 9 associated individuals that it has determined are acting as fronts 

for the North Valle and Cali drug cartels. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out President Clinton's Executive Order 12978, signed 

on October 21, 1995, which applies economic sanctions against the Colombian 

drug cartels. The list of SDNTs includes kingpins, associates and businesses from 

Colombia's Cali, North Coast and North Valle drug cartels. 

With the addition of the names released today, the assets of a total of 527 

businesses and individuals are blocked under the 1995 Executive Order and are 

prohibited from American financial and business dealings. The list of businesses 

and individuals named by Treasury today as SDNTs is available at 

www.treas.gov/ofac. The list will be published in the Federal Register at a later 

date. 

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FROM THE OFFICE OF PUBLIC AFFAIRS 

August 18, 2000 

LS-844 

TREASURY NAMES COLOMBIAN DRUG KINGPINS TO TRAFFICKERS LIST 

The Treasury Department today added the names of Arcangel de Jesus Henao 

Montoya, a leader of one of the most powerful drug trafficking groups that comprise 

Colombia's North Valle drug cartel, and Juan Carlos Ramirez Abadia, a Cali cartel 

drug kingpin, to the list of Specially Designated Narcotics Traffickers (SDNTs). 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels. 

The Treasury action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. The two 

Colombian drug kingpins named to the SDNT list today by Treasury are responsible 

for huge volumes of drugs that have entered the United States. In addition to the 

two drug kingpins, Treasury added five businesses and one associated individual 

that it has determined are acting as fronts for the North Valle drug cartel. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out President Clinton's Executive Order 12978, signed 

on October 21, 1995, which applies economic sanctions against the Colombian 

drug cartels. With the addition of the names released today, the assets of a total of 

532 businesses and individuals are blocked under the 1995 Executive Order; and 

those businesses and individuals are prohibited from American financial and 

business dealings. 

The list of SDNTs now includes nine kingpins from Colombia's drug cartels, namely 

Cali cartel drug kingpins Gilberto Rodriguez Orejuela, Miguel Rodriguez Orejuela, 

Jose Santacruz Londoño, Helmer Herrera Buitrago, and Juan Carlos Ramirez Abadia; North Coast cartel drug kingpin Julio Cesar Nasser David; and North Valle 

cartel drug kingpins Ivan Urdinola Grajales, Julio Fabio Urdinola Grajales, and Arcangel de Jesus Henao Montoya. The U.S. Government will continue to identify 

businesses owned or controlled by Colombian drug cartels and expand the SDNT 

list to include additional drug traffickers and their organizations. 

The list of businesses and individuals named by Treasury today as SDNTs is 

attached and available at www.ustreas.gov/ofac, as is the entire list of SDNTs. The 

list will be published in the Federal Register at a later date. 

132 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FOR IMMEDIATE RELEASE Contact: Public Affairs 

December 22, 2000 (202) 622-2960 

TREASURY NAMES MORE FRONTS OF COLOMBIAN DRUG CARTELS 

The Treasury Department today added the names of eight businesses and eight 

individuals to its list of Specially Designated Narcotics Traffickers (SDNTs). SDNTs are subject 

to the economic sanctions imposed against Colombian drug cartels. 

Treasury’s Office of Foreign Assets Control (OFAC) has determined that these 16 new 

SDNTs are acting as fronts for Colombia’s Cali and North Coast drug cartels. Among the drug 

cartel businesses added to the list of SDNTs today are several determined to be owned or 

controlled by Cali cartel leader Miguel Rodriguez Orejuela and other named SDNTs. The 

Treasury action blocks the assets of SDNTs found in U.S. jurisdiction and prohibits Americans 

from doing business with them. The eight drug cartel businesses announced today on the list join 

220 other entities on the SDNT list including Copservir and its Drogas La Rebaja drugstore 

chain, the America de Cali professional soccer team, the Cosmepop cosmetics company, a radio 

broadcasting company, as well as investment, construction, real estate, agricultural, and 

distribution firms. 

This action is part of the ongoing interagency effort of the Treasury, Justice and State 

Departments to carry out President Clinton's Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against the Colombian drug cartels. With the addition of 

the names released today, the assets of a total of 548 businesses and individuals are blocked 

under the 1995 Executive Order and those businesses and individuals are prohibited from 

financial and business dealings with U.S. persons. The list of SDNTs now includes nine kingpins 

from Colombia’s drug cartels, namely Cali cartel drug kingpins Gilberto Rodriguez Orejuela, 

Miguel Rodriguez Orejuela, Jose Santacruz Londoño, Helmer Herrera Buitrago, and Juan Carlos 

Ramirez Abadia; North Coast cartel drug kingpin Julio Cesar Nasser David; and North Valle 

cartel drug kingpins Ivan Urdinola Grajales, Julio Fabio Urdinola Grajales, and Arcangel de 

Jesus Henao Montoya. The U.S. Government will continue to identify businesses owned or 

controlled by Colombian drug cartels and expand the SDNT list to include additional drug 

traffickers and their organizations. 

The list of businesses and individuals named by Treasury today as SDNTs is attached and 

available at www.ustreas.gov/ofac, as is the entire list of SDNTs. The list will be published in 

the Federal Register at a later date. 

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FROM THE OFFICE OF PUBLIC AFFAIRS 

April 24, 2001 

PO-219 

TREASURY NAMES COLOMBIAN DRUG KINGPIN TO TRAFFICKERS LIST 

The Treasury Department today added the name of Victor Julio Patiño Fomeque, a 

Colombian drug cartel kingpin, to the list of Specially Designated Narcotics 

Traffickers (SDNTs). SDNTs are subject to the economic sanctions imposed 

against Colombian drug cartels. 

The Treasury action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. The 

Colombian drug kingpin named to the SDNT list today by Treasury manages 

maritime drug smuggling operations out of the Pacific port of Buenaventura, 

Colombia. In addition to the drug kingpin, Treasury added three businesses and 

twenty-six associated individuals that it has determined are acting as fronts for 

Victor Julio Patiño Fomeque. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against the Colombian drug cartels. With 

the addition of the names released today, the assets of a total of 578 businesses 

and individuals are blocked under the 1995 Executive Order; and those businesses 

and individuals are prohibited from American financial and business dealings. The 

list of SDNTs now includes ten kingpins from Colombia's drug cartels, namely Cali 

cartel drug kingpins Gilberto Rodriguez Orejuela, Miguel Rodriguez Orejuela, Jose 

Santacruz Londoño, Helmer Herrera Buitrago, and Juan Carlos Ramirez Abadia; 

North Coast cartel drug kingpin Julio Cesar Nasser David; and North Valle cartel 

drug kingpins Ivan Urdinola Grajales, Julio Fabio Urdinola Grajales, and Arcangel 

de Jesus Henao Montoya. The U.S. Government will continue to identify 

businesses owned or controlled by Colombian drug cartels and expand the SDNT 

list to include additional drug traffickers and their organizations. 

The list of businesses and individuals named by Treasury today as SDNTs is 

attached and available at www.treas.gov/ofac, as is the entire list of SDNTs. The list 

will be published in the Federal Register at a later date. 

134 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

October 25, 2002 

PO-3579 

Treasury Designates North Valle Drug Cartel Leader s 

The Treasury Department’s Office of Foreign Assets Control (OFAC) today added 

the names of Diego Leon Montoya Sanchez and Luis Hernando Gomez 

Bustamante, two leaders of the violent North Valle drug cartel in Colombia, to its list 

of Specially Designated Narcotics Traffickers (SDNTs). SDNTs are subject to the 

economic sanctions imposed against Colombian drug cartels in Executive Order 

12978. 

The OFAC action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. The 

Colombian drug kingpins named to the SDNT list today by OFAC smuggle multi-ton 

quantities of cocaine into the United States. In addition to the two North Valle cartel 

leaders, OFAC has added 13 businesses and 21 associated individuals in 

Colombia that it has determined are acting as fronts for Diego Leon Montoya 

Sanchez, Luis Hernando Gomez Bustamante and another North Valle cartel leader, 

Arcangel de Jesus Henao Montoya, previously named an SDNT principal individual 

by OFAC in August 2000. OFAC has cooperated over the past year with the 

Federal Bureau of Investigation’s Miami office in the designation of Diego Leon 

Montoya Sanchez. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against the Colombian drug cartels. With 

the addition of the names released today, the assets of a total of 613 businesses 

and individuals are blocked under the 1995 Executive Order; and those businesses 

and individuals are prohibited from American financial and business dealings. The 

list of SDNTs now includes 12 kingpins from Colombia’s drug cartels, namely Cali 

cartel leaders Gilberto Rodriguez Orejuela, Miguel Rodriguez Orejuela, Jose 

Santacruz Londoño, Helmer Herrera Buitrago, and Juan Carlos Ramirez Abadia; 

North Coast cartel leader Julio Cesar Nasser David; and North Valle cartel leaders 

Ivan Urdinola Grajales, Julio Fabio Urdinola Grajales, Arcangel de Jesus Henao 

Montoya, Victor Julio Patiño Fomeque, Luis Hernando Gomez Bustamante and 

Diego Leon Montoya Sanchez. 

The list of businesses and individuals named by OFAC today as SDNTs is attached 

and available at www.treas.gov/ofac, as is the entire list of SDNTs. The list will be 

published in the Federal Register at a later date. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

135 
TABLE OF CONTENTS APPENDIX

NORTH VALLE CARTEL Department of the Treasury

SDNT Designations OFAC 

(a.k.a. Don Diego)

3 companies 4 individuals

Diego Leon MONTOYA SANCHEZ 

Luis Hernando GOMEZ BUSTAMA NTE 

(a.k.a. Rasguño)

8 companies 9 individuals 

Previously designated by OFAC in August 2000, 

pursuant to E.O. 12978 

2 companies 7 individuals

Arcangel de Jesus HENAO MONTOYA 

Department of the TreasuryOffice of Foreign Assets Control 

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

136 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

February 6, 2003 

JS-15 

Treasury Designates Cali Cartel Network in Spain and Colombia 

The Treasury Department’s Office of Foreign Assets Control (OFAC) last night 

added the names of 59 businesses and 78 individuals to its list of Specially 

Designated Narcotics Traffickers (SDNTs). SDNTs are subject to the economic 

sanctions imposed against Colombian drug cartels in Executive Order 12978. 

OFAC has determined that these 137 new SDNTs are acting as fronts for 

Colombia’s Cali drug cartel and are part of its international business and financial 

network operating in Spain and Colombia. The drug cartel businesses added to the 

list of SDNTs today are all determined to be owned or controlled by Cali cartel 

leaders Miguel Rodriguez Orejuela, currently incarcerated in a Colombian 

maximum security prison, Gilberto Rodriguez Orejuela, and other named SDNTs. 

The OFAC action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. The 59 Cali 

drug cartel businesses announced today include 10 Colombian-owned Spanish 

companies and 49 Colombian companies. In Spain, the businesses include real 

estate firms, an Internet services company, a coffee import/export company, a 

general services company, a graphic arts services provider, and a film distribution 

services company. In Colombia, the businesses include a money exchange house, 

pharmaceutical manufacturers and distributors, import/export firms, and investment, 

real estate and consulting companies. 

The network of 59 Cali cartel fronts in Spain and Colombia named today on the list 

join 244 other Colombian drug cartel businesses on the SDNT list. The list includes 

Cali cartel businesses Copservir, and its Drogas La Rebaja drugstore chain and 

Credirebaja charge card, the America de Cali professional soccer team, the 

Cosmepop cosmetics company, the Farmacoop pharmaceutical laboratory, a Cali 

radio broadcasting company, as well as consulting, investment, construction, real 

estate, agricultural, and distribution firms. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against Colombia’s drug cartels. 

The assets of a total of 749 Colombian drug cartel businesses and individuals are 

now blocked under the 1995 Executive Order; and those businesses and 

individuals are prohibited from American financial and business dealings. The list of 

SDNTs includes 12 kingpins from Colombia’s Cali, North Valle, and North Coast 

drug cartels. 

The list of businesses and individuals named by OFAC as SDNTs today is attached 

and available at www.treas.gov/ofac, as is the entire list of SDNTs. Today’s list will 

be published in the Federal Register at a later date. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

137 
TABLE OF CONTENTS APPENDIX

APPENDIX B 

138 

i

married

married 

shareholder

shareholder

sister 

i / 

l i i

C.C. 16637592 

l

C.C. 31931887 

C.C. 31976822 

l

C.C. 66810048

i

i

C.C. 66860965 

i

i i

ipe

C.C. 16752582 

Sharvet S.A.

i

i

Asems E.U.

los

C.C. 16703148 

i

i

iali i

i l

l i

l

i

i

Fomentamos

i i

il

i

C.C. 51741013 

i

C.C. 31972596

ipe

C.C. 16274109 

C.C. 16242828 

Codisa

ini Asprecol Ltda.

l

l

C.C. 31999055 

i

iaga 

ja/ 

ir Ltda.

Andre Gilberto

i

i Distriexport C.I. S.A.

l 

il

Consulting 

Real

Cali CartelBusiness StructureFebruary 2003

Office of Foreign Assets Control 

DESIGNATION ANNOUNCEMENTS AND CHARTS 

IMPACT REPORT 

owner 

shareholder 

owner 

owner 

shareholder 

owner 

owner 

owner 

shareholder 

owner 

owner 

owner 

owner 

officer president 

owner 

manager 

marr ed

married 

administrator administrator 

administrator 

owner 

owner 

owner 

shareholder 

shareholder 

shareholder shareholder 

shareholder 

owner 

shareholder

shareholder 

director/ 

shareholder Money exchange house 

Account holders 

Accounting 

Security 

Distribut onretail -- Cali 

Rodriguez Orejuela family members 

SDNTs 

SPAIN 

Real estate/ investment 

Pharmaceutica production/d str bution -- Bogota 

Types of Companies 

Jaime 

Rodriguez Mondragon 

Flor de Maria 

Sanc emente Bedoya 

Soraya 

Muñoz Rodriguez 

Aspen E.U.

NIT 805020437-0 

D.C.M. Consu toria E.U. 

NIT 800934781-4 

Serbana E.U.

NIT 830050331-8 

Asing E.U.

NIT 805005185-7 

Prospectiva E.U.

NIT 805006189-0 

Alexandra 

Rodriguez Mondragon 

Mar a Fernanda 

Rodr guez Arbelaez

Consultor a Santafe E.U. 

NIT 830043033-9 

Customer Networks S.L. 

CIF B82998543 

Cafe Andino S.L. 

CIF B81891244 

Rodriguez y Tolbaños S.A. 

CIF A82467887 

CPV S stemas Graf cos S.L. 

CIF B82201039 

Andres Fel

Roa Gutierrez

NIT 830050743-9 

Drocard S.A.

NIT 830059716-0 

Farma 3.000 Ltda. 

