New Executive Order Targets Alleged Significant Transnational Criminal Organizations

U.S. Department of the Treasury on July 25, 2011 released the following:

“President Obama has signed an Executive Order imposing sanctions against significant transnational criminal organizations (TCOs). The Order provides the United States with new tools to break the economic power of transnational organized crime and protect financial markets. It will assist the Administration’s efforts to disrupt, dismantle and defeat the TCOs that pose a significant threat to U.S. national security, foreign policy or the economy.

As a result of this Order, any property in the United States or in the possession or control of U.S. persons in which the significant TCOs listed in the Annex have an interest is blocked, and U.S. persons are prohibited from engaging in transactions with them.

The Order also authorizes the U.S. Department of the Treasury, in consultation with the Departments of Justice and State, to identify for sanctions any individual or entity determined to have materially assisted, sponsored or provided financial, material or technological support for any person whose property and interests in property are blocked pursuant to this Order.

In signing today’s Order, the President imposed sanctions on the following organizations listed in the Annex:

The Brothers’ Circle (Eurasia)
The Brothers’ Circle is a multi-ethnic criminal group composed of leaders and senior members of several Eurasian criminal groups largely based in countries of the former Soviet Union but extending to the Middle East, Africa and Latin America. Many Brothers’ Circle members share a common ideology based on the “thief-in-law” tradition, which seeks to spread their brand of criminal influence globally. The Brothers’ Circle serves as a coordinating body for several national level criminal networks, which includes mediating disputes between the individual criminal networks and directing global criminal activity.

The Camorra (Italy)
Considered the largest Italian organized crime group, the Camorra is a loose collection of allied and competing local clans in the province of Naples and the Campania region of Italy. The Camorra operates internationally and is involved in serious criminal activity such as counterfeiting and narcotics trafficking.

The Camorra may earn more than 10 percent of its roughly $25 billion annual profit through the sale of counterfeit and pirated goods – such as luxury clothing, power tools, CDs, DVDs, and software – in European and U.S. markets. The Camorra’s counterfeiting and piracy activities undermine U.S. sales of genuine products and deny U.S. copyright holders of profits. The International Intellectual Property Alliance (IIPA), a private sector coalition of trade associations, estimates that copyright piracy causes trade losses with Italy of more than $1 billion every year.

The Yakuza (Japan)
The Yakuza comprises the major Japanese organized crime syndicates, sometimes referred to as “families,” and had more than 80,000 members as of 2008. The Yakuza derives most of its profits from the drug trade, particularly methamphetamine, the most widely abused drug in Japan. The Yakuza also profits from other serious criminal activities, including weapons trafficking and nearly all aspects of sexual exploitation: sex tourism, prostitution, human trafficking, “mail order” marriages, pornography, and the exploitation of women and children, with the help of local crime syndicates in East Asia. The Yakuza is also heavily involved in white-collar crime, often using front companies to hide illicit proceeds within legitimate industries, including construction, real estate and finance.

In addition to its networks in Japan, the Yakuza acts globally. It has relationships with criminal affiliates in Asia, Europe and the Americas. In the United States, the Yakuza has been involved primarily in drug trafficking and money laundering.

Los Zetas (Mexico)
Formerly the armed wing of the Gulf Cartel, Los Zetas is an extremely violent transnational criminal organization based primarily in Mexico. The organization is estimated to have thousands of members in Mexico, Central America and the United States. Los Zetas facilitates drug trafficking into the United States and has relationships with U.S.-based gangs. Los Zetas is specifically responsible for the safe passage of large quantities of illegal narcotics, including cocaine, methamphetamine, heroin and marijuana moving through Mexico and eventually into the United States. In addition to drug trafficking, Los Zetas is involved in extortion, money laundering, intellectual property theft and human smuggling. Los Zetas and Gulf Cartel members together are named in multiple indictments in Federal District courts for violating U.S. narcotics laws. These indictments allege that Los Zetas has carried out numerous acts of violence, including murders, kidnappings and tortures.

Los Zetas members are responsible for mass murders in Mexico and Guatemala, and have demonstrated their capacity and willingness to intimidate and brazenly kill law enforcement and other government personnel. In February 2011, Los Zetas members ambushed and killed Immigration and Customs Enforcement (ICE) Special Agent Jaime Zapata and seriously wounded ICE Agent Victor Avila. In April 2011, Mexico’s Office of the Attorney General announced the arrest of Los Zetas cell leaders connected to the discovery of nearly 200 bodies dumped in mass graves in San Fernando, Tamaulipas, Mexico. The victims were kidnapped from passenger buses traveling toward the U.S.-Mexico border. In May 2011, Los Zetas members stormed a ranch in northern Guatemala and killed 27 people and later killed the Guatemalan prosecutor involved in the investigation of the murders.

The President identified Los Zetas as a significant foreign narcotics trafficker under the Foreign Narcotics Kingpin Designation Act in 2009. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has since designated four principal Los Zetas and Gulf Cartel leaders and 54 Mexican principal lieutenants and enforcers for Los Zetas and the Gulf Cartel pursuant to the Kingpin Act.​”

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN List Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at or at one of the offices listed above.

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