SDN Moves: Designations, Delistings and Deals Oh My!!!

Yes, it’s Friday and time for your weekly SDN moves. And it’s been quite a busy week.



In a very interesting turn of events this morning, it was reported that the Turkish government has selected an SDN from whom to procure surface to air missiles. Instead of acquiring U.S. made Patriot or Russian S-300 SAMS, they decided to bizarrely acquire HQ-9 systems from China Naitonal Precision Machinery Import/Export Corporation (CPMEIC). What is extremely interesting about this is that CPMEIC has been designated under [IFSR] and [NPWMD]. According to 31 CFR 561.201(a)(5)(ii), anyone who facilitates a transaction for CPMEIC could be subject to CISADA. As that a bank, even possibly the central bank of Turkey could be facilitating this significant transaction, this could result in a 561 designation that would prohibit opening of a correspondent bank in the U.S.

If anything, it would be wise to monitor this deal closely and ensure your institution doesn’t inadvertently engage in this transaction.



OFAC has targeted two relatively new targets, both the Cachiros in Honduras as well as Los Gueros in Mexico. Erich Ferrari already did a piece on the Gueros organization, whom frankly not much information exists. I honestly don’t know much about them other than their 2009 indictment.

The Cachiros are an interesting case. They are Honduras’ largest organized crime and a transiter of cocaine from Colombia to Mexico. The Cachiros are well connected to Guatemalan gangs (which makes sense given their transportation routes). This is significant in as much as the Sinaloa and particularly the Zetas have extremely strong ties to Guatemala. Many of the Zetas original members were part of the Guatemalan Kabiles, a light infantry/special forces unit similar to the one that the Zetas defected from, and along with distribution of cocaine the Zetas have been known to run training camps and obtain heavy weaponry in Guatemala. I view the designation of the Cochires as a smart attempt to cut as deep in the supply chain of two of the worlds most terrible organizations.

Los Cochires have been known to wield powerful influence, enough to be in a position to pressure the President to appoint one of their own as a minister. Apparently he refused so they offed a senator in revenge. This level of governmental penetration suggests high levels of dual sovereignty for the organization in Honduras and it wouldn’t be surprising if some of these designations have ownership or interests in a large area of commerce. Point and case. it has been alleged that the Cachiros not only have strong ties to the Honduran government but also own the Real Socieded Municipal soccer club and the clubs prime sponsor, Joya Grande, a Zoo in Honduras. (hint: add these to your filter…you’re welcome).

Speaking of Central America, SDNTK Waldemar Lorenzana Lima was captured on the 20th.



Unfortunately, we’ve seen the tragedy that an FTO can strike after al-Shabaab fighters struck a mall in Kenya, killing dozens. People are still reported missing and the attacks are alleged to have involved several Americans and a UK national. Analysts are stating that this attack both marks a shift in al-Shabaab strategy towards a much more dispersed terrorist group rather than the insurgent force that once controlled much of Somalia.  The organization has undergone leadership changes and solidification of power, as we saw with last week’s SDN-on-SDN killing.

OFAC also delisted several SDGTs, mainly because they gave up their ways through kinetic thought disruption. It’s important to remember that the simple act of dying does not remove you from the SDN list as that there may be good reasons for your frozen assets to not pass onto a beneficiary party.