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 TREASURY DESIGNATES NETWORK OF CALI DRUG CARTEL FRONT COMPANIES


10/17/2003
   

FROM THE OFFICE OF PUBLIC AFFAIRS

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WASHINGTON -- The Treasury Department�s Office of Foreign Assets Control (OFAC) today added 39 businesses acting as front companies for the Cali drug cartel based in Colombia and 95 individuals associated with the cartel, and its activities through front companies, to its list of Specially Designated Narcotics Traffickers (SDNTs).  Through a network of pharmaceutical businesses, the cartel has laundered money and has penetrated the Colombian economy.  These front companies form a vital part of the Cali cartel�s international money laundering network.  This action freezes their assets and prohibits financial and commercial transactions with U.S. nationals.  The Treasury Department will continue to work with Colombian authorities on further actions to shut down the cartel�s financial network.

�Today�s action demonstrates the Cali cartel�s continued use of pharmaceutical companies throughout Latin America and the Caribbean to launder drug money and to penetrate the legitimate economy,� stated OFAC Director Rick Newcomb.  �The U.S. banking and pharmaceutical sectors should renew their vigilance against providing financial services or supplying products to these front companies.�

Included among the 39 businesses designated today are Interfarma/Jomaga de Costa Rica in Costa Rica, Latinfarmacos and Espibena in Ecuador, Colfarma Peru in Peru, Premier Sales in Panama, and C.A. V.J. Corporation in Venezuela, all affiliated with the international drug distribution of Cali cartel pharmaceutical laboratories Pentacoop and Farmacoop on the SDNT list.  Also named today are numerous financial fronts in Colombia, such as Coopdisan, Drofarco, and Incommerce, which are created by the Cali cartel using trusted corporate officers to provide bank account services to its business fronts. Inversiones Carfeni and two internet companies in Spain and Ash Trading Inc. in the United States were also named.  Today�s action is a follow-up to sanction actions directed against the Cali cartel in February and March of this year.

The international network of 39 Cali cartel fronts named today join 340 other Colombian drug cartel businesses on the SDNT list.  The list includes Cali cartel businesses Copservir, and its Drogas La Rebaja drugstore chain and Credirebaja charge card, the Obursatiles stock brokerage and Internacional de Divisas money exchange house, the Cosmepop cosmetics company, the America de Cali professional soccer team, as well as consulting, investment, financial, construction, real estate, agricultural, and distribution firms.

This action is part of the ongoing interagency effort of the Treasury, Justice, State, and Homeland Security Departments to carry out Executive Order 12978, signed on October 21, 1995, which applies economic sanctions against Colombia�s drug cartels. The assets of a total of 958 Colombian drug cartel businesses and individuals are now blocked under the 1995 Executive Order; and those businesses and individuals are prohibited from American financial and business dealings. The list of SDNTs includes 14 kingpins from Colombia�s Cali, North Valle, and North Coast drug cartels.

A fact sheet and diagram listing the businesses and individuals named by OFAC as SDNTs today is attached.

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FACT SHEET:
Cali Cartel international network of front companies and individuals

The United States government has named 134 additional companies and persons as Specially Designated Narcotics Traffickers (�SDNTs�).  Based upon available information, we have reason to believe that Gilberto and Miguel Rodriguez Orejuela, leaders of the infamous Cali drug cartel that operates out of Cali, Colombia, own or control various companies in the Bahamas, the British Virgin Islands, Colombia, Costa Rica, Ecuador, Peru, Spain, the United States, and Venezuela through a network of individuals who act for or on their behalf. Gilberto Rodriguez Orejuela and Miguel Rodriguez Orejuela were named as SDNTs on October 21, 1995 pursuant to Executive Order 12978. This international network of companies centers around Rodriguez Orejuela family members and a cadre of trusted business associates, including Colombian, Spanish, Peruvian, and Venezuelan nationals. These individuals are the administrators and shareholders of this network of companies and act for or on behalf of Gilberto and Miguel Rodriguez Orejuela in their business dealings.  Also, this international network of companies is interconnected to Cali cartel front companies established in Colombia.
By this action, 25 companies in Colombia, three companies in Spain, two companies in Ecuador, two companies in the Bahamas, two companies in the British Virgin Islands, one company in Costa Rica, one company in Panama, one company in Peru, one company in Venezuela, one company in the United States, 93 Colombian nationals, one Peruvian national, and one Venezuelan national, associated with the Cali cartel in Colombia, will now be prohibited from transactions with U.S. persons and will have their assets blocked as part of U.S. sanctions against significant narcotics traffickers centered in Colombia.
What follows is an unclassified summary of information concerning the network of 13 companies and 2 individuals outside of Colombia and the United States. We believe that the information is reliable and, taken as a whole, supports the decision to block their assets. This designation marks the first listing of companies and individuals from the Bahamas, the British Virgin Islands, Costa Rica, Peru, and Venezuela as SDNTs pursuant to Executive Order 12978, which began with the designation of four Cali cartel leaders as SDNTs on October 21, 1995.
 


