Overview

On June 30, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) announced coordinated actions targeting fuel smuggling and fuel tax evasion schemes linked to Cartel de Jalisco Nueva Generacion (CJNG), a Mexican criminal organization designated under both counternarcotics and counterterrorism authorities. OFAC also sanctioned two Mexican nationals and nine entities alleged to be involved in CJNG-linked fuel theft and cross-border fuel smuggling operations, while FinCEN simultaneously issued a supplemental Alert providing financial institutions with updated typologies and red flags associated with fuel smuggling and Mexican fuel tax evasion schemes.

OFAC designated the individuals and entities pursuant to Executive Order (E.O.) 14059 and E.O. 13224. According to OFAC’s press report, the targeted schemes involve the smuggling of fuel from the United States into Mexico, the use of shell companies and falsified customs documentation, and the evasion of Mexico’s fuel import tax regime. OFAC additionally stated that these activities generate substantial revenue for CJNG and other Mexico-based transnational criminal organizations.

Treasury Secretary Scott Bessent emphasized the significance of the action, stating that Mexican cartels are expanding beyond traditional narcotics trafficking into other illicit revenue-generating activities and that Treasury will continue targeting the financial infrastructure that supports these organizations.

OFAC also stated that the action was coordinated with a South Texas Homeland Security Task Force-led investigation involving, among others, the Drug Enforcement Administration, Homeland Security Investigations, the Federal Bureau of Investigation, Internal Revenue Service Criminal Investigation, the Bureau of Industry and Security, and U.S. Customs and Border Protection. Treasury further noted that the sanctions designations were developed jointly with Mexico’s financial intelligence unit, the Unidad de Inteligencia Financiera.

CJNG and Huachicol-Related Activities

At the outset we note that CJNG is a U.S.-designated Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT) that OFAC alleges is responsible for a significant portion of the fentanyl and other illicit drugs trafficked into the United States. Following the press report, OFAC stated that, in addition to narcotics trafficking, fuel theft and fuel smuggling activities, known in Mexico as “huachicol,” have become one of the most significant nondrug revenue streams for Mexican cartels. According to OFAC, these activities generally include (1) the theft of fuel and crude oil from Mexico’s state-owned energy company, (2) the smuggling of crude oil into the United States and (3) the smuggling of fuel from the United States into Mexico through schemes designed to evade Mexican fuel taxes.

The press report also stated that cartel-affiliated actors employ a variety of methods to steal hydrocarbons, including illegal pipeline taps, refinery theft, tanker truck hijackings and corruption of local state-owned energy company personnel. OFAC further explained that fuel smuggling schemes frequently involve networks of brokers, logistics providers, shell companies and fuel distributors operating on both sides of the U.S.-Mexico border.

The announcement also highlighted FinCEN’s analysis of Bank Secrecy Act reporting. OFAC noted that in the 12 months following FinCEN’s May 2025 Alert concerning crude oil smuggling, FinCEN received more than 160 Suspicious Activity Reports describing over $7 billion in suspicious activity. 

Sanctioned Individuals

OFAC designated Oscar Guillermo Juraidini Silva (Juraidini), whom OFAC identified as a key facilitator of CJNG’s fuel theft and smuggling activities. OFAC alleged that Juraidini acts as an accountant and financial operator for CJNG, creating and operating shell companies and falsifying customs documentation to facilitate the illicit transfer of fuel across the U.S.-Mexico border. OFAC further alleged that Juraidini imports fuel into Mexico using intentionally misclassified customs filings to evade Mexico’s fuel taxes and that these activities generate tens of millions of dollars annually for the benefit of CJNG.

OFAC also designated seven entities allegedly owned or controlled by Juraidini:

  • Centro Cambiario La Peseta, S.A. de C.V.
  • OJ Living Trust, S.A.P.I. de C.V.
  • RK Real King, S.A. de C.V.
  • Soma Transporte y Servicios, S.A. de C.V.
  • Ogui Fletes
  • OF Transportes
  • Cucumber Sweet Waves Ltd.

Juraidini was designated pursuant to E.O. 14059 and E.O. 13224 for acting for or on behalf of, directly or indirectly, CJNG. OFAC further stated that the seven related entities were designated for being owned, controlled or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Juraidini.

OFAC also designated J. Refugio Ruiz Villagomez, whom OFAC alleges played a role in Jomadi Logistics & Cargo, S.A. de C.V. (Jomadi) and Ahavat Logistics Solution, S.A. de C.V. (Ahavat). The report stated that Ruiz Villagomez knowingly smuggled fuel from the United States into Mexico without proper permits and paid fees to criminal organizations controlling ports of entry between the United States and Mexico.

OFAC cited investigative findings made public by Mexico’s Attorney General’s Office alleging that Jomadi participated in huachicol fiscal activities. OFAC further noted that Jomadi and Ahavat allegedly transacted through the U.S. financial system, involving tens of millions of dollars, with third parties linked to CJNG and other huachicol-related activities.

In connection with this action, OFAC designated:

  • Jomadi Logistics & Cargo, S.A. de C.V.
  • Ahavat Logistics Solution, S.A. de C.V.

Jomadi and Ahavat were designated pursuant to E.O. 14059 and E.O. 13224 for having provided support, goods or services to or in support of CJNG. Treasury further stated that Ruiz Villagomez was designated pursuant to both authorities for acting for or on behalf of, directly or indirectly, Jomadi and Ahavat.

FinCEN Supplemental Alert

Alongside OFAC’s sanctions action, and as linked above, FinCEN issued a supplemental Alert providing financial institutions with additional guidance concerning financial typologies and red flags associated with fuel smuggling activities conducted by CJNG and other Mexico-based transnational criminal organizations. The Alert focuses on schemes involving the smuggling of gasoline, diesel, naphtha and other fuels from the United States into Mexico while evading Mexico’s fuel import taxes. We are happy to discuss any of these topics in further detail. 

OFAC explained in the press report that these schemes often involve complicit fuel distributors, logistics providers, trading companies, front companies, shell companies and brokers operating in both the United States and Mexico. OFAC further noted that cartels use a variety of methods to move proceeds associated with these schemes. 

OFAC Designation Implications

As with prior OFAC designations, all property and interests in property of the designated individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Entities owned 50% or more by one or more blocked persons are also blocked under OFAC’s 50% Rule.

All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods or services by, to or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods or services from any such person.

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We will continue to monitor developments in this area and encourage you to subscribe to be kept informed of the latest developments. Please contact the authors or your usual Herbert Smith Freehills Kramer contacts for more information.

 

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Americas Sanctions Foreign direct investment Jonathan Cross Yash Dattani