DLA Piper

Written by: Nereida Melendez-Rivera, Sonia Torres Pabón, Antonio Cardenas Arriola, Isabel Lecompte The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced significant new sanctions targeting two major Mexican criminal organizations – Carteles Unidos and Los Viagras – along with seven affiliated individuals. These actions are part of a broader US government effort to disrupt the operations of cartels responsible for violence, drug trafficking, terrorism, and widespread extortion, particularly in Mexico’s agricultural sector. In this alert, we highlight the designated entities and individuals targeted by the sanctions. In addition, we discuss legal and compliance implications and set out key takeaways for companies that may be exposed to risk from the sanctions. Background on the sanctioned organizations Carteles Unidos Carteles Unidos originated in Michoacán, México as a defensive alliance against the Jalisco Nueva Generación Cartel (CJNG). It has since evolved into a major criminal enterprise. Its activities include large-scale drug production and trafficking, extortion, arms smuggling, and violent confrontations with both rival organizations and authorities. The group is primarily active in central and western Mexico, but its influence is expanding transnationally. The US government has designated Carteles Unidos as a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT), and it is subject to extensive US sanctions due to its involvement in illicit activities. Los Viagras Los Viagras is a Michoacán-based criminal organization involved in trafficking methamphetamine and cocaine. In its conflict for control of Michoacán, Los Viagras has recently allied with CJNG, one of the two Mexican cartels primarily responsible for the supply of illicit fentanyl into the US. Furthermore, Los Viagras has extorted avocado and citrus growers, cattle ranchers, and entire towns to generate revenue. Los Viagras has also conducted kidnappings and attacked Mexican security forces. Sanctioned individuals The following individuals have been sanctioned for their affiliation with the above-mentioned organizations: Juan Jose Farías Álvarez (“El Abuelo”) Luis Enrique Barragán Chavez (“Wicho”) Alfonso Fernández Magallón (“Poncho”) Edgar Valeriano Orozco Cabadas (“El Kamoni”) Nicolás Sierra Santana (“El Gordo”) Heladio Cisneros Flores (“La Sirena”) César Alejandro Sepúlveda Arellano (“El Botox”) Legal and compliance implications As a result of the sanctions, all property and interests in property of the designated entities and individuals within the US or in the possession or control of US persons are now blocked and must be reported to OFAC. US persons are generally prohibited from engaging in transactions involving these blocked persons or their property. Entities that are owned 50 percent or more, directly or indirectly, by one or more blocked persons are also subject to these restrictions. Violations of these sanctions can result in significant civil or criminal penalties. OFAC may impose civil penalties on a strict liability basis, which means that a violation can result in penalties even if there was no intent to violate the sanctions. Financial institutions and other parties may also face secondary sanctions for facilitating significant transactions with designated persons. Key considerations In response to potential violation of these sanctions, entities may consider the following actions: Reviewing all third-party relationships to identify potential exposure or risks related to the newly sanctioned organizations and persons Conducting enhanced due diligence on business relationships and transactions involving México, especially in regions or industries known to be affected by cartel activity Updating and strengthening compliance protocols, particularly for operations and transactions involving Latin America and México Monitoring for additional designations and regulatory changes, as the enforcement landscape is evolving rapidly and new sanctions may be announced at any time In addition, foreign financial institutions should be aware of the risk of secondary sanctions for knowingly facilitating significant transactions for or on behalf of designated entities or persons. For guidance on risk mitigation and compliance strategies, please contact the authors. Leer este artículo en español.

