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September 18, 2020

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September 17, 2020

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U.S. Sanctions Mexican Executive, Airline, and Newspaper Tied to Drug Trafficking Organization

On Dec. 16, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a Mexican national, Naim Libien Tella, and four Mexican entities linked to Libien Tella, under the Kingpin Act. The new designations, which include a Mexican airline and newspaper, stem from Libien Tella’s narco-trafficking activities in association with the Los Cuinis cartel.

The sanctioned individual and entities now listed on OFAC’s Specially Designated Nationals (SDN) List are:

  • LIBIEN TELLA, NAIM, of Toluca, Mexico;

  • AEROLINEAS AMANECER, S.A. DE C.V. (aka AEROAMANECER), of Mexico City, Mexico;

  • DIARIO AMANECER, of Mexico City, Mexico;

  • UNOMASUNO (aka UNO MAS UNO), of Mexico City, Mexico; and

  • VALGO GRUPO DE INVERSION S.A. DE C.V., of Guadalajara, Mexico.

Under the Kingpin Act and other sanctions programs, U.S. persons are prohibited from dealings with individuals and entities named on OFAC’s SDN List.  More challenging from a compliance standpoint, however, U.S. persons are likewise prohibited from dealings with entities that are not specifically enumerated on the SDN List, but are owned 50% or more in the aggregate by any designated entities or individuals.

Even non-U.S. individuals and entities that have had business dealings with the recently-designated Kingpin Act entities and individual should carefully review their relationships and assess the potential risk for future interactions or transactions. Although the Kingpin Act designation does not bar all transactions, and generally addresses only assets or transactions in the United States or in the possession or control of U.S. persons, a violation of the Kingpin Act can result in both criminal and civil enforcement in the United States. Additionally, entities or individuals that are deemed to be providing material support to any designated individuals or entities run the risk of becoming the target of U.S. sanctions themselves.

©2020 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume V, Number 353


About this Author

Kara Bombach, Greenberg Traurig, Washington DC, International Trade and White Collar Defense Attorney

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals....

Cyril Brennan, Greenberg Traurig Law Firm, Washington DC, International Trade Law Attorney

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s anti-boycott regulations. In addition, he represents clients before the Committee on Foreign Investment in the United States (CFIUS), and advises clients on the Foreign Corrupt Practices Act (FCPA), the foreign direct investment reporting requirements of the Bureau of Economic Analysis (BEA), and other trade and investment-related regulations in the context of mergers and acquisitions.


  • Export controls and economic sanctions

  • Committee on Foreign Investment in the United States (CFIUS)

  • Anticorruption compliance

  • Foreign direct investment reporting

  • Regulatory due diligence

  • Foreign ownership, control or influence (FOCI)