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NOTIFICATION OF BLOCKING OF A THIRD PERSON
ENF 43092
Jessica Johanna Oseguera Gonzalez
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Dear Ms. Oseguera Gonzalez:
You are hereby notified that on April 8, 2015, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Abigael Gonzalez Valencia, Nemesio Oseguera Cervantes, Los Cuinis, and Cartel de Jalisco Nueva Generacion as Specially Designated Narcotics Traffickers (SDNTs) pursuant to the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. §§ 1901-1908, 8 U.S.C. § 1182 (the "Kingpin Act"), which is implemented by the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598, and the Reporting, Procedures and Penalties Regulations, 31 C.F.R. part 501 (collectively, the "Regulations"). A copy of the press release announcing these designations is enclosed.
OFAC has reason to believe that you are a U.S. person[1] subject...
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1) This “Notification of Blocking of a Third Person” was sent to the daughter of Abigael Gonzalez Valencia, who was the leader of the Jalisco New Generation Cartel. Both Gonzalez Valencia and the cartel were designated pursuant to the FNKDA on April 8, 2015, as was the recipient’s uncle. The recipient of the notice, Oseguera Gonzalez, is a dual Mexican-U.S. citizen that, at the time the notice was sent, lived full time in Mexico with intermittent travel to the U.S. [1]
2) A U.S. PERSON'S "NON-ECONOMIC" ACTIVITIES INVOLVING BLOCKED PERSONS
A significant gray area of sanctions law is the extent to which sanctions laws cover “personal relationships” between U.S. persons and sanctioned individuals. Note that the FNKSR has no general license for “personal communications.” In An Unnamed...