August 1, 2025 – DLA Piper advised Grupo Cox (Cox), a leading Spanish multinational water and energy company, in its acquisition of Iberdrola’s assets in Mexico for US$4.2 billion – one of the largest cross-border energy deals of the year. “We appreciated the opportunity to work with the Cox team on this landmark acquisition and look forward to advising the company on its future cross-border initiatives,” said Francisco J. Cerezo, Chair of the US-Latin America and Ibero-Américan practices, who co-led the deal team. “I want to express my deep appreciation for the service provided in this transaction by the DLA Piper team, led by Francisco Cerezo and Mauricio Valdespino,” said Antonio Medina Cuadros, Chief Legal Officer and Secretary General of Grupo Cox. “Their professionalism and tireless work ethic went far beyond what one could expect from legal counsel. Without a doubt, their outstanding effort and dedication were among the key factors in the success of this complex transaction.” In addition to Cerezo (Miami), the cross-border DLA Piper team was co-led by Partner Mauricio Valdespino (Mexico City) and included Partners Edgar Romo, Guillermo Aguayo, Roberto Ríos (all Mexico City), Robert da Silva Ashley (Miami), Michael McGuiness, Amadeu Ribeiro, Frank Mugabi (all New York), Yoko Takagi (Madrid), and Senior Associate Joseline Rodriguez (Miami), and Associates Eduardo Gallástegui, Regina Esparza, and Manuel Domínguez (all Mexico City), among a team of more than 40 DLA Piper attorneys. With more than 1,000 corporate lawyers globally, DLA Piper helps clients execute complex transactions seamlessly while supporting clients across all stages of development. The firm has been rated number one in global M&A volume for 15 consecutive years, according to Mergermarket, and ranked as number one in VC, PE, and M&A in combined global deal volume, according to PitchBook. DLA Piper in Latin America’s team offers full-service business legal counsel to domestic and multinational companies with interests in and operations throughout the region. Our integrated approach to serving clients combines local knowledge with the resources of the DLA Piper global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, in addition to our US-based cross-border attorneys, our teams frequently work with our professionals throughout the LatAm region, Iberian Peninsula, and around the globe. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve all our clients’ legal and business needs, whether they are based in Latin America or wish to do business there.  For more information, visit Latin America | DLA Piper The firm recently received the highest ranking for law firm client service in the BTI Client Service A-Team 2025 report, which identifies law firms providing exceptional service based on client feedback. About DLA Piper DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa, and Asia Pacific, positioning us to help clients with their legal needs around the world. In certain jurisdictions, this information may be considered attorney advertising. dlapiper.com Contact Geneva Youel, Media Relations, DLA Piper, +1 213 330 7779

August 1, 2025 – DLA Piper advised Grupo Cox (Cox), a leading Spanish multinational water and energy company, in its acquisition of Iberdrola’s assets in Mexico for US$4.2 billion – one of the largest cross-border energy deals of the year. “We appreciated the opportunity to work with the Cox team on this landmark acquisition and look forward to advising the company on its future cross-border initiatives,” said Francisco J. Cerezo, Chair of the US-Latin America and Ibero-Américan practices, who co-led the deal team. “I want to express my deep appreciation for the service provided in this transaction by the DLA Piper team, led by Francisco Cerezo and Mauricio Valdespino,” said Antonio Medina Cuadros, Chief Legal Officer and Secretary General of Grupo Cox. “Their professionalism and tireless work ethic went far beyond what one could expect from legal counsel. Without a doubt, their outstanding effort and dedication were among the key factors in the success of this complex transaction.” In addition to Cerezo (Miami), the cross-border DLA Piper team was co-led by Partner Mauricio Valdespino (Mexico City) and included Partners Edgar Romo, Guillermo Aguayo, Roberto Ríos (all Mexico City), Robert da Silva Ashley (Miami), Michael McGuiness, Amadeu Ribeiro, Frank Mugabi (all New York), Yoko Takagi (Madrid), and Senior Associate Joseline Rodriguez (Miami), and Associates Eduardo Gallástegui, Regina Esparza, and Manuel Domínguez (all Mexico City), among a team of more than 40 DLA Piper attorneys. With more than 1,000 corporate lawyers globally, DLA Piper helps clients execute complex transactions seamlessly while supporting clients across all stages of development. The firm has been rated number one in global M&A volume for 15 consecutive years, according to Mergermarket, and ranked as number one in VC, PE, and M&A in combined global deal volume, according to PitchBook. DLA Piper in Latin America’s team offers full-service business legal counsel to domestic and multinational companies with interests in and operations throughout the region. Our integrated approach to serving clients combines local knowledge with the resources of the DLA Piper global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, in addition to our US-based cross-border attorneys, our teams frequently work with our professionals throughout the LatAm region, Iberian Peninsula, and around the globe. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve all our clients’ legal and business needs, whether they are based in Latin America or wish to do business there.  For more information, visit Latin America | DLA Piper The firm recently received the highest ranking for law firm client service in the BTI Client Service A-Team 2025 report, which identifies law firms providing exceptional service based on client feedback.   About DLA Piper DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa, and Asia Pacific, positioning us to help clients with their legal needs around the world. In certain jurisdictions, this information may be considered attorney advertising. dlapiper.com   Contact Geneva Youel, Media Relations, DLA Piper, +1 213 330 7779