Markets Wired

Action Taken in Coordination with Partners in U.S. and Mexico 

WASHINGTON — Today Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Abdul Karim Conteh Human Smuggling Organization (Karim HSO), a transnational criminal organization (TCO) based in Tijuana, Mexico. Human smuggling is a federal crime in which criminals smuggle noncitizens into the United States, as well as transport and harbor noncitizens already in the country illegally, all in deliberate violation of U.S. immigration laws. Together with Department of Homeland Security and Department of Justice components, and other U.S. and foreign partners, OFAC targets these networks to disrupt their finances and illicit profits and ultimately dismantle their operations, which threaten the national security of the United States.

“Today’s action, in close partnership with our U.S. and international partners, disrupts the ability of those seeking to exploit and endanger desperate individuals in search of a better life for themselves and their loved ones,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury, as part of the Administration’s effort to address the crisis on our Southwest border, remains committed to using our tools to degrade the ability of groups like the Karim HSO to engage in these illicit operations.”

Today’s action would not have been possible without the cooperation, support, and ongoing collaboration between OFAC, the U.S. Attorney’s Office for the Southern District of California, the Human Rights and Special Prosecutions Section of the Department of Justice, U.S. Border Patrol, San Diego Sector’s Anti-Smuggling Unit, Homeland Security Investigations (HSI) San Diego, the HSI Human Smuggling Unit, Internal Revenue Service – Criminal Investigations, the Federal Bureau of Investigation, and U.S. Customs and Border Protection’s National Targeting Center International Interdiction Task Force. This designation was enabled by key data from Treasury’s Financial Crimes Enforcement Network (FinCEN).

Additionally, OFAC coordinated this action with the Government of Mexico, including La Unidad de Inteligencia Financiera (UIF), Mexico’s Financial Intelligence Unit.

DISRUPTING THE ABDUL KARIM CONTEH HUMAN SMUGGLING ORGANIZATION

In violation of U.S. immigration laws, the Tijuana, Mexico-based Karim HSO for years has smuggled migrants into the United States for its own financial gain. In addition to providing migrants with fraudulent documents, members of the Karim HSO leverage the U.S. financial system to receive payments for their illicit smuggling operations. The Karim HSO’s standard methodology is to transport migrants to the United States border and advise them on how to cross the border illegally. The Karim HSO’s reach extends both regionally and globally; for example, the Karim HSO maintains affiliations in, and has coordinated the movement of migrants through, Nicaragua. 

 

Sierra Leonean national Abdul Karim Conteh (Karim), the leader of the human smuggling organization sanctioned today, is responsible for smuggling thousands of migrants from Africa, China, the Middle East, Russia, Central Asia, and other jurisdictions into the United States. Karim’s wife, Mexican national Veronica Roblero Pivaral (Veronica), plays a variety of critical roles in the organization, ranging from driving migrants to the U.S. border to receiving payments for smuggling operations. 

Images of Karim and Veronica, both of whom have used false identities in their illicit activity

In addition to Karim and Veronica, OFAC today sanctioned Togolese national Pasaman Francis Marin Abbe Pidoukou (Pasaman) and Sierra Leonean national Issa Kamara (Issa). Both members of the Karim HSO, Pasaman and Issa are responsible for facilitating the transport of migrants for the Karim HSO. 

Treasury’s sanctions also complement an indictment returned by a federal grand jury sitting in the U.S. Attorney’s Office for the Southern District of California. For information on actions previously taken by the U.S. Department of Justice, please see this link.

OFAC’s action today sanctioned the Karim HSO pursuant to Executive Order (E.O.) 13581, as amended by E.O. 13863 (hereafter, “E.O. 13581, as amended”), for being a foreign person that constitutes a significant TCO. OFAC sanctioned Karim, Veronica, Pasaman, and Issa pursuant to E.O. 13581, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the Karim HSO. 

PREVIOUS TREASURY ACTIONS AGAINST HUMAN SMUGGLING ORGANIZATIONS

Today’s action builds on actions that OFAC has taken in the last year to address the national security threat posed by human smuggling. For example, on July 11, 2024, OFAC sanctioned Tren de Aragua pursuant to E.O. 13581, as amended. Tren de Aragua is a Venezuela-based TCO engaging in human smuggling and trafficking, gender-based violence, money laundering, illicit drug trafficking, and other criminal activities.

On December 14, 2023, OFAC sanctioned the Malas Mañas TCO and several members pursuant to E.O. 13581, as amended. The Malas Mañas TCO is a human smuggling and narcotics trafficking organization based in Sonora, Mexico, with operations across the Southwest Border.

Additionally, on June 16, 2023, OFAC sanctioned the Hernandez Salas TCO and its leader, among others, pursuant to E.O. 13581, as amended. The Hernandez Salas TCO, based in Mexicali, Mexico, has facilitated thousands of illegal entries into the United States since at least 2018. 

Furthermore, on January 13, 2023, FinCEN issued an alert providing trends, typologies, and red flag indicators to help financial institutions better identify and report transactions potentially related to human smuggling along the U.S. Southwest Border. This alert followed an increase in attempted illegal border crossings in 2021 and 2022.

SANCTIONS IMPLICATIONS

As a result of today’s 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, OFAC’s 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. 13581, as amended.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entity and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person. 

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the 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 behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s 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 entity designated today, click here.

###