Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the Bhardwaj Human Smuggling Organization (Bhardwaj HSO), a transnational criminal organization (TCO) based in Cancun, Mexico, as well as its leader Vikrant Bhardwaj (Bhardwaj), three other individuals, and 16 companies that have facilitated and profited from the HSO’s criminal activities. The Bhardwaj HSO has smuggled thousands of illegal aliens from Europe, the Middle East, South America, and Asia into the United States. In addition to human smuggling, the Bhardwaj HSO is involved in drug trafficking, bribery, and money laundering.
“At the direction of Secretary Bessent and President Trump, the Treasury Department is taking action to crack down on human smugglers,” said Under Secretary for Terrorism and Financial Intelligence John K. Hurley. “Today’s action, in collaboration with our law enforcement partners, disrupts this network’s ability to smuggle illegal aliens into the United States. The Trump Administration will continue to target and dismantle terrorist transnational criminal organizations to protect the American people.”
Today’s action was taken pursuant to Executive Order (E.O.) 13581, as amended by E.O. 13863 (hereafter, “E.O. 13581, as amended”), which targets transnational criminal organizations and their support structures. OFAC coordinated this action with Homeland Security Investigations (HSI), the Drug Enforcement Administration (DEA), and the Government of Mexico’s financial intelligence unit, the Unidad de Inteligencia Financiera (UIF).
THE BHARDWAJ HUMAN SMUGGLING ORGANIZATION
The Bhardwaj HSO is a sophisticated organization that has blended various transportation methods to facilitate the travel – by air and sea – of undocumented migrants from countries that pose national security concerns to the United States. The Bhardwaj HSO utilizes its own yachts and marinas to transport undocumented migrants into Mexico. Upon arriving in Cancun, the Bhardwaj HSO then facilitates housing for the migrants in hostels and hotels before coordinating with associates to transport the migrants to the U.S.-Mexico border. In collaboration with members of the OFAC-designated Hernandez Salas TCO, the Bhardwaj HSO has used the Tapachula-Cancun-Mexicali corridor to smuggle undocumented migrants into the United States. On June 16, 2023, OFAC designated the Hernandez Salas TCO pursuant to E.O. 13581, as amended, for being a foreign person that constitutes a significant transnational criminal organization.
Human smuggling services contracted by the Bhardwaj HSO generate thousands of dollars per individual. The Bhardwaj HSO also receives operational support from individuals employed by the Sinaloa Cartel.
OFAC designated the Bhardwaj HSO pursuant to E.O. 13581, as amended, for being a foreign person that constitutes a significant transnational criminal organization.
Vikrant Bhardwaj (Bhardwaj) is a dual Indian-Mexican national and the leader of the Bhardwaj HSO. Bhardwaj is the self-identified founder and chief executive officer of several companies in Mexico, India, and the United Arab Emirates (UAE). He collects and launders illicit money through his marinas and various businesses. Bhardwaj has been able to evade law enforcement authorities while continuing to profit from human smuggling and drug trafficking.
Senior members involved in day-to-day operations and logistics for the Bhardwaj HSO include Jose German Valadez Flores (Valadez), a businessman and drug trafficker who is a close associate of Bhardwaj. Valadez plays a significant role in smuggling migrants into Cancun by bribing corrupt Mexican officials. Jorge Alejandro Mendoza Villegas (Mendoza), a former police officer in the state of Quintana Roo, has access to the Cancun International Airport to help coordinate the arrival and departure of undocumented migrants. Since 2020, Mendoza has supported the Bhardwaj HSO human smuggling and drug trafficking activities through the Cancun International Airport.
OFAC designated Bhardwaj, Valadez, and Mendoza pursuant to E.O. 13581, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the Bhardwaj HSO.
BHARDWAJ HSO’S GLOBAL BUSINESS NETWORK
Bhardwaj’s wife, Indu Rani (Rani) is a dual Indian-Mexican national who is involved in her husband’s financial operations and serves as a co-shareholder of several companies in India and Mexico.
Rani is being designated pursuant to E.O. 13581, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Bhardwaj.
In addition to exposing key individuals of the Bhardwaj HSO, OFAC designated Veena Shivani Estates Private Limited, a real estate company in India pursuant to E.O. 13581, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Bhardwaj and Rani.
OFAC designated 8 companies based in Mexico, India, and the UAE pursuant to E.O. 13581, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Bhardwaj:
- A restaurant and bar in India, Michigantap Hospitality Private Limited
- Three companies engaged in real estate activities in India, and the UAE: VVN Buildcon Private Limited, Bhavishya Realcon Private Limited, and VVN Real Estate L.L.C
- An energy and fuel trading companybased in the UAE, Black Gold Plus Energies Trading L.L.C
- Two yachting and touring services companies based in Mexico, V AND V Astillero, S.A. de C.V. and Operadora Turistica Principessa, S.A. de C.V.
- A supermarket in Mexico, VNV Store, S.A. de C.V.
- A real estate company, Bhardwaj, S.A. de C.V.
- A business support services provider, Thercumex, S.A. de C.V.
- A textiles retailer, VNV Fashions, S.A. de C.V.
OFAC designated three companies based in Mexico pursuant to E.O. 13581, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Rani:
OFAC additionally designated three companies based in Mexico pursuant to E.O. 13581, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Valadez:
- A construction company, Constructora Gerlife, S.A. de C.V.
- A transportation company, Comercializadora Vespa, S.A. de C.V.
- A reservation services company, Comercialicun, S.A. de C.V.
OFAC also designated one company based in Mexico pursuant to E.O. 13581, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Mendoza: a construction company, Cargas Y Regulaciones Electricas, S.A. de C.V.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked 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 blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.