NIT 802012873-4 

Distr buidora Sanar de Colombia S.A. 

NIT 805011728-0 

Tervet S.A.

NIT 830068307-1 

Americana de Cosmet cos S.A. 

NIT 830028750-9 

NIT 805012381-3 

Juan Car

Muñoz Rodriguez

2000 Dose E.U. 

NIT 805015749-3 

Prosalud y B enestar S.A. 

Genes S.A.

NIT 890311169-1 

NIT 830050661-3 

Latina de Cosmet cos S.A. 

NIT 830018857-5 

Comerc zadora D glo Ltda. 

NIT 800789578-3 

Distribuc ones G omil Ltda. 

NIT 805008233-6 Comercializadora Intertel S.A.

Fogensa S.A. 

NIT 805015152-7 

NIT 804005325-8 

Productos Ga o y C a. Ltda. 

NIT 800102729-0 

Matsum S.A. 

NIT 830031863-3 

Te efarma

NIT 860527387-8 

Farma XXI Ltda. 

NIT 813006330-2 

Supergen Ltda.

NIT 804009924-8 

Inversiones Kanton Ltda. 

NIT 807000572-9 

Inversiones Nuevo Dia E.U. 

NIT 830020410-3 Rentar Inmob liaria S.A. NIT 805012015-2 

Contactel Comun caciones S.A. 

NIT 805020429-1 

Inversiones Sampla E.U.

NIT 830020409-5 

NIT 830060914-4 

Coomercol

NIT 805010372-8 

Credisol

NIT 830033943-3 

Inversiones y D stribuc ones A M M Ltda. 

NIT 800192791-2 

Inversiete S.A.

NIT 800234909-6 

Claudia P ar 

Rodr guez Ramirerz

Adr ana 

Orozco Niño

Andres Fel

Idarraga Rios

Media Marketing E.U.

NIT 805019234-0 

Internacional de Divisas S.A. 

NIT 805013989-5 

Colimex Ltda.

NIT 800256902-1 

Teconta

NIT 860524476-1 

Caja Solidaria

NIT 830033942-6 

Jaromo Inversiones S.L.

CIF B81784548 

Inversiones Claupi S.L.

CIF B81684421 

Genega Ltda.

NIT 805006744-9 

Adm stradora de Servicios Varios Calima S.A. 

NIT 805007874-2 NIT 805021375-7 

Inversiones Inmobiliarias Valeria S.L. 

CIF B81681454 

Inversiones Españo es Femcar S.L. 

CIF B82290727 

Gilberto and Miguel Rodriguez Orejuela 

Claudia Patricia 

Sanc emente Bedoya 

Vicente Antonio 

Nuñez Tolbaños

DNI 8966981-V 

Ignac o Garcia 

de la Fuente Arr

DNI 27340558-K 

Drogas La Reba

Copserv

NIT 830011670-3 

Farmacoop

NIT 830010878-3 

Cosmepop

NIT 800251322-5 

Valores Corporativos Españoles S.L.

CIF B81681447 

Inversiones Doble Cero E.U.

NIT 830021696-7 

Inmobiliaria Imtasa Ltda. 

NIT 805012623-0 

Rodriguez Ramirez 

C.C. 16798937 

Humberto 

Rodr guez Mondragon 

C.C. 16688683 

Serv futura Ltda.

NIT 830044689-4 NIT 830047057-3 

2000-Dodge S.L.

CIF B83149955 

LEGEND 

Laboratory 

Financia

Distribution/ 

Reta

Service/

 Estate/ 

Investment 

Securtiy 

Red-type denotes inclusion on OFAC's list of SDNTs 

Department of the Treasury
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

March 21, 2003 

JS-122 

Treasury Designates Additional Cali Cartel Fronts in Colombia 

The Treasury Department’s Office of Foreign Assets Control (OFAC) today added 

the names of nine businesses and eight individuals to its list of Specially 

Designated Narcotics Traffickers (SDNTs). SDNTs are subject to the economic 

sanctions imposed against Colombian drug cartels in Executive Order 12978. The 

drug cartel businesses added to the list of SDNTs today are all determined to be 

owned or controlled by Cali cartel leaders Miguel Rodriguez Orejuela, currently 

incarcerated in a Colombian maximum security prison, Gilberto Rodriguez Orejuela, 

arrested in Colombia on March 12, and other named SDNTs. 

The OFAC action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. The network 

of nine Cali drug cartel businesses announced today includes eight companies in 

Colombia and one Colombian-owned business in the U.S. Businesses named 

today include several affiliated with William Rodriguez Abadia, who is indicted in the 

U.S. on drug trafficking charges and whom the Colombian National Police sought to 

arrest during an operation in February. Among the businesses named today as 

SDNTs are: Coopcrear, a front which services cartel business accounts, including 

payments on-behalf of the cartel’s business Copservir, and its Drogas La Rebaja 

drugstore chain; Credivida, a front affiliated with the Drogas La Rebaja drugstore 

chain’s Credirebaja charge card; Seguwra del ValleE.U., a security front owned by 

William Rodriguez Abadia; and Servicios Myral E.U. and C y S Medios E.U., two 

additional companies with security functions affiliated with the Rodriguez Orejuela 

organization. Financial cooperatives, such as Coopcrear named today, are created 

by the Cali cartel using trusted corporate officers to provide bank account services 

to its business fronts. Also named today as part of the cartel’s financial network is 

the Colombian stock brokerage firm Obursatiles S.A. and its U.S. affiliate, 

Internacional de Divisas S.A., LLC, a money exchange house based in Miami, 

Florida. Obursatiles S.A. has been blocked pending investigation since February 

12. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against Colombia’s drug cartels. The 

assets of a total of 766 Colombian drug cartel businesses and individuals are now 

blocked under the 1995 Executive Order; and those businesses and individuals are 

prohibited from American financial and business dealings. The list of SDNTs 

includes 12 kingpins from Colombia’s Cali, North Valle, and North Coast drug 

cartels. 

The list of SDNTs named today is attached and is available at www.treas.gov/ofac, 

as is the entire list of SDNTs. A graphic describing the use of Colombian financial 

cooperatives, such as Coopcrear named today, by the Cali cartel also is available. 

Today’s list will be published in the Federal Register at a later date. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

139 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS

140 IMPACT REPORT
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®. 

March 27, 2003 

JS-138 

Treasury Designates New Cali Cartel Leaders 

The Treasury Department’s Office of Foreign Assets Control (OFAC) today added 

the names of new Cali drug cartel leaders Joaquin Mario Valencia Trujillo and 

Guillermo Valencia Trujillo to its list of Specially Designated Narcotics Traffickers 

(SDNTs). This action also targets their network of 28 front companies and 28 

individuals. SDNTs are subject to the economic sanctions imposed against 

Colombian drug cartels in Executive Order 12978. 

The drug cartel businesses added to the list of SDNTs today are all determined to 

be owned or controlled by Cali cartel leaders Joaquin Mario and Guillermo Valencia 

Trujillo. OFAC has cooperated over the past two years with the U.S. Attorney’s 

Office for the Middle District of Florida and Operation Panama Express, a multiagency drug task force based out of Tampa, Florida, in the designation of Joaquin 

Mario Valencia Trujillo and his network of front companies. 

The OFAC action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, further exposing, isolating, and 

incapacitating Colombian drug cartels and their agents. The network of 28 Cali 

drug cartel businesses announced today includes a prominent paso fino horse 

farm, Criadero La Luisa, an industrial paper manufacturer, Unipapel S.A., a plastics 

company, Geoplasticos S.A., a maritime services provider, Gran Muelle S.A., and 

five financial firms, Compania de Fomento Mercantil S.A., Credisa S.A., Finve S.A., 

Gestora Mercantil S.A., and Unidas S.A., all located in Colombia. 

Also included in the new SDNT list are several commercial paper businesses, 

maritime agencies, real estate, mining, sporting and consulting companies. These 

28 front companies join 312 other Colombian drug cartel businesses on the SDNT 

list. 

This action is part of the ongoing interagency effort of the Treasury, Justice and 

State Departments to carry out Executive Order 12978, signed on October 21, 

1995, which applies economic sanctions against Colombia’s drug cartels. The 

assets of a total of 824 Colombian drug cartel businesses and individuals are now 

blocked under the 1995 Executive Order; and those businesses and individuals are 

prohibited from American financial and business dealings. The list of SDNTs now 

includes 14 kingpins from Colombia’s Cali, North Valle, and North Coast drug 

cartels. 

The list of businesses and individuals named by OFAC as SDNTs today is attached 

and available at www.treas.gov/ofac, as is the entire list of SDNTs. Today’s list will 

be published in the Federal Register at a later date. 

Related Documents: 

Charts.pdf 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

141 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS

142 IMPACT REPORT
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®. 

October 17, 2003 

JS-915 

TREASURY DESIGNATES NETWORK OF CALI DRUG CARTEL FRONT 

COMPANIES 

WASHINGTON -- The Treasury Department’s Office of Foreign Assets Control 

(OFAC) today added 39 businesses acting as front companies for the Cali drug 

cartel based in Colombia and 95 individuals associated with the cartel, and its 

activities through front companies, to its list of Specially Designated Narcotics 

Traffickers (SDNTs). Through a network of pharmaceutical businesses, the cartel 

has laundered money and has penetrated the Colombian economy. These front 

companies form a vital part of the Cali cartel’s international money laundering 

network. This action freezes their assets and prohibits financial and commercial 

transactions with U.S. nationals. The Treasury Department will continue to work 

with Colombian authorities on further actions to shut down the cartel’s financial 

network. 

“Today’s action demonstrates the Cali cartel’s continued use of pharmaceutical 

companies throughout Latin America and the Caribbean to launder drug money and 

to penetrate the legitimate economy,” stated OFAC Director Rick Newcomb. “The 

U.S. banking and pharmaceutical sectors should renew their vigilance against

providing financial services or supplying products to these front companies.” 

Included among the 39 businesses designated today are Interfarma/Jomaga de 

Costa Rica in Costa Rica, Latinfarmacos and Espibena in Ecuador, Colfarma Peru 

in Peru, Premier Sales in Panama, and C.A. V.J. Corporation in Venezuela, all 

affiliated with the international drug distribution of Cali cartel pharmaceutical 

laboratories Pentacoop and Farmacoop on the SDNT list. Also named today are 

numerous financial fronts in Colombia, such as Coopdisan, Drofarco, and 

Incommerce, which are created by the Cali cartel using trusted corporate officers to 

provide bank account services to its business fronts. Inversiones Carfeni and two 

internet companies in Spain and Ash Trading Inc. in the United States were also 

named. Today’s action is a follow-up to sanction actions directed against the Cali 

cartel in February and March of this year. 

The international network of 39 Cali cartel fronts named today join 340 other 

Colombian drug cartel businesses on the SDNT list. The list includes Cali cartel 

businesses Copservir, and its Drogas La Rebaja drugstore chain and Credirebaja 

charge card, the Obursatiles stock brokerage and Internacional de Divisas money 

exchange house, the Cosmepop cosmetics company, the America de Cali 

professional soccer team, as well as consulting, investment, financial, construction, 

real estate, agricultural, and distribution firms. 

This action is part of the ongoing interagency effort of the Treasury, Justice, State, 

and Homeland Security Departments to carry out Executive Order 12978, signed on 

October 21, 1995, which applies economic sanctions against Colombia’s drug 

cartels. The assets of a total of 958 Colombian drug cartel businesses and 

individuals are now blocked under the 1995 Executive Order; and those businesses 

and individuals are prohibited from American financial and business dealings. The 

list of SDNTs includes 14 kingpins from Colombia’s Cali, North Valle, and North 

Coast drug cartels. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

143 
TABLE OF CONTENTS APPENDIX

APPENDIX B 

144 

spouse 

owner 

director 

spouse 

manager 

treasurer

manager 

owner 

owner president 

director

$ US

general

manager

payment manager 

employee

manager 

manager 

manager 

general manager

of laboratories

charge

card 

$ US $ US 

Foundations 

Laboratories 

British Virgin Islands U.S.A. 

Spain 

Ecuador

Costa Rica

Panama

Peru

Venezuela

InternationalDrug Distribution

 Cali cartel leaders 

Drug Stores

 Exporters

The Bahamas 

Copservir -- Drogas La Rebajasuppliers & distributors

Financial services

**Farmacoop

NIT 830010878-3

**Cosmepop

NIT 800251322-5

**Pentacoop

NIT 830016989-1 

Colphar S.A.

Chamartin S.A.

NIT 830074552-2

NIT 805024137-4

Sisva Ltda.

NIT 805006032-3

G M C Grupo

MaquilacionColombiano

C.C. 41322501 

Laboratorios

Profarma Ltda.

NIT 800217468-8 

Distribuidoradel Valle E.U.

NIT 805007212-7 

Macrofarma S.A.

NIT 816005709-6 

Provida E.U.

NIT 805016716-5

Magen Ltda.

NIT 830070365-3

Lemofar Ltda.

NIT 830116405-1 

Incommerce S.A.

NIT 805023544-4 

Coopdisan

NIT 804005384-2 

**Codisa

NIT 860524476-1

Droblam S.A.

NIT 805014078-5

World

Trade Ltda.

NIT 809008109-5 

Coopertiva Mercantil

del Sur Ltda.

NIT 814002508-1 

**Matsum S.A.

NIT 830031863-3 

Mapri de

Colombia Ltda.

NIT 830103959-1 

VOL

Pharmacya Ltda.

NIT 807005617-4 

C A V J

Corporation Ltda.

NIT 830101426-9 

NIT 805002213-1 

Fundaser

NIT 800243417-2 

**Credirebaja S.A.

NIT 805001030-6 

**Copservir

Drogas La Rebaja

NIT 830011670-3 

**Adriana

Santacoloma Hoyos

C.C. 31919241 

Ash Trading, Inc.

U.S. FEIN 65-1128351 

**Maria Fernanda

Rodriguez Arbelaez

C.C. 66860965

**Carolina

Rodriguez Arbelaez

C.C. 29117505 

Inversiones

Carfeni S.L. 

Sociedad Inversora

en Proyectos de

Internet S.A. 

**Customer Networks S.L.

C.I.F. B82998543 

Galeria de Portales S.A.

C.I.F. A82464934

**Ignacio Garcia

de la Fuente Arriaga

D.N.I. 27340558-K 

**Fernando

Villota Galvis

C.C. 17118703 

C.A. V.J. Corporation

RIF J-30460672-9

Premier Sales S.A.Colfarma Peru S.A.

RUC 2033645155

Jomaga de

Costa Rica S.A.

a.k.a. Interfarma S.A.

Numero Judicial

Espibena S.A.

3-101-76327

RUC 1791706420001

**Rionap S.A.

Latinfarmacos S.A.