Companies     Individuals
  25 in Colombia      93 Colombian nationals
  3 in Spain            -
   2 in the Bahamas       -
   2 in the British Virgin Islands -
   2 in Ecuador        -
   1 in Costa Rica         -
   1 in Peru        1 Peruvian national
   1 in Panama        -
   1 in the United States      -
          1 in Venezuela         1 Venezuelan national
    
  39 Total companies         95 Total individuals


COMPANIES IN THE BAHAMAS

ARDILA-MARMOLEJO, LTD.,
(f.k.a. HUYO-GIRALDO, LTD.),
Nassau, Bahamas;
Business Registration No. 88,046 B (Bahamas)

ARDILA-MARMOLEJO, LTD., f.k.a. HUYO-GIRALDO, LTD., is an off-shore holding company based in the Bahamas.  Luis Alejandro ARDILA HUYO, a Colombian national, is the president and treasurer of ARDILA-MARMOLEJO, LTD.  In February 2003, Luis Alejandro ARDILA HUYO was named as an SDNT in Colombia pursuant to Executive Order 12978.  Luis Alejandro ARDILA HUYO also is a director and shareholder in Cali cartel front companies in Colombia.
Because ARDILA-MARMOLEJO, LTD., f.k.a. HUYO-GIRALDO, LTD., is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

SEPULVEDA-IRAGORRI, LTD.,
Calle 6 Oeste No. 4-200 apt. 202, Cali, Colombia;
Nassau, Bahamas;
(Bahamas)

SEPULVEDA-IRAGORRI, LTD. is an off-shore holding company based in the Bahamas.  In addition to being owners of SEPULVEDA-IRAGORRI, LTD., Efrain Hernan SEPULVEDA ZAPATA and Maria Consuelo IRAGORRI TORRES, Colombian nationals, are president and secretary of the company, respectively.  In March 2003, both Efrain Hernan SEPULVEDA ZAPATA and Maria Consuelo IRAGORRI TORRES were named as SDNTs in Colombia pursuant to Executive Order 12978.  Efrain Hernan SEPULVEDA ZAPATA and Maria Consuelo IRAGORRI TORRES also are directors and shareholders in Cali cartel front companies in Colombia.
Because SEPULVEDA-IRAGORRI, LTD. is owned or controlled by individuals who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

B. COMPANIES IN THE BRITISH VIRGIN ISLANDS

KESMAN OVERSEAS,
3rd Floor, Geneva Place, Waterfront Drive, Road Town, Tortola, British Virgin Islands


KESMAN OVERSEAS is an off-shore holding company based in the British Virgin Islands.  Rodrigo Jose SARASTI GUERRERO, a Colombian national, is an officer of KESMAN OVERSEAS.  Rodrigo Jose SARASTI GUERRERO also is the general manager and shareholder in a Cali cartel front company in Colombia.
Because KESMAN OVERSEAS is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

ZARATAN CORPORATION,
Vanterpool Plaza, P.O. Box 873, Wickhams Cay I, Road Town, Tortola, British Virgin Islands;
Avenida 4 Norte No. 4N-30, Cali, Colombia;
Calle 7 Oeste No. 1-13, Cali, Colombia

ZARATAN CORPORATION is an off-shore holding company based in the British Virgin Islands.  Rodrigo Jose SARASTI GUERRERO, a Colombian national, is an officer and 50 percent shareholder of KESMAN OVERSEAS.  Rodrigo Jose SARASTI GUERRERO also is the general manager and shareholder in a Cali cartel front company in Colombia.
Because ZARATAN CORPORATION is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.


