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3/2/2023

Treasury Sanctions Sinaloa Cartel Network of “Super Lab” Suppliers and Fentanyl Operators | U.S. Department of the Tr…

U.S. DEPARTMENT OF THE TREASURY
Treasury Sanctions Sinaloa Cartel Network of “Super Lab”
Suppliers and Fentanyl Operators
February 22, 2023

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) designated six Mexican nationals and Sinaloa Cartel members involved in the
illicit methamphetamine and fentanyl trade as well as six Mexico-based entities pursuant to
Executive Order (E.O.) 14059. Led by brothers Ludim Zamudio Lerma and Luis Alfonso
Zamudio Lerma, this network is responsible for diverting illicit precursor chemicals directly
into the hands of Sinaloa Cartel members and laboratory operators, further bolstering the
Sinaloa Cartelʼs role as the preeminent facilitator of illicit fentanyl and other deadly drugs
being tra icked into the United States.
“The Zamudio Lerma brothers and their network enable the production of synthetic drugs
that devastate American lives, while lining the pockets of Sinaloa Cartel leadership,” said OFAC
Director Andrea Gacki. “Depriving this network of access and resources will hinder the Sinaloa
Cartelʼs ability to produce and tra ic the illicit drugs it depends on.”
Based in Sinaloa, Mexico, the brothers, Ludim Zamudio Lerma and Luis Alfonso Zamudio
Lerma, as well as Ludim Zamudio Lermaʼs son, Ludim Zamudio Ibarra, supply illicit precursor
chemicals to high-level Sinaloa Cartel members, including Luis Gerardo Flores Madrid, who
works for Ovidio Guzman Lopez (the recently captured son of Joaquin “El Chapo” Guzman
Loera), and lab operators, including Ernesto Machado Torres and Jose Santana Arredondo
Beltran. The precursor chemicals are used in super labs — large-scale drug laboratories that
produce 10 or more pounds of an illicit drug per production cycle — to produce illicit fentanyl
and methamphetamine for the Sinaloa Cartel. OFAC designated each of the above individuals
pursuant to E.O. 14059 for having engaged in, or attempted to engage in, activities or
transactions that have materially contributed to, or pose a significant risk of materially
contributing to, the international proliferation of illicit drugs or their means of production.
The Zamudio family owns numerous Mexico-based businesses, two of which — Aceros y
Refacciones del Humaya, S.A. de C.V. and Farmacia Ludim — OFAC designated today
pursuant to E.O. 14059 for having engaged in, or attempted to engage in, activities or
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transactions that have materially contributed to, or pose a significant risk of materially
contributing to, the international proliferation of illicit drugs or their means of production.
Additionally, OFAC designated a real estate business, Inmobiliaria del Rio Humaya, S.A. de
C.V., for being owned, controlled, or directed by, or having acted or purported to act for or on
behalf of, directly or indirectly, Ludim Zamudio Lerma, while a second real estate business,
Operadora Zait, S.A. de C.V., was designated for being owned, controlled, or directed by, or
having acted or purported to act for or on behalf of, directly or indirectly, Luis Alfonso
Zamudio Lerma. OFAC also designated two import/export companies, Operadora del
Humaya, S.A. de C.V. and Operadora Parque Alamedas, S. de R.L. de C.V., for being owned,
controlled, or directed by, or having acted for or on behalf of, directly or indirectly, Ludim
Zamudio Lerma and Ludim Zamudio Ibarra.
This action was coordinated closely with the Government of Mexico and would not have been
possible without the cooperation, support, and ongoing collaboration with the FBI Phoenix
Field O ice (Tucson Resident Agency), the FBI Legal Attaché San Salvador (Sub-O ice
Guatemala City), and the DEA Tucson District O ice.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated
individuals that are in the United States or in the possession or control of U.S. persons must
be blocked and reported to OFAC. OFACʼs regulations generally prohibit all transactions by U.S.
persons or persons within or transiting the United States that involve any property or
interests in property of designated or otherwise blocked persons. U.S. persons may face civil
or criminal penalties for violations of E.O. 14059. In addition, persons that engage in certain
transactions with the individuals and entities designated today may themselves be exposed
to sanctions or subject to an enforcement action.
Todayʼs action is part of a whole-of-government e ort to counter the global threat posed by
the tra icking of illicit drugs into the United States that causes the deaths of tens of
thousands of Americans annually, as well as countless non-fatal overdoses. OFAC, in
coordination with its U.S. government partners and foreign counterparts, will continue to
target and pursue accountability for foreign illicit drug actors.
U.S. sanctions need not be permanent; sanctions are intended to bring about a positive
change of behavior. Consistent with the findings of Treasuryʼs 2021 Sanctions Review

, the

removal of sanctions is available for persons designated under counter narcotics authorities
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who demonstrate a change in behavior and no longer engage in activities linked to
international illicit drug tra icking or other sanctionable activity.
For information concerning the process for seeking removal from any OFAC list, including the
Specially Designated Nationals and Blocked Persons List, please refer to OFACʼs Frequently
Asked Question 897. Additional information regarding sanctions programs administered by
OFAC can be found here.
View more information on the individuals and entities designated today.
View the chart on the individuals and entities designated today.
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