RUC 1791286812001 

Zaratan

Corporation 

Drofarco

NIT 802012877-3

Farmatel E.U. Import Mapri Ltda.

NIT 830079014-4 

Kesman

Overseas 

Pharmaceuticals

exported 

Pharmaceuticals

to Copservir

Goods &Services 

Licensed by INVIMA -­

National Institute for

the Regulation of

Medicines and Foods 

Colombian

Accounts 

Checks 

money

deposits 

Black text denotesdesignation in October 2003

** Red text denotes previously

designated SDNT

Department of the TreasuryOffice of Foreign Assets Control

Specially Designated Narcotics Traffickers (SDNTs)

**Gilberto **Miguel 

Rodriguez Orejuela Rodriguez Orejuela 

**Humberto

Rodriguez Mondragon

C.C. 16688683 

**Juan Carlos

Munoz Rodriguez

C.C. 16703148 

**Jaime

Rodriguez Mondragon

C.C. 16637592

**Maria Alexandra

Rodriguez Mondragon

C.C. 66810048 

**William

Rodriguez Abadia

C.C. 16716259 

**Claudia Pilar

Rodriguez Ramirez

C.C. 51741013 

William Edison

Jimenez Marin

C.C. 19415821

Colombian

Accounts 

U.S.

Accounts 

Comercializadora

de Productos

Farmaceuticos Ltda.

NIT 809010102-0 

Agro Mascotas S.A.

NIT 815002808-1 

**Fernando

Gutierrez Cancino

C.C. 6089071

Hernando

Gutierrez Mancipe

C.C. 2898335 

Ardila-Marmolejo, Ltd. Sepulveda-Iragorri, Ltd. 

Cali Cartel FrontsInternational NetworkOctober 2003 

payments 

DESIGNATION ANNOUNCEMENTS AND CHARTS 

IMPACT REPORT 

 Family Board of Directors -- "Veeduria"

Fundacion Vivir Mejor 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®. 

September 14, 2004 js-1915 

Treasury Designates Financial Web of Colombian Drug Lord s 

The U.S. Department of the Treasury today attacked the financial network of a 

Colombian drug cartel by designating 23 Colombian businesses and 118 individuals 

as Specially Designated Narcotics Traffickers (SDNTs). These entities were acting 

as fronts for the Cali drug cartel and its leaders, Miguel and Gilberto Rodriguez 

Orejuela. 

"Today's action assails the financial infrastructure of the notorious Cali drug cartel," 

said Stuart Levey, Treasury's Under Secretary for Terrorism and Financial 

Intelligence. "We are committed to dismantling the operations of drug Kingpins and 

their cartels by exposing, isolating and incapacitating their agents and sham 

companies and by denying them access to the U.S. financial system." 

These front companies and individuals form a vital part of the Rodriguez Orejuela 

organization's financial network in Colombia, which is centered on the drugstore 

chain Drogas La Rebaja and Copservir, the pharmaceutical laboratory Farmacoop 

and the cosmetics manufacturer Cosmepop. Today's action freezes any assets 

found in the United States and prohibits all financial and commercial transactions 

with U.S. entities. 

"We continue to pursue the financial network of Miguel and Gilberto Rodriguez 

Orejuela and their use of pharmaceutical companies and financial cooperatives in 

Colombia to launder drug money and infiltrate the legitimate economy," said Rick 

Newcomb, Director of Treasury's Office of Foreign Assets Control (OFAC). 

Included among the 23 businesses designated today are numerous financial front 

companies, including Coopifarma, Farmavision, Megapharma, Litopharma, 

Coomulcosta, Activar, Soluciones Cooperativas, Comudrogas, Villaro, Segecol, 

Trimark, Su Servicio Sociedad, Arca Distribuciones, Giamx, and JyG Asesores. 

These entities are all affiliated with Drogas La Rebaja and Copservir, which were 

named to the SDNT list in 1995 and 1997, respectively. Arias Espinosa Aries S.A., 

a key importer of raw materials for the SDNT pharmaceutical laboratory 

Farmacoop, is also named. 

Today's designation is a follow-up to previous actions taken by the Treasury against 

the world-wide financial network of the Rodriguez Orejuela organization in 

February, March and October 2003. 

The 23 front companies named today join 379 other Colombian drug cartel 

businesses on the SDNT list. The list also includes the Credirebaja charge card, the America de Cali professional soccer team, the Obursatiles stock brokerage, the 

Internacional de Divisas money exchange house, as well as agricultural, consulting, 

construction, distribution, financial, investment, manufacturing, mining, real estate 

and service firms. 

This action is part of the ongoing interagency effort of the Treasury, Justice, State 

and Homeland Security Departments to carry out Executive Order 12978, signed on 

October 21, 1995, which applies economic sanctions against Colombia's narcotics 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

145 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

traffickers. The assets of a total of 1,094 Colombian businesses and individuals are 

now blocked under E.O. 12978. The SDNT list includes 14 kingpins from the North 

Valle, North Coast and Cali drug cartels in Colombia, including Miguel and Gilberto 

Rodriguez Orejuela. A diagram of the businesses named by OFAC today is attached. 

For a complete list of the entities designated today, please visit: 

http://www.treas.gov/offices/enforcement/ofac/actions/20040914.shtml. 

For further information on actions taken against the Cali Cartel, please visit: 

http://www.treas.gov/press/releases/js15.htm (February 6, 2003) 

http://www.treas.gov/press/releases/js122.htm (March 21, 2003) 

http://www.treas.gov/press/releases/js915.htm (October 17, 2003) 

-30­

REPORTS 

Diagram of the Cali Cartel Financial Network 

146 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS CREATE & MANAGE FINANCIAL FRONTS DROGAS LA REBAJA & LABORATORIES Drogas La Rebaja officers FAMILY BOARD OF DIRECTORS -- "VEEDURIA" SUPPLIERS FINANCIAL FRONTS 

CALI DRUG LORDS 

GOODS &

SERVICES 

**COPSERVIR

DROGAS LA REBAJA

NIT 830011670-3 

**FARMACOOP

NIT 830010878-3 

SEGECOL LTDA.

NIT 804015530-4 

MEGAPHARMA

NIT 813002466-7 

JYG ASESORES LTDA.

NIT 830120367-3

COOMULCOSTA

NIT 802006273-0

COMUDROGAS

NIT 804001143-6

GIAMX LTDA.

VILLARO LTDA.

NIT 830117443-4 TRIMARK LTDA.

NIT 830117977-5NIT 830095943-9

FARMAVISION

NIT 830037372-6 

ARCA DISTRIBUCIONES

NIT 830131785-6

ACTIVAR

NIT 830099918-2

S L M K LTDA.

NIT 830044689-4 

SU SERVICIO

SOCIEDAD LTDA.

NIT 802021041-1

SOLUCIONES

COOPERATIVAS

NIT 8830118975-5 

FARMALIDER S.A.

NIT 805026183-2

FARMEDIS LTDA.

NIT 813009188-6

 CALI CARTEL

FINANCIAL NETWORK

September 2004 

**COSMEPOP

NIT 800251322-5 

**Jaime

Rodriguez Mondragon

C.C. 16637592 

**Maria Alexandra

Rodriguez Mondragon

C.C. 66810048 

**Humberto

Rodriguez Mondragon

C.C. 16688683 

**William

Rodriguez Abadia

C.C. 16716259 

**Gilberto **Miguel

 Rodriguez Orejuela Rodriguez Orejuela 

DISFOGEN LTDA.

NIT 830116941-6 

TECNOVET LTDA.

NIT 830092117-8

COOPIFARMA

NIT 830071338-9 

ARIAS ESPINOSA

ARIES S.A.

NIT 830012619-1

INVERSIONES

ASE LTDA.

NIT 800245987-8

EXCIPHARMA S.A.

NIT 830107839-4

**Name in red text denotesSDNT previously designated

Department of the TreasuryOffice of Foreign Assets Control 

Specially Designated Narcotics Traffickers (SDNTs)

**Claudia Pilar

Rodriguez Ramirez

C.C. 51741013 

**Juan Carlos

Munoz Rodriguez

C.C. 16703148 

Name in black text denotesSDNT designated September 2004 

LITOPHARMA

NIT 802012669-8

CASH DEPOSITS

FINANCIAL FRONT

BANK ACCOUNTS PAYMENTS 

SUPPLIER

INVOICES PAYMENTS 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

147 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

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October 14, 2004 js-2031 

Treasury Designates North Valle Drug Cartel Traffickers 

The U.S. Department of the Treasury targeted the financial network of the North 

Valle drug cartel by adding two of its leaders, Gabriel Puerta Parra and Luis Antonio 

Hernandez Zea, to the list of Specially Designated Narcotics Traffickers (SDNTs). 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. 

"With actions like today's, the U.S. Government is helping to topple the financial 

empires of drug cartels in Colombia and around the world. This designation 

exposes and undermines the financial network of the North Valle drug cartel in 

Colombia and denies these drug lords and their businesses access to the U.S. 

financial sector," said Juan Zarate, Treasury's Assistant Secretary for Terrorist 

Financing and Financial Crimes. 

"DEA is steadfast in its mission to strip illicit profits from the organizations that 

supply illegal drugs to the United States. Today's action is a testament to our 

partnership with OFAC and our foreign law enforcement counterparts. The power of 

combining the enforcement tools of DEA with the immense regulatory authority of 

the Treasury Department casts a shadow from which drug traffickers cannot hide," 

said Karen P. Tandy, Administrator of the Drug Enforcement Administration (DEA). 

Puerta Parra is a leading member of the North Valle drug cartel and is the subject 

of two federal criminal indictments in the United States, both unsealed earlier this 

year. The indictments filed in the District Court for the District of Columbia and the 

Southern District of Florida charge Puerta Parra with violations of the Racketeer 

Influenced and Corrupt Organizations Act and with conspiracy to import, possess 

and distribute cocaine in the United States. On October 7, 2004, Colombian 

National Police arrested Puerta Parra near Bogota, Colombia. He is currently 

awaiting extradition to the United States. Considered the statesman of the North 

Valle cartel, Puerta Parra has long played an influential role among drug cartel 

leaders, including resolving disputes within the North Valle cartel and with other 

drug cartels. 

"We are financially isolating Puerta Parra, his business associates, and his 

facilitators and wiping away the veneer of legitimacy of any of their activities," 

Zarate continued. 

In addition, the Colombian airline, Intercontinental de Aviacion S.A., and 14 other 

North Valle cartel businesses were also added to the list of SDNTs today. These 

entities were designated as they are owned or controlled by Puerta Parra and 

Hernandez Zea, as well as Piedad Velez Rengifo, the widow of deceased North 

Valle cartel kingpin Jose Orlando Henao Montoya. 

Intercontinental de Aviacion S.A. is a small, regional Colombian airline that has 

facilitated the North Valle cartel's drug trafficking and money laundering activities 

since the late 1980s. The network also includes two key offshore companies, Largo 

Leasing Limited in the Cayman Islands and Trans Pacific World Leasing Limited in 

Vanuatu, which are incorporated by and directly support Intercontinental de 

148 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

Aviacion. The other front companies announced today include a mining company, 

Industrial Minera y Pecuaria S.A., two financial investment firms, Accirent S.A., and 

Comercializadora Andino Brasilera S.A., a civil engineering firm, Inversiones y 

Comercializadora Incom Ltda., an airline finance company, Intercontinental de 

Financiacion Aerea S.A., an aircraft parts supplier, Aerocomercial Alas de Colombia 

Ltda., a travel services provider, Asociacion Turistica Internacional S.C.S., and a 

hotel management company, Cia. Constructora y Comercializadora del Sur Ltda., 

all of which are located in Columbia. 

Also designated today are 14 individuals who act as agents for Gabriel Puerta 

Parra , Luis Antonio Hernandez Zea and Piedad Velez Rengifo in the designated 

companies. Today's action freezes any assets found in the United States and 

prohibits all financial and commercial transactions between the designated persons 

and entities and any U.S. person. 

A total of 417 Colombian drug cartel businesses are now on the SDNT list. The list 

also includes the paso fino horse farm Criadero La Luisa E.U., the industrial paper 

manufacturer Unipapel S.A., the agro-industrial business Viscaya Ltda., the 

Obursatiles stock brokerage firm, and the America de Cali professional soccer 

team, as well as other agricultural, pharmaceutical, consulting, construction, 

distribution, financial, investment, manufacturing, mining, real estate and service 

firms. 

This action is part of the ongoing interagency effort, that includes the Departments 

of the Treasury, Justice, State and Homeland Security, to implement Executive 

Order 12978, signed on October 21, 1995, which applies economic sanctions 

against Colombia's drug cartels. Today's announcement is a result of the Treasury 

Department's Office of Foreign Assets Control's continuing close working 

relationship with U.S. law enforcement authorities, and particularly, in this case, 

DEA field offices in Phoenix and Miami. The U.S. government continues to work 

with and support the Colombian government in attacking the finances of Colombia's 

drug cartels. 

The assets of a total of 1,125 businesses and individuals in Colombia, Costa Rica, 

Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the British 

Virgin Islands, and the Cayman Islands, are now blocked under E.O. 12978. The 

SDNT list includes 16 kingpins from the Cali, North Valle, and North Coast drug 

cartels in Colombia, including Gabriel Puerta Parra and Luis Antonio Hernandez 

Zea. 

For a complete list of the entities designated today, please visit: 

http://www.treas.gov/offices/enforcement/ofac/actions/ 

LINKS 

Diagram of the North Valle Drug Cartel Financial Network 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

149 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

North Valle Drug Cartel Department of the Treasury 

Office of Foreign Assets Control Financial Network 

Widow 

Board Member 

Piedad VELEZ RENGIFO 

DOB 22 Oct 1959 

C.C. 31835778 

Bogota, Colombia 

NIT # 860009526-3 

October 2004 

Isabel Cristina GALVEZ FERNANDEZ 

DOB 23 Sept 1955 

C.C. 31280944 

Wife of PUERTA PARRA 

U.S. Federal Indictment 

April 2004 Gabriel PUERTA PARRA 

DOB 1 Oct 1942 

C.C. 8238830 

Luis Antonio HERNANDEZ ZEA 

DOB 7 May 1960 

C.C. 79252957 

Jose Orlando HENAO MONTOYA 

(Deceased) 

INTERCONTINENTAL DE AVIACION S.A. 

INTERCONTINENTAL SHAREHOLDERS 

VELEZ RENGIFO FRONT HERNANDEZ ZEA FRONTS PUERTA PARRA FRONTS 

INVERSIONES Y COMERCIALIZADORA ACCIRENT S.A. INCOM LTDA.
 NIT # 830088969-0 INDUSTRIAL MINERA Y PECUARIA S.A. NIT # 890329658-9
 "IMPECUA"


NIT # 830000855-1


AEROCOMERCIAL ALAS DE COLOMBIA LTDA. 

