Part I: A Breakdown of the CJNG's Finances

"Redlogarythm" for Borderland Beat

For Part II, please click this hyperlink

US Department of the Treasury chart displaying the businesses owned by the Jalisco New Generation Cartel (CJNG) and its financial branch, Los Cuinis. Several of the entities and individuals pictured here are mentioned in this exclusive Borderland Beat report.

The Jalisco New Generation Cartel (CJNG) is one of the two main criminal groups in Mexico. Born as an offshoot of the Sinaloa federation, the organization has been able to dominate a violent market and create a vast criminal portfolio: meth, marijuana, cocaine, heroin, fentanyl, oil theft, kidnapping, bootlegging, alien smuggling, and arms trafficking.

Nevertheless, to say that the CJNG has achieved this position by its own means is far from the truth. On its way to the top, Nemesio Oseguera Cervantes ('El Mencho') and the rest CJNG's bosses have been constantly aided and supported by another organization. This group has been tied to the CJNG for years but is quieter and richer: Los Cuinis.

Los Cuinis could be defined as the business/financial branch of CJNG. The CJNG obtains the money through its criminal activities and then handles it to Los Cuinis, which in turn launder and invest it, destining part of it to reinvesting in the CJNG's operations while the other part follows the mysterious path into the international financial sector: restaurants, prostitution rings, music festivals, hotels, car dealerships, gas stations and even newspapers.

Too much has been written about CJNG's history, leadership, tactics, and structure. Nevertheless, a quick search on the internet will allow us to discover that Los Cuini's organization is far more unknown. Apart from occasional news recounting on arrests of high-ranking Cuinis members and relatives in Mexico, Argentina and Uruguay, the basics of this money laundering and drug trafficking network remain highly ignored.

Nevertheless, their existence and magnitude are clear if we consider that the CJNG is an organization which is currently involved in the export of tons of meth and cocaine per month to the US. Such a magnitude of drugs must generate and incredible amount of cash/revenue which must be managed and introduced into the financial system, disguised as legitimate profits, and reinvested in order to allow the business to continue, thus creating a perfect circle which enables the CJNG's 24/7 activities.

Borderland Beat's purpose in this article is to present an introduction into Los Cuini's and CJNG's finances. We will first make a brief introduction of the history of the Milenio Cartel (CJNG's predecessor), which was founded my members of the Valencia clan. Los Cuinis is currently directed by relatives of the early Milenio's directive.

We will also analyze the initial investments and financial operations of some members of the Gonzalez Valencia clan, specifically covering Hotelito Desconocido, a boutique hotel in the coast of Jalisco bought by the clan in 2007. It became one of the CJNG's major investments until it was seized in 2015.

 

This is the result of an investigation which lasted 2 months. The data includes economic and financial information about CJNG's/Los Cuini's offshore corporate structure (designed by Panamanian lawyers), where they use accountants, lawyers, and legal firms to create their financial emporium and vast investment portfolio.

Most of the information has been obtained from the Office of Foreign Assets Control (OFAC) webpage, Mexican newspapers and magazines, Mexican government public records and my own personal notes. 

The Valencia clan and the Milenio Cartel 

The story of the Valencia clan starts as every single Mexican criminal dynasty does: with a patriarchy. In this case it was José Valencia, a rural farmer from the municipality of Aguililla (Michoacán). During the 1970s, José Valencia started in the business of opium and marijuana by acting as supplier of other local traffickers.

Not much is known about the early beginnings of the Valencia family in the drug business, but by the 1980s their success was so obvious that they had to start buying avocado plantations in order to disguise the illicit origin of their assets. In fact, the Valencia family became known as the Avocado Kings. It was during this time that the clan started to be referred as the Milenio Cartel.

By the 1990s the Milenio Cartel's leadership was varied. The founder José Valencia was replaced by Armando Valencia Cornelio (AKA El Maradona) and his cousins, the brothers Luís Valencia Valencia and Ventura Valencia Valencia.

In 2001, the Colombian supplier of the Milenio Cartel, a drug trafficker called Gino Brunetti, was captured and revealed the identity of his Mexican clients. As a result, Valencia Cornelio was captured in 2003.

