Key Takeaways 

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border. 
  • OFAC’s actions are the latest examples of a broader national security strategy to use sanctions, AML authorities, criminal prosecutions, and other tools to counter cartels on the U.S.-Mexico border. These efforts have targeted in particular non-traditional financial institutions such as casinos, public-facing professionals, and disinformation actors. 
  • The State Department designated CDN as a foreign terrorist organization (FTO) on February 20, 2026, and today’s designations were issued under both Executive Order 14059 (narcotics trafficking) and Executive Order 13224 (terrorism), underscoring the U.S. government’s treatment of major cartels as hybrid criminal-terrorist threats.

Overview of the Designations

On April 14, 2026, the U.S. Department of the Treasury announced OFAC sanctions targeting a money laundering and cash smuggling network operated by CDN, a U.S.-designated Foreign Terrorist Organization (FTO) with significant influence in Nuevo Laredo, located on the U.S.-Mexico border. Key designation targets include:

  • Casino Centenario and Diamante Casino, identified as vehicles for laundering illicit proceeds and facilitating cartel operations. The announcement notes that Casino Centenario is only two miles from the U.S. border and is known to have U.S. patrons;
  • Comercializadora y Arrendadora de Mexico (CAMSA), the operator of the casinos;
  • Senior cartel-linked individuals, including:
    • Eduardo Javier Islas Valdez (Islas), a coordinator of human smuggling operations along the Rio Grande;
    • Juan Pablo Penilla Rodriguez (Penilla), a defense attorney acting as an intermediary for imprisoned CDN member to current CDN leadership; and
    • Jesus Reymundo Ramos Vazquez (Ramos), a CDN associate purported who leads CDN disinformation campaigns supporting cartel interests while purporting to be a “human rights activist.” enTreasury also issued General License (GL) 35, authorizing wind-down transactions through May 13, 2026, involving Casino Centenario, Diamante Casino, or CAMSA, or any entity in which one or more of the foregoing three designated entities owns a 50 percent or greater interest.

While OFAC has long targeted cartel leadership and trafficking networks, this action is notable for its focus on professional enablers — an attorney and disinformation “influence” for the cartel — and on specific vehicles for the laundering of funds, in the form of the sanctioned casinos.

Broader Enforcement Trend

This action is the latest in a series of coordinated U.S. Government measures targeting cartels and their financial infrastructure. For example:

  • On November 13, 2025, FinCEN issued a finding and notice of proposed rulemaking (NPRM) that identified transactions involving ten identified Mexico-based gambling establishments to be of “primary money laundering concern. This action was taken concurrently with OFAC designations that sanctioned members of a criminal group that used the establishments to launder the proceeds of narcotics trafficking in collaboration with the Sinaloa Cartel.
  • On July 3, 2025, FinCEN issued orders pursuant to the Fentanyl Sanctions Act and FEND Off Fentanyl Act determining that three Mexican financial institutions are “of primary money laundering concern in connection with illicit opioid trafficking,” which orders effectively excluded the three financial institutions from the U.S. financial system.
  • On March 10, 2025, FinCEN issued an expanded Geographic Targeting Order (GTO) that requires money services businesses (MSBs) to file Currency Transaction Reports with FinCEN for cash transactions between $1,000 and $10,000 occurring in specific U.S. counties and ZIP codes located near the U.S-Mexico border, intended to help law enforcement identify efforts to structure transactions to evade existing currency reporting requirements
  • On February 20, 2025, the U.S. State Department designated eight international criminal organizations as Foreign Terrorist Organizations (FTOs), including several entities operating in Mexico. See more on this development from Crowell’s past client alert here. The State Department has identified several other cartels and international criminal organizations as FTOs since then. The use of terrorism authorities expands potential criminal liability associated with support for these groups, and also can give rise to civil liability in suits by private plaintiffs against persons that aid them.

Practical Considerations

Financial institutions, FinTechs, and companies with operations or transactions involving Mexico or with other cross-border exposure may wish to consider:

  • Enhanced screening and Customer Due Diligence (CDD) for gaming companies and non-traditional financial institution counterparties in Mexico, particularly near border regions.
  • Reviewing customer profiles tied to pro-cartel legal, media, or advocacy roles in high-risk jurisdictions, and conducting Enhanced Due Diligence (EDD) for high-risk customers.
  • Reassessing exposure to cash-intensive businesses that may serve as laundering conduits.

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Photo of Dmitry Bergoltsev Dmitry Bergoltsev

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works…

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works closely with attorneys to develop practical solutions for clients facing challenges before the Office of Foreign Assets Control (OFAC), U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), and other federal agencies. Dmitry’s key areas of focus include advising clients on sanctions and export controls compliance, U.S. import and export regulations, and supply chain due diligence, with particular attention to the geopolitical and regulatory risks our clients face when operating across global markets.

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Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

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For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

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