NIT # 800049071-7 LA FRONTERA UNION GALVEZ Y CIA S EN C 

NIT # 800050795-2 

AEROVIAS ATLANTICO LTDA. 

"AEROATLANTICO LTDA" 

NIT # 890109958-1 

ASOCIACION TURISTICA INTERNACIONAL S.C.S. 

NIT # 890325040-4 

RELATED COMPANIES 

PUERTA PARRA FRONT HERNANDEZ ZEA FRONTS 

GREEN ISLAND S.A. 

NIT # 830067456-4 

OFF-SHORE FRONT COMPANIES 

INTERCONTINENTAL DE 

FINANCIACION AEREA S.A. 

"INTERFIAR" 

NIT # 800043810-6 

VELEZ RENGIFO FRONT 

DESARROLLOS AGROINDUSTRIALES S.A. 

NIT # 830000782-2 

COMERCIALIZADORA ANDINO BRASILERA S.A. 

"CABRASA" 

NIT # 8300032982 

CONTROLLED BY HERNANDEZ ZEA 

CIA CONSTRUCTORA Y COMERCIALIZADORA DEL SUR LTDA.


"COSUR"


NIT # 890329758-7


TRANS PACIFIC LARGO LEASING LTD. 

WORLD LEASING LIMITED Cayman Islands 

Vanuatu 

BUSINESS ASSOCIATES 

Melba Rosa ARCE JARAMILLO 

C.C. 31945032 

Hilda Nelly MERCHAN PERILLA 

C.C. 41474108 

Alfonso RAMIREZ VALDIVIESO 

C.C. 17035234 

Alfonso SANCHEZ LOPEZ 

C.C. 318356 

Antonieta NUMA SANJUAN 

C.C. 60291819 

Manuel Antonio CUBILLOS CORREDOR 

C.C. 19057000 

Luis Alfredo GALLEGO RAMOS 

C.C. 16585721 

Ana Elvia HERNANDEZ ZEA 

C.C. 41503907 

Jaime Antonio OLIVELLA CELEDON 

C.C. 17100787 

Oliverio PEREZ NARVAEZ 

C.C. 6488451 

William VELEZ MONTES 

C.C. 17086144 

Elsa Yaneth TRIVINO RODRIGUEZ 

C.C. 20484603 

150 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

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November 17, 2004 

JS-2106 

Treasury Further Assails the Financial Infrastructure of the 

Cali Drug Cartel by Designating 23 Linked 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added seven businesses and 16 individuals to its list of Specially Designated 

Narcotics Traffickers (SDNTs). These companies and individuals were acting as 

fronts for Colombian drug lords Miguel and Gilberto Rodriguez Orejuela and formed 

a vital part of the organization's financial network in Colombia and abroad. 

"We have seen that the notorious Rodriguez Orejuela organization manipulates 

people and businesses – both inside Colombia and out – to traffic narcotics and 

bankroll their network," said OFAC Director Robert Werner. "We continue to attack 

the financial web of the Cali Cartel, and today's action ensures that these sham 

companies and operatives are denied access to the U.S. economy and financial 

system." 

Today's announcement is a follow-up to OFAC sanctions actions in 2003-2004 

against the world-wide financial network of the Rodriguez Orejuela organization. 

The OFAC action blocks the assets of SDNTs found in U.S. jurisdiction and 

prohibits Americans from doing business with them, thereby further exposing, 

isolating, and incapacitating Colombian drug cartels and their agents. 

U.S. fugitive William Rodriguez Abadia, son of Miguel Rodriguez Orejeula and heir 

to the organizational throne, is among the shareholders of Alero S.A., a garment 

manufacturer located in Cali, Colombia and named in today's action. Also included 

among the seven businesses designated today are the Colombian financial front 

companies, A G Representaciones Ltda., Inversiones Capital Ltda., 

Representaciones Zatza Ltda., and Valores Corporativos S.A. These businesses 

are all affiliated with the money remittance company Internacional de Divisas S.A. 

and the stock brokerage firm Obursatiles S.A., both of which were named to the 

SDNT list in 2003 because of their links to the Rodriguez Orejuela organization. In 

addition, Farfalla Investment S.A. of Panama and Galaviz Corporation, Ltd. of the 

Bahamas were also designated. 

The legal representative of Alero is Maria Iragorri Torres, who was named as an 

SDNT in March 2003 due to her involvement in Internacional de Divisas and 

Obursatiles. Iragorri Torres, who is also involved in Valores Corporativos, was 

arrested by Colombian authorities due to allegations of money laundering in 

January 2004. 

Previously designated SDNT entities from the Cali and North Valle cartels include 

the Colombian airline Intercontinental de Aviacion S.A., the paso fino horse farm 

Criadero La Luisa E.U., the industrial brick company Ladrillera La Candelaria Ltda., 

the mining company Industrial Minera y Pecuaria S.A., the industrial paper 

manufacturer Unipapel S.A., the agro-industrial business Viscaya Ltda., and the America de Cali professional soccer team, as well as other agricultural, aviation, 

consulting, construction, distribution, financial, hotel, investment, manufacturing, 

mining, offshore, pharmaceutical, real estate and service firms. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

151 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

This action is part of the ongoing interagency effort of the Treasury, Justice, State, 

and Homeland Security Departments to carry out Executive Order 12978, signed on 

October 21, 1995, which applies economic sanctions against Colombia's narcotics 

traffickers. The assets of a total of 1,147 Colombian businesses and individuals are 

now blocked under the 1995 Executive Order. The SDNT list includes 16 kingpins 

from the Cali, North Valle, and North Coast drug cartels in Colombia. 

A diagram of the businesses named by OFAC today is attached. 

For a complete list of the entities designated today, please visit: 

http://www.treas.gov/offices/enforcement/ofac/actions/ 

For further information on actions taken against the Cali Cartel, please visit: 

http://www.treasury.gov/press/releases/js1915.htm (September 14, 2004) 

http://www.treas.gov/press/releases/js15.htm (February 6, 2003) 

http://www.treas.gov/press/releases/js122.htm (March 21, 2003) 

http://www.treas.gov/press/releases/js915.htm (October 17, 2003) 

152 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS Legal Representative Related Financial Companies A G REPRESENTACIONES LTDA. Cali, Colombia NIT# 800132578-3 INVERSIONES CAPITAL LTDA. Cali, Colombia NIT# 800106082-2 REPRESENTACIONES ZATZA LTDA. Cali, Colombia NIT# 805011682-0 VALORES CORPORATIVOS S.A. (a.k.a. VALORCORP S.A.) Bogota, Colombia NIT# 830015542-7

Luis AlejandroARDILA HUYO

CC 16670574 

Claudia Patricia

SANCLEMENTE BEDOYA

CC 3199055 

Efrain Hernan

SEPULVEDA ZAPATA

CC 16449272 

Department of the Treasury

Office of Foreign Assets Control

Adriana

SANTACOLOMA HOYOS

CC 31919241 

Maria Alexandra

RODRIGUEZ MONDRAGON

CC 66810048

Jaime

MILLAN SALAS

CC 16589582 

Gonzalo

QUINTANA HERNANDEZ

CC 16603939 

Claudia Pilar

RODRIGUEZ RAMIREZ

CC 51741013 

Adriana

OROZCO NINO

CC 31972596 

Andre Gilberto

RODRIGUEZ RAMIREZ

CC 16798937 

Jaime

RODRIGUEZ MONDRAGON

CC 16637592

Alfredo

ROA MEJIA

CC 2439912 

Humberto

RODRIGUEZ MONDRAGON

CC 16688683 

Alicia

MONDRAGON AVILA

CC 29086016 

Maria Consuelo

IRAGORRI TORRES

CC 31921847

ALERO S.A.

Cali, Colombia NIT# 800239872-5 

RIONAP COMERCIO Y

REPRESENTACIONES S.A.

Ecuador 

LATINFARMACOS S.A.

Ecuador 

ESPIBENA S.A.

Ecuador 

Gloria Isabel

MORA ROMERO

Cedula 4-192-157;

alt. Cedula 4-194-157

Panama 

Carmen Rosa

MORALES ESPINAR

DNI No. 10006822

Peru 

Mario Jesus

CARRASCO URQUIZO

DNI No. 06266307

Peru 

Luis Fernando

CARDENAS GONGORA

CC 10105501 

Carlos Arturo

CARDONA ACEVEDO

CC 4383319 

OBURSATILES S.A. NIT# 800012425-0

INTERNACIONAL DE DIVISAS S.A. NIT # 805013989-5

and INTERNACIONAL DE DIVISAS S.A., LLC (USA) 

Guido

CAMPO RAMIREZ

CC 16218589

Miryam Yaneth

ROJAS GOMEZ

CC 23323121

Juan Guillermo

URIVE CADAVID

CC 16628855

Rene Alejandro

PEREZ RINCON

CC 16636377

Luis Hernando

GUERRERO BRAND

CC 16656929

Name in red text denotes

SDNT previously designated

Name in black text denotes

SDNT designated November 2004

All companies and individuals are

Colombian unless otherwise stated 

Sandra Patricia

BENAVIDES

MONTENEGRO

RUC# 0400778890

Ecuador 

Ecuadorian Companies 

PREMIER SALES S.A.

Panama 

FARFALLA

INVESTMENT S.A.

Panama City, Panama

RUC# 1986361395028 

Alberto

ROJAS VARGAS

CC 13922413 

Offshore Companies

GALAVIZ

CORPORATION, LTD.

Nassau, Bahamas 

INVERSIONES ARA LTDA.

NIT# 800084422-7 

Miguel & Gilberto

RODRIGUEZ

OREJUELA 

Jorge Armando

ARDILA HUYO

CC 16448389 

Maria Ximena

WILSON GARCIA

CC 31985001 

Isabel Fernanda

GARCIA VASQUEZ

CC 31983848 

Fernando

GRANDE BENAVIDES

CC 16675553 

William

RODRIGUEZ ABADIA

CC 16716259 

U.S.

Fugitive 

Arrested by Colombian

Authorities in January 2004:

Allegations of

Money Laundering

Officers and Shareholders

Officers and Shareholders 

Andres Felipe

ROA GUTIERREZ

CC 16752582

COLFARMA

PERU S.A.

Peru 

SDNT Principal

Individuals

Cali CartelFinancial NetworkNovember 2004 Specially DesignatedNarcotics Traffickers(SDNTs)

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

153 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

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March 17, 2005 

JS-2324 

Treasury Designation Targets North Valle Drug Cartel Leader 

In another step aimed at depriving Colombian narcotics traffickers of capital, the 

U.S. Department of the Treasury today added the name of North Valle drug cartel 

leader Carlos Alberto Renteria Mantilla ("Beto Renteria") to its list of Specially 

Designated Narcotics Traffickers (SDNTs), along with 11 front companies and 

individuals operating on his behalf. 

"Designating Beto Renteria as a leader of North Valle cartel is a fundamental step 

in our battle to undermine the financial network of this notorious Colombian drug 

cartel," said Robert Werner, Director of the Treasury's Office of Foreign Assets 

Control (OFAC). "The North Valle drug cartel depends on its financial network to 

stay in businesses, and actions like today's can deal a serious blow to those 

resources." 

Beto Renteria is a leading member of the North Valle drug cartel, and his 

involvement in narcotics trafficking has been documented back to the late 1970s. 

Beto Renteria is the subject of two federal criminal indictments in the United States. 

In 2004, the District Court for the District of Columbia charged Beto Renteria with 

violations of the Racketeer Influenced and Corrupt Organizations Act (RICO). Ten 

years prior, an indictment was filed in the Southern District of Florida charging Beto 

Renteria with conspiracy to import, possess and distribute cocaine in the United 

States. The United States is offering up to $5 million for information leading to his 

arrest. 

This action also targets a financial network of 11 front companies and individuals 

that act for or on behalf of Beto Renteria. The four Colombian businesses identified 

today are Dimabe Ltda., Inversiones Agroindustriales del Occidente Ltda., 

Compania Agropecuaria del Sur Ltda. and Colombo Andino Comercial Coalsa Ltda. All four businesses are located in Bogota, Colombia. The seven Colombian 

individuals designated today include Beto Renteria's wife, Maria Nury Caicedo 

Gallego, and their key financial front man, Mauricio Pardo Ojeda. 

Today's announcement is a result of OFAC's close working relationship with U.S. 

law enforcement authorities, and particularly in this case, the Drug Enforcement Administration (DEA). 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. Today's action freezes any assets found in the 

United States and prohibits all financial and commercial transactions between the 

designees and any U.S. person. 

The U.S. Government continues to work with and support the Colombian 

government in attacking the finances of Colombia's drug cartels. In February 2005, 

the Colombian government seized the airline Intercontinental de Aviacion, which 

had been designated by OFAC in October 2004 because it was owned and 

controlled by North Valle cartel leaders Gabriel Puerta Parra and Luis Hernandez 

Zea. 

154 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

The assets of a total of 1,159 business and individuals in Colombia, Costa Rica, 

Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the British 

Virgin Islands and the Cayman Islands are now blocked under E.O. 12978. The 428 

SDNT businesses include agricultural, aviation, consulting, construction, 

distribution, financial, investment, manufacturing, mining, offshore, pharmaceutical, 

real estate and service firms. The SDNT list includes 17 kingpins from the Cali, 

North Valle, and North Coast drug cartels in Colombia, including North Valle cartel 

leader Carlos Alberto Renteria Mantilla. 

A complete list of the entities identified today can be found at: 

http://www.treas.gov/offices/enforcement/ofac/actions/. 

REPORTS 

Renteria Chart 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

155 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS FRONT COMPANIES FAMILY and COMPANY SHAREHOLDERS

Carlos Alberto RENTERIA MANTILLA

a.k.a. Beto RENTERIA

a.k.a. Don Beto

C.C. 6494208

DOB 11 Mar 1945 

Beatriz RENTERIA CAICEDO

C.C. 52424737

DOB 30 Nov 1977 

Maria Nury CAICEDO GALLEGO

C.C. 31191388

DOB 16 Nov 1956 

Maria RENTERIA CAICEDO

C.C. 52410645

DOB 27 May 1981 

U.S. Federal Indictment

May 2004

Javier CAMACHO VALLEJO

C.C. 16614154

Mauricio PARDO OJEDA

C.C. 19445690

DOB 27 Jul 1961 

Luis Mario CEDENO HERRERA

C.C. 16637213 

Jairo Camilo COLLAZOS TELLO

C.C. 14998261

DOB 9 Dec 1953 

FRONTMEN 

Colombo Andina Comercial

Coalsa Ltda.

NIT 800084516-0 

Compania Agropecuaria del Sur Ltda.

Coagrosur Ltda.NIT 80107990-1 

Inversiones Agroindustriales

del Occidente Ltda.

a.k.a. Inagroccidente

NIT 800107993-1 

Dimabe Ltda.