C. COMPANY IN COSTA RICA

JOMAGA DE COSTA RICA S.A.,
(a.k.a. INTERFARMA S.A.),
200 Norte y 25 Oeste del Restaurante Tierra Colombiana,
San Francisco de Dos Rios, San Jose, San Jose, Costa Rica;
Numero Judicial # 3-101-76327 (Costa Rica)

 JOMAGA DE COSTA RICA S.A., a.k.a. INTERFARMA S.A., is a pharmaceutical distributor based in San Jose, Costa Rica. Fernando VILLOTA GALVIS, a Colombian national, is the treasurer of JOMAGA DE COSTA RICA S.A., a.k.a. INTERFARMA S.A.  In April 1997, Fernando VILLOTA GALVIS was named as an SDNT in Colombia pursuant to Executive Order 12978.  Fernando VILLOTA GALVIS also is an officer and director in Cali cartel front companies in Colombia.  In addition, Giovanny Mauricio LARA SANCHEZ and Sonia Viviana FORERO SALAMANCA, both Colombian nationals, are president and secretary of JOMAGA DE COSTA RICA S.A., a.k.a. INTERFARMA S.A., respectively.  Giovanny Mauricio LARA SANCHEZ and Sonia Viviana FORERO SALAMANCA also are employees in a Cali cartel front company in Colombia.  Further, JOMAGA DE COSTA RICA S.A., a.k.a. INTERFARMA S.A., has a financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA., a Cali cartel front company based in Colombia.  MATERIAS PRIMAS Y SUMINISTROS LTDA. was named as an SDNT in Colombia pursuant to Executive Order 12978 in February 2003.
   Because JOMAGA DE COSTA RICA S.A., a.k.a. INTERFARMA S.A., is owned or controlled by individuals and a front company who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.


D. COMPANIES IN ECUADOR

ESPIBENA COMERCIALIZADORA DE MEDICAMENTOS GENERICOS S.A.,
(a.k.a. ESPIBENA S.A.),
Luis Cordero 1154 y Juan Leon Mera, Edificio Gabriela Mistral,
Quito, Ecuador;
RUC # 1791706420001 (Ecuador)

 ESPIBENA COMERCIALIZADORA DE MEDICAMENTOS GENERICOS S.A., a.k.a. ESPIBENA S.A., is a pharmaceutical distributor based in Quito, Ecuador.  William Edison JIMENEZ MARIN, a Colombian national, is the manager of ESPIBENA S.A.  William Edison JIMENEZ MARIN also is an officer and employee in Cali cartel front companies in Colombia.  In addition, ESPIBENA S.A. has a significant financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA. and PENTACOOP, both Cali cartel front companies based in Colombia.  MATERIAS PRIMAS Y SUMINISTROS LTDA. and PENTACOOP were named as SDNTs in Colombia pursuant to Executive Order 12978 in February 2003 and April 1997, respectively.
 Because ESPIBENA COMERCIALIZADORA DE MEDICAMENTOS GENERICOS S.A., a.k.a. ESPIBENA S.A., is owned or controlled by an individual and front companies who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

LATINOAMERICANA DE FARMACOS S.A.,
(a.k.a. LATINFARMACOS S.A.),
(a.k.a. FARMACIA AMAZONAS),
(a.k.a. FARMACIA DORAL),
(a.k.a. FARMACIA JARDIN SUR),
(a.k.a. FARMACIA LA COLINA),
(a.k.a. FARMACIA PROVIDA),
Av. 10 de Agosto 2753 y Gral. Vicente Aguirre, Edificio Freile Ardiani, Quito, Ecuador;
Av. Amazonas 244 y Jorge Washington, Quito, Ecuador;
Av. Amazonas 1134 y General Foch, Quito, Ecaudor;
Av. Rodrigo de Chavez 387, Quito, Ecaudor;
Gualberto Perez 633 y Andres Perez, Quito, Ecuador;
Michelena y Mariscal Sucre, Quito, Ecuador;
Tres de Julio y Cuenca, Santo Domingo, Ecuador;
Ambato, Ecuador;
Cayambe, Ecuador;
El Carmen, Ecuador;
Tulcan, Ecuador;
Quito, Ecuador;
RUC # 1791286812001 (Ecuador)

