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11/30/2023

Treasury Takes Third Action Against CJNG Timeshare Fraud Network Centered in Puerto Vallarta | U.S. Department of …

Treasury Takes Third Action Against CJNG Timeshare Fraud
Network Centered in Puerto Vallarta
November 30, 2023

Treasury Coordinates with Government of Mexico to Further Disrupt CJNG Timeshare Fraud
WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) sanctioned three Mexican individuals and 13 Mexican companies. These
individuals and companies are linked, directly or indirectly, to timeshare fraud led by the Cartel
de Jalisco Nueva Generacion (CJNG). CJNG, a violent Mexico-based organization, tra ics a
significant proportion of the illicit fentanyl and other deadly drugs that enter the United
States. OFAC coordinated this action with the Government of Mexico, including its Financial
Intelligence Unit, as well as U.S. Government partners, including the Federal Bureau of
Investigation (FBI), and the Drug Enforcement Administration.
“The CJNG cartel, a leading tra icker of narcotics like illicit fentanyl into the United States,
generates substantial revenue for its multi-faceted criminal enterprise through its timeshare
fraud network,” said Secretary of the Treasury Janet L. Yellen. “CJNG uses extreme violence
and intimidation to control the timeshare network, which o en targets elder U.S. citizens and
can defraud victims of their life savings. Treasury remains committed to the Administrationʼs
whole-of-government e ort, in coordination with our partners in Mexico, to disrupt CJNGʼs
revenue sources and ability to tra ic deadly drugs like fentanyl.”

EXPOSING CJNG T IMESHARE F RAUD
On March 2, 2023, OFAC sanctioned eight Mexican companies pursuant to Executive Order
(E.O.) 14059. These companies are linked, directly or indirectly, to CJNGʼs timeshare fraud
activities. On April 27, 2023, OFAC sanctioned seven Mexican individuals, including drug
tra icking fugitive Eduardo Pardo Espino, and 19 Mexican companies pursuant to E.O. 14059.
These individuals and companies are also linked, directly or indirectly, to CJNGʼs timeshare
fraud activities.
Although there are di erent types of timeshare fraud, the schemes o en involve the
following: (1) third-party scammers, who claim to have ready buyers, make unsolicited
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purchase o ers to timeshare owners;
(2) if o ers are accepted, scammers make requests to timeshare owners for payments of
advance fees and taxes, supposedly to facilitate or expedite the sale with assurances of
reimbursement upon closing; and
(3) once multiple payments have been made to the scammers, timeshare owners eventually
realize that the o ers were fictitious, that there are no buyers, and that their money is gone.

CONT INUING TO DISRUPT CJNGʼS T IMESHARE F RAUD
NET W ORK
Building on the two
actions taken earlier this
year, today OFAC
sanctioned additional
Mexican individuals and
companies pursuant to
E.O. 14059 that are linked,
directly or indirectly, to
CJNGʼs timeshare
activities. Many of these
individuals and entities
are located in Puerto
Vallarta, Jalisco, Mexico,
which is a CJNG strategic
stronghold for drug
tra icking and various other illicit activities.
Today, OFAC sanctioned Mexican individuals Teresa De Jesus Alvarado Rubio (Alvarado),
Manuel Alejandro Foubert Cadena (Foubert), and Gabriela Del Villar Contreras (Del Villar)
pursuant to E.O. 14059 for being owned, controlled, or directed by, or having acted or
purported to act for on behalf of, directly or indirectly, CJNG, a person sanctioned pursuant to
E.O. 14059. Alvarado has been linked to timeshare fraud activities in the Puerto Vallarta area
for approximately 15 years. Foubert has been linked to timeshare fraud activities in Puerto
Vallarta and elsewhere since at least 2016. Del Villar is a Puerto Vallarta attorney who engages
in debt collection and real estate fraud on behalf of CJNG.
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Also today, OFAC sanctioned 13 Mexican companies pursuant to E.O. 14059. OFAC sanctioned
Grupo Empresarial Epta, S.A. de C.V., which is purported to be engaged in real estate
activities, for being owned, controlled, or directed by, or having acted or purported to act for
or on behalf of, directly or indirectly, CJNG.
OFAC sanctioned the following nine companies—listed with their purported activities—for
being owned, controlled, or directed by, or having acted or purported to act for or on behalf
of, directly or indirectly, Foubert, a person sanctioned pursuant to E.O. 14059: Assis Realty
And Vacation Club, S.A. de C.V. (real estate activities), Axis Sale & Maintenance Buildings,
S.A. de C.V. (real estate activities), Comercializadora de Servicios Turisticos de Vallarta,
S.A. de C.V. (real estate activities), Condos & Vacations Buildings Sale & Maintenance, S.A.
de C.V. (real estate activities), Grupo Minera Barro Pacifico, S.A.P.I. de C.V. (mining),
International Realty & Maintenance, S.A. de C.V. (real estate activities), Mega Comercial
Ferrelectrica, S.A. de C.V. (wholesale trade), Real Estates & Holiday Cities, S.A. de C.V. (real
estate activities), and Terra Minas e Inversiones del Pacifico, S.A.P.I. de C.V. (mining).
OFAC sanctioned the following three Mexican companies—listed with their purported
activities—for being owned, controlled, or directed by, or having acted or purported to act for
or on behalf of, directly or indirectly, Del Villar, a person sanctioned pursuant to E.O. 14059:
Banlu Comercializadora, S.A. de C.V. (a.k.a. Cear Gym) (wholesale trade; sports club),
Crowlands, S.A. de C.V. (real estate activities), and Skairu, S.A. de C.V. (real estate
activities).