NIT 800107988-4

U.S. Federal Indictment

July 1995

Narcotics Trafficking 

Department of the Treasury

Office of Foreign Assets Control 

l 

Racketeering Influenced and Corrupt Organizations (RICO)

North Valle Drug Carte

Financial Netw ork 

March 2005 

156 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

FROM THE OFFICE OF PUBLIC AFFAIRS 

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May 11, 2005 

JS-2440 

Treasury Designation Targets North Valle 

Cartel Associates, Businesses 

-Sixty-three Individuals, Entities Named 

Colombian Narcotics TraffickersThe U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added 32 companies and 31 individuals to its list of Specially Designated 

Narcotics Traffickers (SDNTs). The companies named form the Grajales business 

group, known in Colombia as Grupo Grajales. Also designated today was the head 

of Grupo Grajales, Raul Alberto Grajales Lemos. 

"Today's designation dealt another serious blow to the financial network of the 

North Valle cartel," said Robert Werner, Director of OFAC. "By breaking the 

financial backbone of groups like North Valle, we help thwart the ability of cartels to 

traffic lethal narcotics in the United States and abroad." 

"Actions like today's weaken the viability of rogue groups and reduce their ability to 

undermine the legitimate, democratic governments of countries in which they 

operate, like Colombia. The designation process is a truly important tool that 

furthers the national security and foreign policy interests of the Untied States by 

helping to promote stability abroad," Werner continued. 

Raul Grajales Lemos, the head of Grupo Grajales, is the subject of a cocaine 

trafficking indictment filed in the Southern District of Florida. In addition, he has 

been associated with various leaders of the North Valle drug cartel for many years, 

including SDNT principal individuals Ivan Urdinola Grajales (deceased 2002) and 

Carlos Alberto Renteria Mantilla (a.k.a. Beto Renteria). The North Valle drug cartel 

is the target of a Racketeer Influenced and Corrupt Organizations (RICO) Act 

indictment filed in the District of Columbia. 

Lorena Henao Montoya (SDNT since February 2000), the widow of confessed 

narcotics trafficker Ivan Urdinola Grajales, was captured in Panama in January 

2004. Documents seized from Lorena Henao Montoya's properties and associates 

demonstrate her financial links to principal Grupo Grajales companies, including 

Grajales S.A. (fruit cultivation), Casa Grajales S.A. (winery), Frexco S.A. (fruit 

processing and exports) and Hotel Los Vinedos (La Union, Valle, Colombia). Other 

documents seized in Panama exposed Lorena Henao Montoya's bribery of 

Colombian officials involved in asset forfeiture cases against her. She pleaded 

guilty to these charges and is now serving a prison sentence in Colombia. 

Beto Renteria, a fugitive who was named as a leader of the North Valle drug cartel 

in the RICO indictment, also has a financial interest in Grupo Grajales companies. 

Beto Renteria's key financial front man, Mauricio Pardo Ojeda (SDNT since March 

2005), is involved in the holding and management companies that operate Casa 

Estrella, a Colombian department store chain. In addition, the wife of Beto Renteria, 

Maria Nury Caicedo Gallego (SDNT since March 2005), is involved in Salome 

Grajales y Cia. Ltda., a company named after the sister of Raul Grajales Lemos. 

The Casa Estrella department store chain was once known as "Casa Grajales" and 

remains a part of Grupo Grajales. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

157 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. Today's action freezes any assets found in the 

United States and prohibits all financial and commercial transactions between the 

designees and any U.S. person. 

The assets of a total of 1,215 business and individuals in Aruba, Colombia, Costa 

Rica, Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the 

British Virgin Islands and the Cayman Islands are now blocked under E.O. 12978. 

The 460 SDNT businesses include agricultural, aviation, consulting, construction, 

distribution, financial, investment, manufacturing, mining, offshore, pharmaceutical, 

real estate and service firms. The SDNT list includes 18 kingpins from the Cali, 

North Valle and North Coast drug cartels in Colombia, including newly named North 

Valle cartel leader Raul Alberto Grajales Lemos. 

For more information on recent Treasury actions against the North Valle cartel, 

please visit the following links: 

Treasury Designation Targets North Valle Drug Cartel Leader 

http://www.treas.gov/press/releases/js2324.htm 

Treasury Designates North Valle Drug Cartel Traffickers 

http://www.treas.gov/press/releases/js2031.htm A complete list of the entities identified today can be found at: 

http://www.treas.gov/offices/enforcement/ofac/actions/. 

REPORTS 

A diagram of the individuals and businesses designated today 

158 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

Partners Partners 

Husband

President 

po 

j panies 

Grup j g panies 

La Union, Valle, Colombia

La Union, Valle, Colombia

La Union, Valle, Colombia

AGUILA LTDA.

La Union, Valle, Colombia La Union, Valle, Colombia

La Union, Valle, Colombia La Union, Valle, Colombia

MONICA LTDA.

La Union, Valle, Colombia

SOCIEDAD DE NEGOCIOS

La Union, Valle, Colombia

La Union, Valle, Colombia

GAD S.A.

La Union, Valle, ColombiaLa Union, Valle, Colombia

La Union, Valle, Colombia

Companies linked to

Beto RENTERIA 

p p j p Casa Estrella Manag p

ALMACAES S.A.

Casa Estrella Holding p

La Union, Valle, Colombia

La Union, Valle, Colombia

ARMAGEDON S.A.

La Union, Valle, Colombia

BLACKMORE

INVESTMENTS A.V.V.

SALIM S.A.

La Union, Valle, Colombia

SALOME GRAJALES Y CIA. LTDA. AGRONILO S.A.

panies

U.S. Department of the Treasury

Office of Foreign Assets Control 

Ivan

CC 94190353

(SDNT; Deceased 2002) 

Lorena

CC 31981533

( ) 

p

(SDNT) 

North Valle Cartel Financial Network April 2005 

EL EDEN S.A.

y y; 

Serving Prison for Drug g

Specially Designated Narcotics Traffickers (SDNTs) 

GRAJALES LEMOS

( ) 

Grupo Grajales 

Business Business

& Wife 

Additional Gru

Gra ales Com

o Gra ales Holdin Com

GRAJALES S.A.

NIT# 891900090-8 

FREXCO S.A.

NIT# 800183514-0 

HOTEL LOS VINEDOS

NIT# 800108902-6 

IBADAN LTDA. 

Tulua, Valle, Colombia

NIT# 800112215-1 

INVERSIONES

NIT# 891903843-0 

INVERSIONES 

GRAME LTDA.

NIT# 891903520-7 

INVERSIONES LOS 

POSSO LTDA. S.C.S.

NIT# 891903760-8 

INVERSIONES SANTA 

CECILIA S.C.S.

NIT# 891903795-5 

INVERSIONES SANTA 

NIT# 800042933-9 

PANAMERICANA LTDA. 

Cali, Colombia

NIT# 800091914-8 

SAN AGUSTIN LTDA.

NIT# 800042932-1 

INDUSTRIAS DEL 

ESPIRITU SANTO S.A. 

Malambo, Atlantico, Colombia 

NIT# 821002015-8 

INTERNATIONAL 

TRANSPORTES DEL

FREEZE DRIED S.A. 

Bogota, Colombia

NIT# 830132968-1 

ESPIRITU SANTO S.A.

NIT# 821002971-4 NIT# 821002436-5 

HEBRON S.A. 

Tulua, Valle, Colombia

NIT# 800107304-7 

CRETA S.A.

NIT# 800019962-6 

CASA GRAJALES S.A.

NIT# 891902138-1 

Princi al Gru o Gra ales Com anies ement Com anies 

G.L.G. S.A. 

Bogota, Colombia

NIT# 800023807-8 

Bogota, Colombia

NIT# 830086515-1 

C.A.D. S.A. 

Bogota, Colombia

NIT# 800173127-0 

RAMAL S.A. 

Bogota, Colombia

NIT# 800142109-5 

 Com anies 

MACEDONIA LTDA.NIT# 800121860-9 

AGUSTIN GRAJALES 

Y CIA. LTDA.

NIT# 800166941-0 

NIT# 800112221-4 

JOSAFAT S.A. 

Tulua, Valle, Colombia

NIT# 800112217-4 Oranjestad, Aruba 

C.R. No. 12128.0 

NIT# 821001412-4 

Bogota, Colombia

NIT# 800141337-3 

Toro, Valle, Colombia

NIT# 800099699-5 

Additional Com

URDINOLA GRAJALES HENAO MONTOYA

SDNT

Com anies linked to 

Lorena HENAO MONTOYA 

Carlos Alberto 

RENTERIA MANTILLA 

a.k.a. Beto RENTERIA 

CC 6494208 

ILOVIN S.A. 

Bogota, Colombia

NIT# 800141304-0 

INDUSTRIAS 

AGROPECUARIA

Panama 

Pleaded Guilt to Briber

Sentence in Colombia 

Indicted in U.S. 

 Traffickin

Raul Alberto

CC 6356044 

SDNT

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

159 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

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November 9, 2005 

JS-3012 

Treasury Designates Violent Colombian Drug Lord 

Action Additionally Targets Four Companies, Ten Associates of North Valle 

Cartel 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today named Colombian Wilber Varela, a.k.a. "Jabon," as a principal Specially 

Designated Narcotics Trafficker (SDNT) of the North Valle drug cartel. The 

Treasury also identified four companies and ten other North Valle associates, 

including rising North Valle cartel leaders Eduardo Restrepo Victoria, a.k.a. "El 

Socio" and Ramon Quintero Sanclemente. Today's action was taken pursuant to 

Executive Order 12978, which applies economic sanctions against Colombian drug 

cartels. 

"An assassin turned drug lord, Varela's trafficking and lethal exploits are fueled 

through the North Valle cartel's financial flows," said Robert Werner, OFAC 

Director. "This designation directly targets a financial nucleus of the notorious North 

Valle cartel." 

In May 2004, the District Court for the District of Colombia charged the leaders of 

the North Valle cartel, including Wilber Varela, with Racketeer Influenced and 

Corrupt Organizations Act (RICO) violations. The District Court for the Eastern 

District of New York separately indicted Varela on narcotics trafficking charges. 

Considered extremely dangerous, Varela is a former assassin who rose to become 

a North Valle cartel leader by killing competing rival cartel leaders. The United 

States is offering up to $5 million for information leading to his arrest. 

Ramon Quintero Sanclemente and Eduardo Restrepo Victoria are rising North Valle 

traffickers associated with Varela. In 1999, the Southern District of Florida indicted 

Ramon Quintero Sanclemente, a.k.a. Lucas, on narcotics trafficking and money 

trafficking charges. Restrepo Victoria is wanted by Colombian authorities on 

conspiracy and gunrunning charges. Also named today are four companies owned and controlled by Varela associates. 

They include a plastics company, an agricultural company and a professional 

services firm, all based in Colombia. A Guadalajara, Mexico travel agency is also 

named. 

Today's announcement is a result of the ongoing efforts between OFAC and U.S. 

law enforcement, particularly the Drug Enforcement Administration and the Federal 

Bureau of Investigation. 

Today's action freezes any assets the designees may have located in the United 

States and prohibits all financial and commercial transactions between the 

designees and any U.S. person. 

1,230 companies and individuals in Aruba, Colombia, Costa Rica, Ecuador, Mexico, 

Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the British Virgin Islands, 

and the Cayman Islands, have been designated pursuant to E.O. 12978. The 464 

SDNT businesses include agricultural, aviation, consulting, construction, 

distribution, financial, investment, manufacturing, mining, offshore, pharmaceutical, 

real estate, service and travel firms. The SDNT list includes 19 drug kingpins from 

160 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

the Cali, North Valle, and North Coast drug cartels in Colombia, including newly 

named North Valle cartel leader Wilber Varela. 

For a complete list of individuals and entities designated today, please visit: 

http://www.treasury.gov/offices/enforcement/ofac/actions/20051109.shtml. 

REPORTS 

Varela Drug Trafficking Organization North Valle Drug Cartel November 

2005 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

161 
TABLE OF CONTENTS APPENDIX

APPENDIX B 

162 

RR TOUR S.A. DE C.V.

MEXICO

Maria Teresa

RESTREPO VICTORIA

c.c. 41477630 

AGROPECUARIA

PALMA DEL RIO S.A.

Ibague, Colombia

NIT # 830061299-7 

Julio Cesar

LOPEZ PENA

DOB 25 June 1961

c.c. 16655942 

Eduardo

RESTREPO VICTORIA 

DOB 28 Sep 1958

c.c. 12187343 

Roberto LONDONO VELEZ

DOB 17 Dec 1958

c.c. 7527342 

RESTREPO VICTORIA

DOB 5 Jan 1968

c.c. 55060642 

Yolanda SALAZAR ARCILA 

c.c. 25018274 

Luis Enrique

CALLE SERNA 

DOB 16 Aug 1976

c.c. 94487319 

Jose Ignacio

BEDOYA VELEZ

DOB 6 Jan 1959

c.c. 16351225 

A

DOB 6 November 1954

c.c. 16545384

ASSOCIATES 

Ramon 

Q

DOB 30 Nov 1960

c.c. 14881147 

Jaime Alberto MARIN ZAMORA 

DOB 22 JUL 1964

c.c. 7544228 

RICO

May 2004 

PLASTEC LTDA.

Armenia, Colombia

NIT # 801000358-7 

VARELA Drug Trafficking Organization 

North Valle Drug Cartel

November 2005

Narcotics Trafficking 

May 2004 

Department of the Treasury 

Office of Foreign Assets Control 

NIT # 801000611-6 

DESIGNATION ANNOUNCEMENTS AND CHARTS 

IMPACT REPORT 

Guadalajara

DOB 4 Dec 1949

Norma Constanza

Wilber VAREL

UINTERO SANCLEMENTE

U.S. Federal Indictment U.S. Federal Indictment 

ASES O RIAS 

PROFESIONALES LTDA.

Armenia, Colombia
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

To view or print the PDF con tent on this page, downloadthefree Adobe® Acrobat® R eader® . 

November 30, 2005 

JS-3028 

Treasury Names Front Companies, Sham 

Operatives Helping To Bankroll NarcoTrafficking in Colombia 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added two individuals and three companies tied to the North Valle drug cartel 

to its list of Specially Designated Narcotics Traffickers (SDNTs). The two 

individuals, both Colombian, act as front persons for North Valle leaders Raul 

Grajales Lemos and Carlos Alberto Renteria Mantilla (a.k.a. Beto Renteria). Both 

Raul Grajales Lemos and Beto Renteria have been indicted in the United States on 

charges relating to narcotics trafficking. 

"The North Valle cartel has used these straw men and front companies in attempts 

to operate under a cloak of legitimacy," said Robert Werner, Director of OFAC. 

"Designating the North Valle's financial network severely restricts the cartel's efforts 

to launder drug proceeds." 