 LATINOAMERICANA DE FARMACOS S.A., a.k.a. LATINFARMACOS S.A., a.k.a. FARMACIA AMAZONAS, a.k.a. FARMACIA DORAL, a.k.a. FARMACIA JARDIN SUR, a.k.a. FARMACIA LA COLINA, a.k.a. FARMACIA PROVIDA, is a pharmaceutical distributor and drug store chain based in Quito, Ecuador.  Colombian national Ruben Dario RESTREPO HERNANDEZ, and Rodriguez Orejuela family members Soraya MUNOZ RODRIGUEZ, Juan Carlos MUNOZ RODRIGUEZ, Jaime RODRIGUEZ MONDRAGON, and Humberto RODRIGUEZ MONDRAGON are officers and shareholders in LATINOAMERICANA DE FARMACOS S.A.  Ruben Dario RESTREPO HERNANDEZ was named as an SDNT in Colombia pursuant to Executive Order 12978 in April 1997, while Soraya MUNOZ RODRIGUEZ, Juan Carlos MUNOZ RODRIGUEZ, Jaime RODRIGUEZ MONDRAGON, and Humberto RODRIGUEZ MONDRAGON were named as SDNTs in Colombia pursuant to Executive Order 12978 in October 1995. Ruben Dario RESTREPO HERNANDEZ, Soraya MUNOZ RODRIGUEZ, Juan Carlos MUNOZ RODRIGUEZ, Jaime RODRIGUEZ MONDRAGON, and Humberto RODRIGUEZ MONDRAGON also are officers/directors/shareholders in Cali cartel front companies in Colombia.  In February 2002, Colombian authorities released a bulletin announcing the investigation of Humberto RODRIGUEZ MONDRAGON on charges of money laundering.  In addition, LATINOAMERICANA DE FARMACOS S.A. is administered jointly with RIONAP S.A., a Cali cartel front company also based in Quito, Ecuador.  RIONAP S.A. was named as an SDNT in Colombia pursuant to Executive Order 12978 in March 1996.
 Because LATINOAMERICANA DE FARMACOS S.A., a.k.a. LATINFARMACOS S.A., a.k.a. FARMACIA AMAZONAS, a.k.a. FARMACIA DORAL, a.k.a. FARMACIA JARDIN SUR, a.k.a. FARMACIA LA COLINA, a.k.a. FARMACIA PROVIDA, is owned or controlled by individuals and a front company who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

E. COMPANY IN PANAMA

PREMIER SALES S.A.,
Avenida Ernesto T. Lefevre, Planta Baja, Panama, Panama;
P.O. Box 4064, Zona 5 Panama, Panama;
(Panama)

 PREMIER SALES S.A. is a pharmaceutical distributor based in Panama City, Panama.  PREMIER SALES S.A. has a significant financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA. and PENTACOOP, both Cali cartel front companies based in Colombia.  MATERIAS PRIMAS Y SUMINISTROS LTDA. and PENTACOOP were named as SDNTs in Colombia pursuant to Executive Order 12978 in February 2003 and April 1997, respectively.
 Because PREMIER SALES S.A. is owned or controlled by front companies who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

F. COMPANY AND INDIVIDUAL IN PERU

COLFARMA PERU S.A.,
Av. Los Plateros 145 piso 2, Urb. El Artesano Ate, Lima, Peru;
RUC # 2033645155 (Peru)

 COLFARMA PERU S.A. is a pharmaceutical distributor based in Lima, Peru.  COLFARMA PERU S.A. has a significant business and financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA., PENTACOOP, and DROMARCA Y CIA., all Cali cartel front companies based in Colombia.  MATERIAS PRIMAS Y SUMINISTROS LTDA., PENTACOOP, and DROMARCA Y CIA. were named as SDNTs in Colombia pursuant to Executive Order 12978 in February 2003, April 1997, and April 2000, respectively.
 Because COLFARMA PERU S.A. is owned or controlled by front companies who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

MORALES LUYO, Luis Jaime,
c/o COLFARMA PERU S.A., Lima, Peru;
LE 08195408 (Peru)(individual)

Luis Jaime MORALES LYUO, a Peruvian national, is president, legal representative, and a shareholder of COLFARMA PERU S.A., which has a significant business and financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA., PENTACOOP, and DROMARCA Y CIA., all Cali cartel front companies based in Colombia.
Because Luis Jaime MORALES LYUO acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, he serves as a front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

G. COMPANIES IN SPAIN

INVERSIONES CARFENI, S.L.,
Calle Gran Via 80, 28013 Madrid, Madrid, Spain;
(Spain)

INVERSIONES CARFENI, S.L., is an investment company based in Madrid, Spain.   
Carolina RODRIGUEZ ARBELAEZ, a Colombian national and daughter of Cali cartel leader Miguel Rodriguez Orejuela, is the company�s sole administrator.  In October 1995, Carolina RODRIGUEZ ARBELAEZ was named as an SDNT in Colombia pursuant to Executive Order 12978.  Carolina RODRIGUEZ ARBELAEZ also is a director and shareholder in Cali cartel front companies in Colombia.
Because INVERSIONES CARFENI, S.L. is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

GALERIA DE PORTALES, S.A.,
Miguel Yuste 48, 28037 Madrid, Madrid, Spain;
Jose Serrano 166, 28019 Madrid, Madrid, Spain;
C.I.F. A82464934 (Spain)

