Paez is also a recruiter for Alberto David Benguiat Jimenez’s money laundering organization and is involved in laundering money on behalf of the Sinaloa Cartel. Alberto David Benguiat Jimenez (Benguiat) is based in Mexico City and operates a money laundering network moving illicit narcotics proceeds from the United States into Mexico on behalf of the Sinaloa Cartel and OFAC-designated fentanyl trafficker Jose Angel Rivera Zazueta (Rivera), whose drug trafficking organization imports precursor chemicals from China into Mexico to manufacture synthetic drugs, including fentanyl, MDMA (ecstasy), crystal methamphetamine, and ketamine. Benguiat’s network has laundered over $50 million to date. On March 31, 2025, the United States District Court for the Southern District of California unsealed an indictment charging Benguiat with conspiracy to launder monetary instruments and transmit monetary instruments for the purpose of laundering. Christian Noe Amador Valenzuela (Amador) is a close associate of Benguiat who launders money as a part of the network. On March 31, 2025, the United States District Court for the Southern District of California unsealed an indictment charging Amador with conspiracy to launder monetary instruments. Benguiat’s organization uses a network of front companies and shell corporations to obscure the origins of the money it moves from the United States, including Scatman and Hatman Corp S.A.P.I. de C.V., Personas Unidas Hoas S.A.P.I. de C.V., Grupo Zipfel de Mexico S.A., Grupo Unter Empresarial S.A. de C.V., Productions Pipo S. De R.L. de C.V., and Grupo Vindende S.A. de C.V. Esparragoza, Viramontes, and Benguiat were designated today pursuant to E.O. 14059 for having provided, or attempted to provide, financial, material, or technological support for, or goods or services in support of, the Sinaloa Cartel. Additionally, Esparragoza, Viramontes, and Benguiat were designated today pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the Sinaloa Cartel.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