The two individuals, Armando Jacobo Jaar Jacir and Maria Sair Pelissier Ospina, 

represent the interests of Raul Grajales Lemos and Beto Renteria in the operation 

of Casa Estrella, a department store chain located in Colombia that was previously 

named a SDNT. This activity is carried out in attempts to hide the North Valle's 

control of the chain. Armando Jacobo Jaar Jacir has been a business associate of 

Raul Grajales Lemos and Beto Renteria for over a decade and participates in 

multiple companies controlled by them, in addition to Casa Estrella . Maria Sair 

Pelissier Ospina has also been a business associate of Raul Grajales Lemos for 

over a decade and participates in multiple companies controlled by Raul Grajales 

Lemos and Beto Renteria, including Casa Estrella . Also named as SDNTs today were two companies controlled by Armando Jacobo 

Jaar Jacir, Armando Jaar y Cia. S.C.S. in Colombia and Jacaria Florida, Inc. in the 

United States. In addition, Comercializadora Pelissier Ospina Ltda . in Colombia, a 

company controlled by Maria Sair Pelissier Ospina, was also named. 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. Today's action freezes any assets the designees 

may have located under U.S. jurisdiction and prohibits all financial and commercial 

transactions between the designees and any U.S. person. 

The assets of a total of 1,235 business and individuals in Aruba, Colombia, Costa 

Rica, Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the 

British Virgin Islands, the Cayman Islands and the United States have been 

designated pursuant E.O. 12978. The 467 SDNT businesses include agricultural, 

aviation, consulting, construction, distribution, financial, investment, manufacturing, 

mining, offshore, pharmaceutical, real estate and service firms. The SDNT list 

includes 19 kingpins from the Cali, North Valle and North Coast drug cartels in 

Colombia. 

REPORTS 

A diagram of the individuals and businesses designated 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

163 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

p

gement

Partners 

GAD S.A. ARMAGEDON S.A.

R 

SDNT Principal Individuals 

Bogota, Colombia

Associated Company 

Casa Estrella Operating / Real Estate Companies

ALMACAES S.A.

( ) 

Armando Jacobo JAAR JACIR**

CC 7432263 ( ) 

JACARIA FLORIDA, INC.**

Miami, Florida, United States

Associated Company

Cali, Barranquilla, & Bogota

Department Store

Locations 

Panamanian

Suppliers 

GRAJALES / RENTERIA Associates

( ) 

-Fug

Raul Alberto GRAJALES LEMOS

-Cap y

BLACKMORE SALIM S.A.

North Valle CartelFinancial Network 

November 2005 

U.S. Department of the Treasury

Office of Foreign Assets Control

Narcotics Traffickers

Ownershi /Control 

Shareholders 

Mana

Casa Estrella Holding Companies

La Union, Valle, Colombia

NIT# 821002971-4 

JOSAFAT S.A. 

Tulua, Valle, Colombia

NIT# 800112217-4 

MACEDONIA LTDA. 

La Union, Valle, Colombia

NIT# 800121860-9 

HEBRON S.A. 

Tulua, Valle, Colombia

NIT# 800107304-7 

CRETA S.A. 

La Union, Valle, Colombia

NIT# 800019962-6 

AGUSTIN GRAJALES 

Y CIA. LTDA. 

La Union, Valle, Colombia 

NIT# 800166941-0 

La Union, Valle, Colombia 

NIT# 800112221-4 

ARMANDO JAA

Y CIA. S.C.S.** 

Barranquilla, Colombia 

NIT# 890114337-6 

COMERCIALIZADORA PELISSIER OSPINA LTDA.** 

NIT# 830009052-5 

Bogota, Colombia

NIT# 830086515-1 

ILOVIN S.A. 

Bogota, Colombia

NIT# 800141304-0 

C.A.D. S.A. 

Bogota, Colombia

NIT# 800173127-0 

G.L.G. S.A. 

Bogota, Colombia

NIT# 800023807-8 

RAMAL S.A. 

Bogota, Colombia

NIT# 800142109-5 

Maria Sair PELISSIER OSPINA**

CC 51561790 Colombia Colombia US FEIN 592804133 

Carlos Alberto RENTERIA MANTILLA

"Beto RENTERIA"

CC 6494208 (Colombia) 

itiveCC 6356044 (Colombia) tured Ma 2005-

INVESTMENTS A.V.V. 

Oranjestad, Aruba

C.R. No. 12128.0 

La Union, Valle, Colombia 

NIT# 821001412-4 

Specially Designated

** New SDNTs 

164 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®. 

June 13, 2006 

JS-4318 

Treasury Identifies International Financial Network of 

Colombia’s Notorious North Valle Drug Cartel 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added five individuals and twenty companies tied to Colombia's North Valle 

drug cartel to its list of Specially Designated Narcotics Traffickers (SDNTs). The 

five individuals act as front persons for North Valle cartel leaders Raul Alberto 

Grajales Lemos (Raul Grajales) and Carlos Alberto Renteria Mantilla (Beto 

Renteria). Both Raul Grajales and Beto Renteria have been indicted in the U.S. on 

charges relating to narcotics trafficking. 

"Today's action exposes a key financial network of the North Valle cartel," said 

Barbara Hammerle, Acting Director of OFAC. "This network utilizes front companies 

in Colombia, the United States, Panama, and the British Virgin Islands to move its 

illicit proceeds. By exposing the financial backbone of Colombian drug cartels 

through our designation process, we thwart their ability to launder illicit proceeds." 

The four newly named Colombian individuals, Francisco Javier Duque Correa, 

Ricardo Jaar Jacir, Moises Abdal Saieh Muvdi, and Carlos Ernesto Saieh Jamis, 

represent the interests of Raul Grajales and Beto Renteria in the operation of Casa 

Estrella and associated companies. Casa Estrella is a department store chain 

located in Colombia that was previously named as an SDNT by OFAC in May 2005. 

This activity is carried out in attempts to hide the North Valle cartel's control of the 

department store chain. 

Francisco Javier Duque Correa is the general manager of Casa Estrella and has 

been an associate of Raul Grajales for the past 16 years. Ricardo Jaar Jacir, a 

share holder in Casa Estrella, is the half brother of Armando Jaar Jacir, a key front 

person for Raul Grajales and Beto Renteria who was previously designated by 

OFAC in November 2005. Moises Abdal Saieh Muvdi and Carlos Ernesto Saieh 

Jamis have been business associates of Raul Grajales and Beto Renteria for the 

past 15 years and are also shareholders in Casa Estrella. 

The fifth individual designated today, Salvadoran national Carmen Elena Siman De 

Jaar, was named for her involvement in the SDNT entity, Armando Jaar y Cia. 

S.C.S., as well as her involvement in Cipe Investments Corporation, a Panamanian 

shell company. Carmen Elena Siman is the wife of Armando Jaar Jacir. Also named today are 20 companies which comprise an international financial 

network for Colombia's North Valle cartel. These companies are located in 

Colombia (8), Panama (5), the British Virgin Islands (1) and the United States (6). 

The 20 companies encompass a wide range of services including real estate, 

investment, construction, property management and manufacturing. The U.S. and 

Panamanian companies are owned or controlled by Moises Abdal Saieh Muvdi and 

Carlos Ernesto Saieh Jamis. These entities are shell companies used to facilitate 

financial transactions. Gimber Investing Corporation is located in the British Virgin 

Islands and is the majority shareholder of Confecciones Lord S.A., a Colombian 

company also named today, which is affiliated with Casa Estrella. 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. Today's action freezes any assets found in the 

United States and prohibits all financial and commercial transactions between the 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

165 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

designees and any U.S. person. 

The assets of a total of 1,260 business and individuals in Aruba, Colombia, Costa 

Rica, Ecuador, Mexico, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, 

the British Virgin Islands, the Cayman Islands, and the United States have been 

designated by OFAC pursuant E.O. 12978. The 487 SDNT businesses include 

agricultural, aviation, consulting, construction, distribution, financial, horse breeding, 

investment, manufacturing, maritime, mining, offshore, industrial paper, 

pharmaceutical, real estate and service firms. The SDNT list includes 19 kingpins 

from the Cali, North Valle and North Coast drug cartels in Colombia. 

For a complete list of the individuals and entities designated today, please visit: 

http://www.treasury.gov/offices/enforcement/ofac/actions/index.shtml 

REPORTS z North Valle Cartel Financial Network 

166 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS g Sp

North Valle CartelFinancial Network 

( ) 

( ) 

( ) 

-Cap y

Colombian Department Store Chain ( ) Q p

( )

Office of Foreign Assets Control 

q Barranq

Barranq q

Barranq

p

Barranq

Specially Designated

g

on November 30, 2005

y

yy

yy

Barranq

Barran

q

q g

R 

( ) 

( ) 

( ) ( ) 

p

( ) 

Partners 

Shareholders Mana ement 

ouse 

June 2006 

SDNT Principal Individuals 

Carlos Alberto RENTERIA MANTILLA 

"Beto RENTERIA"

CC 6494208 Colombia

-FugitiveRaul Alberto GRAJALES LEMOS CC 6356044 Colombia tured Ma 2005-

CASA ESTRELLA

GRAJALES / RENTERIA Associates 

Maria Sair PELISSIER OSPINA** 

CC 51561790 Colombia

Francisco Javier DU UE CORREA 

DOB 4 A r 1948 

CC 8292581 Colombia

U.S. Department of the Treasury

Barranquilla, Colombia 

FINANZAS DEL NORTE LUIS SAIEH Y CIA. S.C.A. 

Barran uilla, Colombia 

NIT 890108715-2 

CARLOS SAIEH Y CIA. S.C.S. 

uilla, Colombia 

NIT 800180437-8 

RICARDO JAAR Y CIA. S.C.A. 

uilla, Colombia 

NIT 890114336-9 

MOISES SAIEH Y CIA. S.C.A. 

Barran uilla, Colombia 

NIT 890114338-3

ARMANDO JAAR Y CIA. S.C.S.** 

uilla, Colombia 

NIT 890114337-6 

ALM INVESTMENT FLORIDA, INC. 

Miami, FL United States 

US FEIN 65-0336852 

SUNSET & 97TH HOLDINGS, LLC. 

Miami, FL United States 

US FEIN 260064717 

MARC LLC 

Miami, FL United States 

GRANADA ASSOCIATES, INC. 

Miami, FL United States 

US FEIN 65-0336843 

KAREN OVERSEAS FLORIDA, INC. 

Miami, FL United States 

US FEIN 592827636 

VILLAROSA INVESTMENTS FLORIDA, INC. 

Miami, FL United States 

US FEIN 650439600 

Miami, Florida 

U.S. Pro erties 

and Accounts 

British Virgin Islands 

INVERSIONES DEL PRADO ABDALA SAIEH Y CIA. S.C.A. 

uilla, Colombia 

NIT 890108452-0 

Narcotics Traffickers 

**SDNTs Desi nated 

Panama 

CIPE INVESTMENTS CORPORATION 

Panama Cit , Panama 

RUC 2209651197910 

RIXFORD INVESTMENT CORPORATION 

Panama Cit , Panama 

RUC 1963801394709 

KATTUS II CORPORATION 

Panama Cit , Panama 

RUC 1724681390286 

KAREN OVERSEAS, INC. 

Panama Cit , Panama 

RUC 2172211194799 

ELIZABETH OVERSEAS, INC. 

Panama Cit , Panama 

RUC 2172202194798 

CONFECCIONES LORD S.A. 

uilla, Colombia 

NIT 890101890-1 

URBANIZADORA ALTAVISTA INTERNACIONAL S.A. 

uilla, Colombia 

NIT 802014697-3 

CONSTRUCTORA ALTAVISTA INTERNACIONAL S.A. 

Barran uilla, Colombia 

NIT 802019866-4 

GIMBER INVESTING CORPORATION 

British Vir in Islands 

Carmen Elena SIMAN DE JAA

DOB 01 Nov 1953 

CC 1629942 El Salvador

Armando Jacobo JAAR JACIR** 

CC 7432263 Colombia

Carlos Ernesto SAIEH JAMIS 

DOB 24 Feb 1964 

CC 8739066 Colombia

Moises Abdal SAIEH MUVDI 

DOB 6 Jun 1945 

CC 7427466 Colombia

Ricardo JAAR JASSIR 

DOB 29 Se 1940 

CC 3714973 Colombia

GRAJALES / RENTERIA Associates 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

167 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

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August 29, 2006 

HP-74 

Treasury Designation Targets Elusive North Valle Cartel Leader 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added to its list of Specially Designated Narcotics Traffickers four individuals 

and two companies tied to Juan Carlos Ramirez Abadia, a leader of Colombia's 

North Valle drug cartel. 

"Juan Carlos Ramirez Abadia has been one of the most powerful and most elusive 

drug traffickers in Colombia," said Adam J. Szubin, Director of OFAC. "Today we 

are exposing and taking action against elements of his financial network for the first 

time, including seemingly legitimate companies built upon narcotics proceeds." 

The four individuals act as front persons for North Valle cartel leader Juan Carlos 

Ramirez Abadia (a.k.a. Chupeta or "Lollipop"), who was named a Specially 

Designated Narcotics Trafficker (SDNT) by OFAC in August 2000. These front 

individuals operate a Colombian pharmaceutical distribution company, Disdrogas 

Ltda., on behalf of Juan Carlos Ramirez Abadia. Also designated today was a 

Colombian holding company named Ramirez Abadia y Cia. S.C.S. 

Juan Carlos Ramirez Abadia began his illicit career in narcotics trafficking with 

Colombia's Cali drug cartel. He was indicted on federal drug trafficking charges in 

Colorado in 1994 and the Eastern District of New York in 1995. Juan Carlos 

Ramirez Abadia surrendered to Colombian authorities in 1996. Following his 

release from a Colombian prison in 2002, Ramirez Abadia continued his trafficking 

activities and closely allied himself with the North Valle drug cartel. In 2004, the 

District Court for the District of Columbia indicted the North Valle drug cartel under 

the Racketeer Influenced and Corrupt Organizations Act (RICO) and named Juan 

Carlos Ramirez Abadia as one of its leaders. 

Ramirez Abadia founded the holding company Ramirez y Cia. Ltda. in the late 

1980s, early in his narcotics trafficking career. Ramirez Abadia eventually changed 

the name of the company to Disdrogas Ltda. and placed the official ownership and 

management in the hands of persons he could trust to protect his asset. These 

trusted persons included his parents, Omar Ramirez Ponce and Carmen Alicia Abadia Bastidas, and his business associates Jorge Rodrigo Salinas Cuevas and 

Edgar Marino Otalora Restrepo, all of whom were named today by OFAC. In 

addition, OFAC has designated the Colombian holding company Ramirez Abadia y 

Cia. S.C.S., which was created to hold real estate and other assets for Ramirez Abadia. 

