Sumilab is run by the Favela Lopez family, including siblings, Victor Andres Favela Lopez (Victor Andres), Francisco Favela Lopez (Francisco), Jorge Luis Favela Lopez (Jorge Luis), and Maria Gabriela Favela Lopez (Maria Gabriela), as well as Maria Gabriela’s spouse, Jairo Verdugo Araujo (Jairo), and Gilberto Gallardo Garcia (Gilberto), who is married to another Favela Lopez sibling. Victor Andres, Francisco, and Jorge Luis operate under the Los Chapitos faction of the Sinaloa Cartel and are responsible for supplying and distributing precursor chemicals and lab equipment to Sinaloa Cartel-affiliated chemical brokers and lab operators, who produce illicit fentanyl and methamphetamine. Today, Sumilab, Victor Andres, Francisco, and Jorge Luis were designated pursuant to Executive Order (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; and pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the Sinaloa Cartel. Specifically, in the days and weeks following OFAC’s action, Victor Andres, Francisco, and Jorge Luis each removed themselves and/or other family members from numerous corporate filings—to include Agrolaren, Viand, Favelab, and Fagalab—and installed front persons in their place. For example, Cesar Elias Lopez Araujo (Cesar Elias), sanctioned today, was the front person of choice for Victor Andres.
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”).