Ventura Valencia Valencia was killed in 2006 and replaced by another cousin: Oscar Nava Valencia (AKA El Lobo), who led the Milenio Cartel with Luis Valencia Valencia until he was arrested in October 2009. He was succeeded by his brother Juan Nava Valencia (AKA El Tigre).

By this time, the Milenio Cartel had changed its operational area. Back in 2003 the emergence of a new organization in Michoacán, La Familia Michoacana, and the arrival of Osiel Cardenas's Gulf Cartel and Los Zetas, brought too much attention to Michoacan.

The Valencias agreed to move to a much more peaceful state: Jalisco. Nevertheless, the new relocation required them to partner with the organization which already controlled the area, the Sinaloa Cartel.

The Sinaloa Cartel designed Ignacio Nacho Coronel Villareal as the Milenio Cartel's tutor. Under his guidance the Valencia family became involved in the manufacturing of crystal meth.

It was Nacho Coronel who introduced a Chinese Mexican businessperson called Zenli-Ye-Gon to the Valencias. Ye-Gon's chemical company Unimed imported Chinese and Hong Kong-made ephedrine and pseudoephedrine to Mexico. Ye-Gon became one of Valencia's biggest raw material suppliers.

Nacho Coronel was killed by the Mexican Army in July 2010 and was replaced by his nephew Martín Beltrán Coronel as the tutor of the Milenio Cartel. Martín was arrested in May 2011 and his downfall led to an internal turf battle between two Milenio factions which ended up in the formation of what would become known as the CJNG.

The first faction, Los Torcidos (The Traitors), was led by Erick Valencia Salazar (AKA El 85). He was half-brother of Luis and Ventura Valencia Valencia and was supported by Rubén Oseguera Cervantes (AKA El Mencho). El Mencho was Oscar Nava Valencia's security chief.

The second faction branded itself as La Resistencia (The Resistance). It was led by Ramiro Pozas Gonzalez (AKA El Molca), who supported Elpidio Mojarro Ramírez (AKA El Pilo). El Pilo was Oscar Nava Valencia's main lieutenant and considered himself the successor of the Milenio Cartel's leadership. To fight Los Torcidos, La Resistencia partnered with Los Zetas and La Familia Michoacana.

Maybe it was this alliance or the fact that La Resistencia started losing the war that cause for Sinaloa to support Los Torcidos. In the end, Los Torcidos became the Milenio Cartel's rightful heirs, at least form Sinaloa'a point of view.

In September 2011, the turf war being battled between El Chapo and Los Zetas for some parts of Veracruz reached a new level when two trailers were left in Boca del Río containing the chopped remains of at least 35 people. The perpetrators said that the victims were Zetas members.

At first, reports said that the carnage had been committed by Gente Nueva, an enforcer group of the Sinaloa Cartel. Gente Nueva was responsible for fighting many of the Sinaloa Cartel's proxy wars (like in Chihuahua, where they fought La Linea and other gangs working for the old Juarez Cartel).

Nevertheless, a few days later a video surfaced on the internet. It depicted three masked men sitting behind a desk. They referred to themselves as Los Mata Zetas (The Zeta Killers) and said that the Boca del Rio massacre was their doing.

Later it was discovered that the video was produced by Los Torcidos, which at the time (2011/2012) rebranded themselves as the CJNG.

During this early phase, the CJNG was led by Erick Valencia Salazar until his capture in March 2012. It was at this moment when El Mencho rose to the top of the CJNG's command structure. We must remember that Erick Valencia Salazar reportedly left the CJNG to form the Cartel Nueva Plaza, based in Guadalajara, which is now one of the main opponents of CJNG.

In 2012, El Mencho consolidated his role as CJNG leader and partnered with his friend Abigael González Valencia (AKA El Cuini). El Cuini became the head of the CJNG's financial network: Los Cuinis. El Mencho and El Cuini had worked together in the US, where the first one was jailed for dealing with heroin. After returning to Mexico, El Mencho married Rosalinda, one of Abigael's sisters. 