SDNTs are subject to the economic sanctions imposed against Colombian drug 

cartels in Executive Order 12978. Today's action freezes any assets found in the 

United States and prohibits all financial and commercial transactions by U.S. 

persons involving the designees. 

The assets of a total of 1,294 businesses and individuals in Aruba, Colombia, Costa 

Rica, Ecuador, Mexico, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, 

the British Virgin Islands, the Cayman Islands, and the United States have been 

designated by OFAC pursuant E.O. 12978. The 489 currently designated 

businesses include agricultural, aviation, consulting, construction, distribution, 

financial, horse breeding, hotels, investment, manufacturing, maritime, mining, 

offshore, industrial paper, pharmaceutical, real estate and service firms. The SDNT 

168 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

list includes 19 kingpins from the Cali, North Valle and North Coast drug cartels in 

Colombia. 

REPORTS 

z North Valle Cartel’s Financial Network. 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

169 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS Shareholders Manager Manager 

North Valle CartelFinancial Network 

Edg

( ) 

Jorg go 

( ) 

Sp y DesignatedNarcotics Traffickers 

ipal Individual 

( ) 

A 

(Col ia) 

( peta") 

- Fug

p y p

DISDROGAS LTDA.

(Colombia) 

i li

(Colombia) 

Omar RAMIREZ PONCE

( ) (Col ia) 

i g: 

i ( ) and 

( ) 

g Cartel: 

gton, DC ( ) 

Parents / Business Partners 

U.S. Department of the Treasury

Office of Foreign Assets Control 

ar Marino 

OTALORA RESTREPO

CC 5198602 Colombia

e Rodri

SALINAS CUEVAS 

CC 14930332 Colombia

eciall

SDNT Princ

Since 2000

Juan Carlos RAMIREZ ABADI

CC 16684736 omb

aka "Chu

itive -

Com anies Founded and Controlled b "Chu eta" 

NIT # 800058576-2 

Locat ons in Ca , Neiva, & Pasto RAMIREZ ABADIA Y CIA. S.C.S. 

NIT # 800117676-4 

CC 6064636 Colombia

Carmen Alicia ABADIA BASTIDAS

CC 29021074 omb

Ind cted in the U.S. for Narcotics Traffickin

Federal D stricts of Colorado 1994

the Eastern District of New York 1995

Named as a Leader of 

the North Valle Dru

RICO Indictment in Washin 2004

August 2006 

170 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

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October 25, 2006 

HP-151 

Treasury Targets North Valle Cartel’s Next 

Generation of Leaders 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added two North Valle drug cartel leaders to its list of Specially Designated 

Narcotics Traffickers (SDNTs): Jhonny Cano Correa and Orlando Sabogal Zuluaga. 

OFAC also designated six entities and 16 individuals that have been controlled by 

or worked on behalf of the two North Valle cartel leaders. The designated 

individuals include rising North Valle drug trafficker Carlos Arturo Patiño Restrepo 

(a.k.a. "Patemuro"). 

"Treasury continues its relentless pursuit of the finances of Colombian drug 

traffickers. With the naming of Jhonny Cano Correa and Orlando Sabogal Zuluaga 

as principal narcotics traffickers, we have struck yet another blow against the North 

Valle drug cartel." said Adam Szubin, Director of OFAC. 

Jhonny Cano Correa and Orlando Sabogal Zuluaga were indicted on drug 

trafficking and money laundering charges in the District Court for the Eastern 

District of New York in July 2003. Until 2004, Jhonny Cano Correa and Orlando 

Sabogal Zuluaga served as key lieutenants in the Luis Hernando Gomez 

Bustamante drug trafficking organization. Gomez Bustamante was a top leader of 

the North Valle drug cartel until his 2004 arrest while attempting to enter Cuba on a 

false passport. After Gomez Bustamante's arrest, Jhonny Cano Correa and 

Orlando Sabogal Zuluaga rose in the cartel to become leaders of their own drug 

trafficking organizations. 

Jhonny Cano Correa is a violent drug trafficker, allegedly responsible for multiple 

murders. Colombian authorities arrested Jhonny Cano Correa in October 2005 and 

extradited him to the United States on September 22, 2006. Also designated is 

Jhonny Cano's principal holding company, Cano Agudelo S en C. 

Orlando Sabogal Zuluaga remains a fugitive from justice, with the U.S. State 

Department offering up to $5 million for information leading to his arrest. Today's 

action freezes the assets of Orlando Sabogal, several key family members, and 

their principal holding company, Orlando Sabogal e Hijos & Cia S en C in Colombia. 

OFAC has also designated Carlos Arturo Patiño Restrepo ("Patemuro"), a rising 

North Valle cartel trafficker, who has been tied to SDNT principal individuals Luis 

Hernando Gomez Bustamante as well as Wilber Varela, one of Colombia's most 

wanted drug traffickers. Two Patiño Restrepo companies, located in Pereira, 

Colombia -- Comercializadora de Café del Occidente Codecafe Ltda. and 

Inversiones Macarnic Patino y Cia S.C.S. -- were also named today. Patiño 

Restrepo's designation makes clear that OFAC is targeting the next generation of 

Colombian drug traffickers. 

Today's actions benefited greatly from the assistance of the U.S. Attorney's Office 

for the Eastern District of New York and the El Dorado Task Force, a DHS/ICE 

money laundering task force in New York. OFAC would particularly like to thank Assistant U.S. Attorney Bonnie Klapper for her invaluable support in this case. 

This action is part of an ongoing interagency effort to implement Executive Order 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

171 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

12978, signed on October 21, 1995, which applies economic sanctions against 

Colombia's drug cartels. This effort includes the Departments of Treasury, Justice, 

State, and Homeland Security. Today's action freezes any assets found in the 

United States or in possession or control of U.S. persons and prohibits all financial 

and commercial transactions between the designees and any U.S. person. 

The assets of a total of 1,283 business and individuals in Aruba, Colombia, Costa 

Rica, Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the 

British Virgin Islands, the Cayman Islands and the United States have been 

designated pursuant E.O. 12978. The 494 SDNT businesses include agricultural, 

aviation, consulting, construction, distribution, financial, investment, manufacturing, 

mining, offshore, pharmaceutical, real estate and service firms. The SDNT list now 

includes 21 principal narcotics traffickers from the Cali, North Valle and North Coast 

drug cartels in Colombia. 

REPORTS z chart of today

’s designation. 

172 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS p i Felipe l Juli lle Al

( ying informat olombian 

unles therw ted.) 

i l

j

l

i l

l

l

p

Wil

l Si

l 

g lle 

l

p l

lle 

l

Jai

Other front ersons 

Dan ela 

SABOGAL ZULUAGA 

c.c. TI-89071954430 

c.c. 22012785 (Venezuela) 

SABOGAL ZULUAGA 

c.c. TI-92013100049 

c.c. 22012787 (Venezue a) 

ana 

SABOGAL ZULUAGA 

c.c. TI-870328535419 

c.c. 22012784 (Venezuela) 

U.S. Federal Indictment 

Eastern District of New York 

Narcotics trafficking & 

Money laundering 

ORLANDO SABOGAL E HIJOS & CIA S EN C 

NIT # 800181393-7 

Ansermanuevo, Va

CANO AGUDELO S EN C 

cala, Valle 

NIT # 821002095-7 

Diana Patricia 

ZULUAGA ALZATE 

c.c. 252465323 

North Valle Drug Cartel 

October 2006 

All identif ion is C

s o ise no

Department of the Treasury 

Office of Foreign Assets Control 

Extradited 

September 23, 2006 

Jhon E de ber CANO CORREA 

DOB 13 Dec 1963 

c.c. 16217170 

a.k.a. Jhonny CANO 

a.k.a. Ale andro CARDONA RIBILLAS 

Named SDNT Principal 

October 2002 

Arrested in Cuba 

2004 

Orlando SABOGAL ZULUAGA 

a.k.a. Carlos Alberto GUILLEN JIMENEZ 

a.k.a. Juan Pab o CONTRERAS VIVAS 

DOB 22 Feb 1966 

c.c. 18505378 

U.S. Fugitive 

Luis Hernando GOMEZ BUSTAMANTE

"Rasguno" 

COMERCIALIZADORA DE CAFE 

DEL OCCIDENTE CODECAFE LTDA. 

NIT # 816004106-0 

Pere ra, Risara da 

Sandra Mi ena 

HERNANDEZ ARBOLEDA 

c.c. 42109136 

INVERSIONES MACARNIC 

PATINO Y CIA S.C.S. 

NIT # 816005011-4 

Pereira, Risara da 

Carlos Arturo 

PATINO RESTREPO 

DOB 27 A r 1964 

c.c. 9991679 

mer de Jesus 

GOMEZ BUSTAMANTE 

DOB 26 Jan 1970 

c.c. 16223940 

Carlos Umberto 

RESTREPO CLAVIJO 

c.c. 16206322 

Luis Alfonso 

GOMEZ BUSTAMANTE 

DOB 1 Nov 1953 

c.c. 4451571 

GAVIOTAS LTDA. 

a.k.a. Motel Campo Amor 

a.k.a. Hote n Pecados 

ak.a. Hote Sin PK2 

Carta o, Va

NIT # 800032092-7 

Juan Carlos 

PATINO TORRES 

DOB 26 Jun 1971 

c.c. 10141042 

Juan de a Cruz 

GALLEGO CANO 

DOB 26 Feb 1956 

c.c. 6272570 

Yolando Sofia 

CANO ALZATE 

DOB 25 A r 1957 

c.c. 31399608 

Davinson GOMEZ OCAMPO 

DOB 10 Ju 1960 

c.c. 2470433 

GOMEZ MARIN LTDA. 

NIT # 800102465-1 

Cartago, Va

Jose Aldemar RENDON RAMIREZ 

DOB 24 Ju 1950 

c.c. 16202349 

Juan Carlos 

GIRALDO FRANCO 

DOB 10 Jun 1971 

c.c. 16791184 

me ROJAS FRANCO 

c.c. 16210083 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

173 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

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October 31, 2006 

HP-148 

Treasury Acts Against Narco Leader’s Front Companies, Cohorts 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today designated seven individuals and ten entities associated with North Valle 

drug cartel leader Carlos Alberto Renteria Mantilla (Beto Renteria). Today's 

designation is the fifth designation targeting Beto Renteria's financial network. 

"Beto Renteria is one of Colombia's most powerful and sophisticated narcotics 

traffickers, investing his illicit proceeds across businesses in Colombia and offshore 

locations," said Adam Szubin, Director of the Office of Foreign Assets Control. 

"Today we have again taken aim at Beto Renteria's organization, exposing his web 

of front companies and targeting their assets." 

Today's action targets a financial network of ten front companies and seven 

individuals that act for or on behalf of Renteria. The ten Colombian businesses 

identified today are four sugar companies: Agropecuaria Lindaraja S.A., Canaduz 

S.A., Inversiones Brasilar S.A. and Tarritos S.A.; the soccer team Cortulua; the 

accounting firm Camacho Vallejo Asesores; the beach-front hotel Tres Casitas; and 

two medical clinics, Apoyos Diagnosticos S.A. and Clinica San Francisco S.A. All 

but one of the businesses is located in Colombia; the other, Kutry Management, is 

located in Panama. OFAC previously identified Renteria's business interests in the 

department store chain Casa Estrella and numerous Grupo Grajales companies. 

The seven Colombian individuals designated today are front persons working on 

behalf of Beto Renteria in the named companies, including key front persons James 

Osorio Valencia and Ricardo Sandoval Salazar. 

OFAC named Beto Renteria as a principal Specially Designated Narcotics 

Trafficker (SDNT) in March 2005, and the U.S. State Department is offering up to 

$5 million for information leading to Beto Renteria's capture. In May 2004, the U.S. Attorney's Office for the District of Columbia identified Beto Renteria as one of the 

leaders of the North Valle drug cartel and charged the cartel with violations of the 

Racketeer Influenced and Corrupt Organizations Act (RICO). 

This action is part of an ongoing interagency effort to implement Executive Order 

12978, signed on October 21, 1995, which applies economic sanctions against 

Colombia's drug cartels. This effort includes the Departments of the Treasury, 

Justice, State and Homeland Security. Today's action freezes any assets found in 

the United States and prohibits all financial and commercial transactions by any 

U.S. person with the designees. 

OFAC has designated a total of 1300 businesses and individuals in Aruba, 

Colombia, Costa Rica, Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the 

Bahamas, the British Virgin Islands, the Cayman Islands and the United States 

pursuant E.O. 12978. The 504 SDNT businesses include agricultural, aviation, 

consulting, construction, distribution, financial, investment, manufacturing, mining, 

offshore, pharmaceutical, real estate and service firms. The SDNT list includes 21 

kingpins from the Cali, North Valle and North Coast drug cartels in Colombia. 

REPORTS 

z View the Designation Chart 

174 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

R 

i

ing Infl p gani ( ) 

g

Cali 

ll l i

l

g

Cali 

Cali Cali 

i

i

l i

Medical 

Agro-industrial

 Related companies 

Ricardo SANDOVAL SALAZA

C.C. 16693550 

Carlos Alberto RENTERIA MANTILLA 

"Beto RENTERIA" 

DOB 11 MAR 1945 

C.C. 6494208 

U.S. Federal Indictment 

July 1995 

Narcotics Trafficking 

U.S. Federal Ind ctment 

May 2004 

Racketeer uenced and Corru t Or zations RICO

James Au usto OSORIO VALENCIA 

DOB 16 Nov 1958 

C.C. 19365692 

TARRITOS S.A. 

NIT # 805028114-3 

INVERSIONES BRASILAR S.A. 

Bogota 

NIT # 891305286-2 

Beto RENTERIA Drug Trafficking Organization 

North Va e Drug Carte

October 2006 

U.S. Department of the Treasury 

Office of Fore gn Assets Control 

Jose Manue TRONCOSO POSSE 

DOB 26 Nov 1953 

C.C. 19233258 

Oscar I nacio MARTAN RODRIGUEZ 

DOB 8 Feb 1958 

C.C. 19365692 

AGROPECUARIA LINDARAJA S.A. 

NIT # 890327360-0 

Andres Fernando QUINTANA FUERTES 

DOB 3 Jul 1966 

C.C. 16989000 

German DUQUE JARAMILLO 

DOB 20 Apr 1951 

C.C. 14972079 

CLINICA SAN FRANCISCO S.A. 

Tulua, Valle 

NIT # 800191916-1 

APOYOS DIAGNOSTICOS S.A.. 

Tulua 

NIT # 800118755-2 

Alfonso BUENO GUERRERO 

DOB 19 Sep 1941 

C.C. 17056503 

CORPORACION CLUB DEPORTIVO TULUA 

"CORTULUA" 

Tulua, Valle 

NIT # 800097185-2 

CAMACHO VALLEJO ASESORES E.U. 