GALERIA DE PORTALES, S.A. is an internet services company based in Madrid, Spain.   
Ignacio Garcia DE LA FUENTE ARRIAGA, a Spanish national and husband to Maria Fernanda RODRIGUEZ ARBELAEZ, a daughter of Cali cartel leader Miguel RODRIGUEZ OREJUELA, is the company�s sole administrator.  In February 2003, Ignacio Garcia DE LA FUENTE ARRIAGA was named as an SDNT in Spain pursuant to Executive Order 12978.  Ignacio Garcia DE LA FUENTE ARRIAGA also is the president and shareholder in a Cali cartel front company in Spain.
Because GALERIA DE PORTALES, S.A. is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

SOCIEDAD INVERSORA EN PROYECTOS DE INTERNET, S.A.,
Calle Segre 25, 28002 Madrid, Madrid, Spain;
(Spain)

SOCIEDAD INVERSORA EN PROYECTOS DE INTERNET, S.A. is an internet services company based in Madrid, Spain.   
Ignacio Garcia DE LA FUENTE ARRIAGA, a Spanish national and husband to Maria Fernanda RODRIGUEZ ARBELAEZ, a daughter of Cali cartel leader Miguel RODRIGUEZ OREJUELA, is the company�s sole administrator.  In February 2003, Ignacio Garcia DE LA FUENTE ARRIAGA was named as an SDNT in Spain pursuant to Executive Order 12978.  Ignacio Garcia DE LA FUENTE ARRIAGA also is the president and shareholder in a Cali cartel front company in Spain.  In addition, SOCIEDAD INVERSORA EN PROYECTOS DE INTERNET, S.A. is the subsidiary of GALERIA DE PORTALES, S.A., also administered by Ignacio Garcia DE LA FUENTE ARRIAGA.
Because SOCIEDAD INVERSORA EN PROYECTOS DE INTERNET, S.A. is owned or controlled by an individual who acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

H. COMPANY AND INDIVIDUAL IN VENEZUELA

C.A. V.J. CORPORATION,
Avenida 20 (detras del Country Club), Edificio Drcenca, Barquisimeto, Lara, Venezuela;
Calle 14, Zona Industrial 1, Intercomunal de Cabudare, Barquisimeto, Lara, Venezuela;
Calle 18, Zona Industrial 1, Intercomunal de Cabudare, Barquisimeto, Lara, Venezuela;
RIF # J-30460672-9 (Venezuela)

 C.A. V.J. CORPORATION is a pharmaceutical distributor based in Barquisimeto, Lara, Venezuela.  C.A. V.J. CORPORATION has a significant business and financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA. and DROMARCA Y CIA., Cali cartel front companies based in Colombia.  MATERIAS PRIMAS Y SUMINISTROS LTDA. and DROMARCA Y CIA. were named as SDNTs in Colombia pursuant to Executive Order 12978 in February 2003 and April 2000, respectively.  In addition, the president and majority shareholder of C.A. V.J. CORPORATION is Venezuelan national Victor Julio ESCALONA.  He also is a business partner with Colombian national Gustavo Alberto CORREA CANCINO, an officer in DROMARCA Y CIA., in C A V J CORPORATION LTDA., the Colombian affiliate of C.A. V.J. CORPORATION based in Venezuela.
 Because C.A. V.J. CORPORATION is owned or controlled by front companies who act for or on behalf of Gilberto and Miguel Rodriguez Orejuela, it serves as a corporate front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

ESCALONA, Victor Julio,
c/o C.A. V.J. CORPORATION, Barquisimeto, Lara, Venezuela;
c/o C A V J CORPORATION LTDA., Bogota, Colombia;
c/o VOL PHARMACYA LTDA., Cucuta, Colombia;
Passport A0229910 (Venezuela);
C.I.N. 7353289 (Venezuela)(individual)

 Victor Julio ESCALONA, a Venezuelan national, is president and majority shareholder of C.A. V.J. CORPORATION, which has a significant business and financial relationship with MATERIAS PRIMAS Y SUMINISTROS LTDA. and DROMARCA Y CIA., Cali cartel front companies based in Colombia.  In addition, he also is business partner with Colombian national Gustavo Alberto CORREA CANCINO, an officer in DROMARCA Y CIA., in the Colombian affiliate of C.A. V.J. CORPORATION, C A V J CORPORATION LTDA.  Further, Victor Julio ESCALONA is the manager, legal representative, and a shareholder of the pharmaceutical distributor VOL PHARMACY LTDA. based in Colombia.
 Because Victor Julio ESCALONA acts for or on behalf of Gilberto and Miguel Rodriguez Orejuela, he serves as a front for their narcotics trafficking and money laundering activities, and therefore is listed for designation as an SDNT.

 

 

 

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