Source: La Rosa, Lucy and Shirk, David A. The New Generation: Mexico´s Emerging Organized Crime Threat. Justice in Mexico. March 19, 2018 p. 8

The González Valencia financial role:

Los Cuinis is made up of approximately 18 siblings: Abigael, Gerardo, Arnulfo, Elvis, Edgar Eden, Jose Maria, Ulises Giovani, Mauricio, Jose, Luis Angel, Rosalinda, Marisa Yvette, Noemi, Berenice, Maria Elena, Erika, and Abigail. These siblings are the main core of Los Cuinis, although nearly half of them have not been designated by the OFAC as individuals linked to Los Cuinis nor to CJNG.

In fact, only 9 of them are listed as individuals under the Kingpin Act: Abigael, Ulises Giovani, Luis Angel, Egar Eden, Arnulfo, Elvis, Marisa Yvette, Noemi, and Abigail. 

It is worth nothing that Rosalinda Gonzalez Valencia (El Mencho's wife) is not included in the OFAC sanctions even though various reports mention that she is a top financial operator for the cartel. 

To avoid asset forfeiture or further investigations each time their names appeared on investigators' radar, the Gonzalez Valencia siblings developed a network of straw men to manage the cartel's assets. Some of them were relatives (i.e., spouses); in other cases, they are their lawyers and/or local businesspeople they know.

Mexican law does not allow the use of straw men Thus, the establishment of such networks requires the use of trusted people since these front men are the ones who manage and own the entities.

Contrary to what happens in countries such as Costa Rica, Panama, or Uruguay (where front men are simple legal formalities that do not prevent the management of the legal entity by the beneficial owner), in Mexico straw men used by organized crime receive the instructions from the beneficial owners (the Gonzalez Valencia in this case) but they are the ones who must also manage the entity.

Their management and operations are done with assistance and advise from the cartel's attorneys.

That is why Los Cuinis members use their spouses or close friends to manage and own their businesses.

Examples:

1.  Wendy Dalaithy Amaral Arevalo: wife of Gerardo Gonzalez Valencia

2. Jennifer Beaney Camacho Cazares: wife of Abigael Gonzalez Valencia

3. Liliana Rosas Camba: wife of Gonzalo Mendoza Gaytan AKA El Sapo (the Puerto Vallarta plaza boss for the CJNG who was also in charge of recruitment through fake private security employment offers)

4.  Ana Paulina Barajas Sahd: wife of Ulises Giovani Gonzalez Valencia

Los Cuinis did not start as a money laundering entity for the CJNG in 2012. They were already in the laundering business since the 2000s. During these years they were employed by the Milenio Cartel as financial operators. When the Milenio Cartel went under Sinaloa's protection, they started working for Nacho Coronel. This leads us to the first money laundering case we mentioned earlier: the Hotelito Desconocido resort spa in Jalisco.

Hotelito Desconocido 

Founded in 1995 as a luxury hotel/boutique by an Italian businessman, the complex was in the shores of Tomatlán (Jalisco). It became famous as a holiday destination for well-known Hollywood stars such as Julia Roberts and Gary Oldman.

After the hotel became quite profitable, it caught the attention of Los Cuinis and they decided to buy it to disguise their drug money. Investigators do not know certainly know who came up with this scheme. We must remember that in 2007, Los Cuinis were laundering money for the Milenio Cartel, which was working with the Sinaloa Cartel.

Since Hotelito Desconocido remained as a laundering front for CJNG after they split from the Sinaloa Cartel, it may indicate that this operation was fully designed by Los Cuinis from the start.

When a criminal organization manages its assets, it does not always do it directly. The most common thing is to create a secondary entity which will be the one operating the asset. In Hotelito Desconocido's case it was W&G Arquitectos (W&G Architects).

W&G Arquitectos was legally formed in Mexico City on April 1, 2005. The notary who drew up the legal documents was Mexico City's nº 68 Alejandro Soberón Alonso.

According to its founding statutes, W&G's purpose was: "to possess, acquire or exploit any intellectual/industrial property rights, including brands, patents, commercial names and copyright. Design, production and commercialization of any kind of movable goods and machinery for the industry in general."

The statutes also enabled W&G to get involved in the real estate sector and to grant loans.

As we can see, W&G's statutes were deliberately wide and vague to allow most forms of economic activity. Thus, the legal name of the company wanted to suggest an architecture firm, but the legal documents of the entity indicated that the business was conceived to be the backbone of a money laundering scheme (in money laundering investigations, this company is referred to as a "Placement").