NIT # 805031109-7 

KUTRY MANAGEMENT Panama City, PANAMA 

RUC # 34407212255995 

CANADUZ S.A. 

NIT # 805024035-1 

COPORACION HOTELERA DEL 

CARIBE LTDA. 

San Andres, Prov dencia 

NIT # 800104679-1 

KEY FRONT MEN 

Maur cio PARDO OJEDA 

DOB 27 Jul 1961 

C.C. 19445690 

Previous y des gnated SDNT March 2005 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

175 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

United States Attorney 

Southern District of New York 

FOR IMMEDIATE RELEASE CONTACT: U.S. ATTORNEY'S OFFICE 

NOVEMBER 16, 2006 SOUTHERN DISTRICT OF NEW YORK

 LAUREN McDONOUGH, YUSILL SCRIBNER

 PUBLIC INFORMATION OFFICE

 (212) 637-2600

 U.S. ATTORNEY'S OFFICE

 SOUTHERN DISTRICT OF FLORIDA

 ALICIA VALLE

 SPECIAL COUNSEL TO THE U.S. ATTORNEY

 (305) 961-9153


CALI CARTEL LEADERS PLEAD GUILTY TO LAUNDERING


COCAINE PROCEEDS THROUGH PHARMACEUTICAL DRUG COMPANIES


MICHAEL J. GARCIA, the United States Attorney for the


Southern District of New York, and R. ALEXANDER ACOSTA, the


United States Attorney for the Southern District of Florida,


announced today the guilty pleas of GILBERTO RODRIGUEZ-OREJUELA


and MIGUEL ANGEL RODRIGUEZ-OREJUELA, brothers and the leaders of


the notorious Cali Cartel in Colombia, to money-laundering


charges. Under the terms of a plea agreement with the United


States Government, the RODRIGUEZ-OREJUELA brothers previously


pleaded guilty to an Indictment filed in the Southern District of


Florida (the "SDFL Indictment") charging them with importing tons


of cocaine into the United States. The agreement also called for


the brothers to plead guilty to an Indictment initially filed in


the Southern District of New York (the "SDNY Indictment")


charging them with money-laundering crimes. The guilty pleas to


the SDNY Indictment were entered today before Judge FEDERICO A.


MORENO of the United States District Court for the Southern


District of Florida.


As alleged in both the SDNY and the SDFL Indictments,


GILBERTO and MIGUEL ANGEL RODRIGUEZ-OREJUELA once controlled a


powerful Colombian narcotics-trafficking organization based in


Cali, Colombia (the "Cali Cartel"). In their previous guilty


pleas to the SDFL Indictment, the defendants admitted to


importing more than 200 tons of cocaine into the United States


for resale. 


As alleged in the SDNY Indictment, in order to insulate


the illicit fortune of the Cali Cartel from law enforcement


176 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

detection and seizure, GILBERTO RODRIGUEZ-OREJUELA, MIGUEL ANGEL


RODRIGUEZ-OREJUELA, and their criminal associates invested


millions of dollars of the Cali Cartel's cocaine proceeds in


ostensibly legitimate companies, including companies involved in


the production and sale of pharmaceutical drugs. Although


GILBERTO and MIGUEL ANGEL RODRIGUEZ-OREJUELA were initially


identified in public documents in Colombia as partners in several


of the companies, they subsequently attempted to conceal their


continuing ownership and control of these companies to protect


their illicit assets from seizure by law enforcement authorities. 


As part of their efforts at concealment, the RODRIGUEZ-OREJUELA


brothers allegedly arranged for their companies to be held under


the names of family members or trusted associates when, in fact,


the companies continued to be controlled by the defendants.


On October 21, 1995, President CLINTON, pursuant to the


authority granted by, among other things, the International


Emergency Economic Powers Act, Sections 1701 to 1706 of Title 50


of the United States Code, signed Executive Order 12978, entitled


"Blocking Assets and Prohibiting Transactions with Significant


Narcotics Traffickers." In the Order, President CLINTON declared


a national emergency based on the threat posed to the United


States by significant narcotics traffickers centered in Colombia;


applied economic sanctions against, among others, GILBERTO


RODRIGUEZ-OREJUELA and MIGUEL ANGEL RODRIGUEZ-OREJUELA; and


delegated the enforcement and regulation of the economic


sanctions to the Treasury Department's Office of Foreign Asset


Control ("OFAC").


Based on the continuing threat posed to the United


States by significant narcotics traffickers centered in Colombia,


on about October 19, 2001, President BUSH continued the national


emergency declared in Executive Order 12978. From October 21,


1995 to the present, OFAC has persisted in applying economic


sanctions against numerous companies effectively controlled by


GILBERTO and MIGUEL ANGEL RODRIGUEZ-OREJUELA and against other


criminal associates of the Cali Cartel.


As charged in the SDNY Indictment, between about


October 21, 1995 and the present, in an attempt to protect their


assets and to evade OFAC sanctions, and in violation of United


States law, GILBERTO RODRIGUEZ-OREJUELA, MIGUEL ANGEL RODRIGUEZ-


OREJUELA, and their associates removed their names from companies


that had been sanctioned by OFAC. In addition, after the


companies themselves were subsequently sanctioned by OFAC,


GILBERTO and MIGUEL ANGEL RODRIGUEZ-OREJUELA, with the assistance


of others, established "new" or "re-organized" companies to


replace the previously-sanctioned companies. In fact, these


-2­

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

177 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

"new" or "re-organized" companies simply assumed the assets and


continued to perform the services of the previously sanctioned


companies and often had the same management and physical business


locations. After the "new" or "re-organized" companies were


formed to protect their assets and to evade OFAC sanctions,


GILBERTO and MIGUEL ANGEL RODRIGUEZ-OREJUELA then named


additional family members and trusted associates who had not been


sanctioned by OFAC to manage the companies. Between about March


2002 and January 2003, the RODRIGUEZ-OREJUELA brothers were


involved in transferring approximately $1.5 million in funds


controlled by pharmaceutical drug companies through bank accounts


in New York, New York.


Immediately following their guilty pleas today, Judge


MORENO sentenced GILBERTO and MIGUEL RODRIGUEZ-OREJUELA, 67 and


62 years old, respectively, to 87 months' imprisonment on the


money-laundering charges, to run concurrently with the sentence


of 360 months' imprisonment he previously imposed on the cocaine-


trafficking charges in the SDFL Indictment.


The charges in the SDNY Indictment were the result of a


joint Organized Crime Drug Enforcement Task Force ("OCDETF")


investigation entitled "Operation Dynasty" which involved the


United States Attorney's Office for the Southern District of New


York, the United States Drug Enforcement Administration ("DEA"),


OFAC, the Colombian National Police ("CNP"), and the Colombian


Fiscalia Money Laundering Section.


Mr. GARCIA praised the investigative efforts of the


DEA, OFAC, the CNP, and the Colombian Fiscalia Money Laundering


Section and thanked the U.S. Attorney’s Office in the Southern


District of Florida for its cooperation in this matter.


Operation Dynasty is being prosecuted by the Office's


International Narcotics Trafficking Unit. Assistant United


States Attorneys BOYD M. JOHNSON III, GLEN G. MCGORTY, and KEVIN


R. PUVALOWSKI are in charge of the prosecution.

06-185 ###

-3­

178 IMPACT REPORT 
APPENDIX B 

 DESIGNATION ANNOUNCEMENTS AND CHARTS 

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November 28, 2006 

HP-179 

Treasury Targets Drug Cartel Assets in 

Colombia and Offshore Havens 

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) 

today added five Colombian individuals and twenty-two entities to its list of Specially 

Designated Narcotics Traffickers (SDNTs) for their ties to the North Valle drug 

cartel. 

"Today's action levies financial sanctions against another group of previouslyconcealed entities and individuals operating on behalf of the North Valle cartel," 

said Adam Szubin, Director of the Office of Foreign Assets Control. "OFAC will 

continue to dismantle the cartel's financial empire and expose its willing 

collaborators." 

The five Colombian individuals act as front persons for the North Valle drug cartel 

leader Raul Grajales Lemos (Raul Grajales), and one of the individuals is also 

associated with North Valle leader Carlos Alberto "Beto" Renteria (Beto Renteria). 

Today's action is the sixth designation against the financial network of Raul 

Grajales and Beto Renteria. 

One of the individuals named today, Abdala Saieh Jassir has served as a front 

person for Raul Grajales and Beto Renteria since 1988. He is the father of SDNT 

Moises Abdal Saieh Muvdi, who was designated by OFAC on June 13, 2006, and is 

currently in Colombian custody on money laundering charges. Abdala Saieh Jassir 

has also operated as the manager of Confecciones Lord S.A., an SDNT entity that 

supplies goods to Casa Estrella, a designated Colombian department store chain 

owned by Raul Grajales and Beto Renteria. The remaining four individuals 

designated today, Gloria Elena Fajardo Hernandez, Piedad Rocio Sanchez 

Candelo, Sandra Milena Prieto Santiago and Hector Leon, have played key roles in 

managing companies controlled by Raul Grajales. 

Twenty-two companies controlled by Raul Grajales and/or Beto Renteria have also 

been designated today as SDNTs. Five of these companies are run by SDNTs 

Moises Abdal Saieh Muvdi, Carlos Ernesto Saieh Jamis and Abdala Saieh Jassir, 

who have worked for or on behalf of Beto Renteria and Raul Grajales for well over a 

decade. These five entities form a part of the international financial network of Raul 

Grajales and Beto Renteria, and are located in Barbados, the British Virgin Islands, 

the Cayman Islands and Panama. The remaining seventeen companies are 

controlled by Raul Grajales and encompass a wide range of services including 

agricultural, consulting, telecommunications, car rental, retail, accessory 

manufacturing, publishing, construction, agricultural products, agricultural research 

and education and the exportation of products. 

This action is part of an ongoing interagency effort to expose, isolate, and disrupt 

Colombia's drug cartels by means of economic sanctions pursuant to Executive 

Order 12978. This effort involves the Departments of the Treasury, Justice, State 

and Homeland Security. Today's action freezes any assets of the designees found 

in the United States and prohibits all financial and commercial transactions by any 

U.S. person with the designees. 

The assets of a total of 1327 businesses and individuals have been designated 

pursuant to E.O. 12978, in the United States, Aruba, Barbados, Colombia, Costa 

IMPACT REPORT 

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

179 
TABLE OF CONTENTS APPENDIX

APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

Rica, Ecuador, Panama, Peru, Spain, Vanuatu, Venezuela, the Bahamas, the 

British Virgin Islands, and the Cayman Islands. The 526 SDNT businesses include 

agricultural, aviation, consulting, construction, distribution, financial, investment, 

manufacturing, mining, offshore, pharmaceutical, publishing, real estate, retail, 

service and telecommunication firms. The SDNT list includes 21 kingpins from the 

Cali, North Valle and North Coast drug cartels in Colombia. 

REPORTS z Please find attached a chart of today

’s designation. 

180 IMPACT REPORT 
APPENDIX B  DESIGNATION ANNOUNCEMENTS AND CHARTS 

North Valle Cartel

Financial Network Office of Foreign Assets Control

R 

MELON LTDA. 

SDNT Principal Individuals 

Grajales Companies 

Colombian Department Store Chain

RENTERIA MANTILLA

g

Partners 

U.S. Department of the Treasury 

Specially Designated 

Narcotics Traffickers November 2006 

Moises Abdal 

SAIEH MUVDI 

CC 7427466 (Colombia) 

Designated June 13, 2006 

Abdala 

SAIEH JASSI

CC 812202 (Colombia) 

Carlos Ernesto 

SAIEH JAMIS 

CC 8739066 (Colombia) 

Designated June 13, 2006 

Gloria Elena 

FAJARDO HERNANDEZ

CC 29926353 (Colombia) 

Hector

LEON 

CC 19251100 (Colombia) 

Sandra Milena 

PRIETO SANTIAGO 

CC 66702878 (Colombia) 

Piedad Rocio 

SANCHEZ CANDELO 

CC 31252839 (Colombia) 

KATTUS CORPORATION 

St. Michael, Barbados 

Registration ID 67199901 

MLA INVESTMENTS INC. 

British Virgin Islands 

C.R. No. IBC 525487 

BRUNELLO LTD. 

Grand Cayman, Cayman Islands 

C.R. No. 68557 

JAMCE INVESTMENTS LTD. 

Grand Cayman, Cayman Islands 

C.R. No. 93989 

VILLAROSA INVESTMENTS 

CORPORATION 

Panama City, Panama 

C.R. No. 312563/48824/0058 

WORLD WORKING

COMERCIALIZADORA INTERNACIONAL S.A. 

NIT # 805023286-9 (Colombia) 

PLAZA REAL LTDA. 

NIT # 805000581-8 (Colombia) NIT # 890331686-1 (Colombia) 

MANUFACTURAS REAL S.A. 

NIT # 800158181-6 (Colombia) 

JEHOVA LTDA. 

NIT # 800112196-8 (Colombia) 

CALI @TELE.COM LTDA. 

NIT # 805021515-1 (Colombia) 

Grajales / Renteria Associates 

Additional Grajales Associates 

CASA ESTRELLA

Designated May 11, 2005 

Raul Alberto 

GRAJALES LEMOS

CC 6356044 (Colombia) 

Designated May 11, 2005 

-Captured May 2005-

Carlos Alberto

("Beto RENTERIA") 

CC 6494208 (Colombia) 

Designated March 17, 2005 

-Fu itiveOffshore Companies Barbados 

British Virgin Islands 

Cayman Islands 

Panama 

ASESORES CONSULTORES ASOCIADOS LTDA. 

NIT# 805007818-1 (Colombia) 

DOXA S.A. 

NIT # 821002801-0 (Colombia) 

CONSTRUCCIONES E INVERSIONES LTDA. 

NIT # 800154939-3 (Colombia) 

CITICAR LTDA. 

NIT # 800026660-6 (Colombia) 

COMMUNICACIONES ABIERTAS CAMARY LTDA. 

NIT # 805028107-1 (Colombia) 

CONFECCIONES LINA MARIA LTDA. 

NIT # 800026667-7 (Colombia) 

L.GR. E.U. 

NIT # 805024405-3 (Colombia) 

GBS TRADING S.A. 

NIT # 805026824-5 (Colombia) 

FUNDACION CENTRO DE INVESTIGACION 

HORTIFRUTICOLA DE COLOMBIA 

NIT # 821002640-1 (Colombia) 

FUNDACION CENTRO FRUTICOLA ANDINO 

NIT # 800077756-2 (Colombia) 

EAGLE COMMUNICATION BROKERS INC. 

Panama 

IMPACT REPORT 

: 2007 — 618-814

APPENDIX B DESIGNATION ANNOUNCEMENTS AND CHARTS 

181