ARTICLE
26 August 2019

OFAC Sanctions China-Based Drug Trafficking Organization

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Cadwalader, Wickersham & Taft LLP

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OFAC designated the China-based Zheng Drug Trafficking Organization ("Zheng DTO") and Chinese nationals Zheng Fujing and Yan Xiaobing
Worldwide International Law
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OFAC designated the China-based Zheng Drug Trafficking Organization ("Zheng DTO") and Chinese nationals Zheng Fujing and Yan Xiaobing, identifying them as "significant foreign narcotics traffickers[s]" under the Foreign Narcotics Kingpin Designation Act. OFAC also designated Chinese national Zheng Guanghua for his involvement with the Zheng DTO, and the Chinese entity Qinsheng Pharmaceutical Co. Ltd. because of Zheng Fujing's ownership of the business.

According to OFAC, Zheng Fujing and Yan Xiaobing shipped hundreds of packages of synthetic opioids to the United States using commercial mail carriers. In connection with its action against Zheng and Yan, OFAC identified bitcoin addresses associated with these two individuals "to maximize disruption of their financial dealings."

As a result of OFAC's action, all property and interests in property of the designated individuals and entities in the United States, or in the possession or control of U.S. persons, must be blocked and reported to OFAC. In addition, OFAC regulations generally forbid all dealings by U.S. persons, and all transactions that occur within or transiting the United States, that involve the property or interests in property of blocked individuals or entities.

In a related advisory, the Financial Crimes Enforcement Network alerted financial institutions to conduct that is potentially indicative of criminal actors using financial schemes to traffic fentanyl and other synthetic opioids.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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