OT HER ACT IONS AGAINST CJNG
On April 8, 2015, OFAC sanctioned CJNG pursuant to the Foreign Narcotics Kingpin
Designation Act (Kingpin Act) for playing a significant role in international narcotics
tra icking. On December 15, 2021, OFAC also designated CJNG pursuant to E.O. 14059. In
other actions, OFAC has sanctioned numerous CJNG-linked companies that were engaged in
various commercial activities and multiple individuals who played critical roles in CJNGʼs drug
tra icking, money laundering, and corruption. Many recent actions have focused on CJNGʼs
strategic stronghold of Puerto Vallarta. OFAC has sanctioned the following senior CJNG
members based in Puerto Vallarta: Carlos Andres Rivera Varela (a.k.a. “La Firma”), Francisco
Javier Gudino Haro (a.k.a. “La Gallina”), and Julio Cesar Montero Pinzon (a.k.a. Luis Armando
Velazquez Baltazar; a.k.a. Cesar Hernandez Jimenez; a.k.a. “El Tarjetas”). These three

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individuals are part of a CJNG enforcement group based in Puerto Vallarta that orchestrates
assassinations of rivals and politicians using high-powered weaponry.

T IMESHARE F RAUD RESOURCES
On March 2, 2023, the FBI issued a public service announcement to consumers concerning
scammers targeting owners of timeshares in Mexico. Victims of this type of scam are
encouraged to file a complaint with the FBIʼs Internet Crime Complaint Center by
visiting https://www.ic3.gov.
At times, perpetrators of timeshare fraud misuse government agency names in attempts to
appear legitimate. For example, perpetrators may call victims and claim to represent OFAC,
demanding a payment in exchange for the release of funds that the perpetrator claims OFAC
has “blocked.” On March 2, 2023, OFAC issued an alert regarding such scams, warning that
individuals may falsely claim to represent OFAC in furtherance of their fraud.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated persons
described above that are in the United States or in the possession or control of U.S. persons
are blocked and must be reported to OFAC. In addition, any entities that are owned, directly
or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked
persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or
exempt, OFACʼs regulations generally prohibit all transactions by U.S. persons or 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 and the Kingpin Act.
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 is causing the deaths of tens of
thousands of Americans annually, as well as countless more 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.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List),
but also from its willingness to remove persons from the SDN List consistent with the law.
The ultimate goal of sanctions is not to punish, but to bring about a positive change in
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behavior. For information concerning the process for seeking removal from an OFAC list,
including the SDN List, please refer to OFACʼs Frequently Asked Question 897 here. For
detailed information on the process to submit a request for removal from an OFAC sanctions
list, please click here.
For more information on the individuals and entities designated today, click here.
To view a chart on the entities designated today, click here.
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