SDN Roundup: the top SDNTKs in Mexico and which cartels to focus on

Borderland Beat has a good little article of the top ten most wanted cartel leaders in Mexico. One of the top honchos, Miguel Trevino, was captured and has been charged with money laundering. Oddly, its unlikely that murder charges will stick in Mexico, but we will see. If you or your compliance program are looking to do a deep dive into the risks associated with Mexico, it may be a good idea to mirror OFAC’s actions. Of the members on this list, the ones I would focus on the most would be of the bosses belonging to either the Sinaloa or Zeta cartels.  OFAC designation strategy has been primarily targeted towards those two entities and with good reasons. Tracking the cartels can be a difficult job. One thing I noticed when doing my thesis is that you could have four turf maps from the same time period that will tell you five different answers. Cartels expand, contract and replicate with such fluidity that it is hard to keep track. Take a look at what happened with La Familia: a leader is either killed or arrested and the organizations engages in a fun version of cartel mitosis and viola, you now have two cartels for the price of one. The two cartels that have differentiated themselves however are both the Sinaloa and Zetas, and for two very different reasons. These reasons make them a greater threat and thus a more frequent stomping ground for SDN designations. Perhaps the greatest focus from OFAC will be on the Sinaloa cartel, and the main reasons is that Sinaloa has been the historic root of the cartels and their organization has remained persistently effective. Sinaloa province has been the traditional heartland of Mexican criminal activity and the original center of (legal) opiate production. Geographically, the terrain is mountainous and hard for the government to establish a presence and lends itself well to a smuggling route up through Sonora province and into the U.S. But more than that, due to a lack of government presence and corrupt institutions with the old PRI, the cartel was able to firmly cement itself in a monopoly until they decided to split (well, more like the government sort of forced them to split through death and destruction) into the the Sinaloa Federation (which still retained the main institutional structure), the Arrellano-Felix Organization and the Juarez Cartel.  This drove up competition, which meant more violence yet Sinaloa always remained the base of power. This remains the case today, with Sinaloa best able to prevent splinter factions and drawing from its own regional security as the progenitor of the cartels. The focus by OFAC on the Zetas is a bit more short term. In a lecture a while back I got into a heated argument when I asserted that the Sinaloa should be the main focus of the USG and the other cartels were necessary diversions. A very angry attendee asked me how I could possibly brush off the Zetas as they were the most violent and even she had been threatened when she lived in Mexico. My first response was something along the lines “yeah, you and everyone else in Tamaulipas” (which for the record, didn’t make her feel better) and then bet her a dollar that while the Zetas were a huge concern at present, they wouldn’t be in five years. Well, it’s been a year, their leadership is now MIA behind bars or in body bags, groups such as the Sangre Zetas show evidence of splintering and I could really use the extra dollar. But in the end,...

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