 

The initial capital of W&G was MXN$50,000, which at the time was the legal minimum in order to create a Sociedad Anonima de Capital Variable (Public Limited Company of Variable Capital), the corporate structure used by Los Cuinis. This entity structure is simple, cheap and enables shareholders to avoid economic sanctions in the case of default. The capital was represented by only 50 stocks.

Who were the owners (i.e., shareholders) of W&G Arquitectos? It is not easy to answer this question since they were constantly changing. Nevertheless, we have been able to identify 3 main shareholders during the initial moments of W&G:

1.    Wendy Dalaithy Amaral Arevalo: 5,950 stocks for MXN$5,950,000

2.   María del Carmen Arevalo Monzon (cousin of Wendy Dalaithy): 3,600 stocks for MXN$3,600,000

3. ARE-CO Construcciones (a real estate firm involved in houses construction (it is based in Naucalpan de Juárez, State of Mexico, and is the only company in touch with W&G Arquitectos which is not connected to other Cuinis assets.): 8,400 stocks for MXN$8,400,000

These 17,950 stocks were the result of a capital increase decided in a shareholders' meeting held in Naucalpan de Juarez on April 1, 2005, the same day W&G was founded. It was agreed to increment the shareholder equity by 17,950 new stocks for MXN$17,950,000.

For nearly two years, W&G Arquitectos remained silent without any remarkable activity. The only important operation the company was involved was a loan requested by Wendy Dalaithy to Juan Carlos Cortez Orendain (a Mexican businessman who is linked to a car wash business in Tepic), on January 1, 2007. Wendy Dalaithy asked for MXN$58,000,000 committing herself to pay before December 1, 2012 through a promissory note.

A second capital increase happened on July 20, 2007. 55,500 new stocks were issued for MXN$55,500,000.

It was at this time when Wendy Dalaithy and her cronies at W&G started sketching the acquisition of Hotelito Desconocido. The hotel resort was already a well-known and luxurious property and W&G's size was not big enough to face such an operation. Los Cuinis' firm had been involved in constant capital increases since its creation through loans and obscure shareholder contributions. Yet they needed more money to purchase the hotel. The answer to this problem was to get a second loan.

On October 25, 2007, the same notary used for W&G creation (Alejandro Soberón) left a record of a shareholder meeting at which it was decided that the purchase of Hotelito Desconocido would be done through a bank loan.

The candidate for the loan: Banco Bansí. Founded in 1995 in Guadalajara, Jalisco, by a conglomerate of businessmen and finance professionals, the bank says it is designed for investors who want to increase their operations.

According to their own webpage, they offer investments, credits, trusts (which is one of the most common financial structures for money laundering), currency exchange (dollars for pesos and vice versa), appraisals and electronic banking. The electronic banking benefits are offered through personalized service, advisory, planification and/or fully developed surveys for decision taking.

 

Since Banco Bansi has old ties with Guadalajara, there is a chance that it could also have ties to drug cartels in the area. This assumption becomes clear because financial institutions are obliged to apply with the so-called Know Your Customer (KYC) policy whose objective is to identify the customer and cut relations with those whose activities are not clear or are doubtful.

Banco Bansi granted MXN$40 million to W&G Arquitectos on November 5, 2007.

That same day, they bought Hotelito Desconocido from MMC, the company that created and owned the hotel before them.

The purchase invoice for W&G was: 

• Land and buildings: US$7,700,000 (VAT: US$182,250) 

• Construction Equipment: US$285,000 (VAT: US$42,750) 

• Brand and Property Rights: US$250,000 (VAT: US$37,500) 

• TOTAL (concepts + Value Added Tax): US$8,497,500

By then Wendy Dalaithy Arevalo had already achieved the role of president and shareholder's assembly head. We infer that Banco Bansi knew who Wendy Dalaithy was or her ties to the Cuinis clan due to the KYC policy.

On August 9, 2012, W&G paid back the MXN$40 million loan (plus interests) to Banco Bansi. 

W&G did not only purchase the land and the buildings in it. They also acquired three public concessions from the Federal Government. Hotelito Desconocido was in Tomatlán, an area branded as a natural reserve. In order to build or conduct economic activities in such a place companies must obtain a permission from the government.

The permission to operate is granted through concessions. In this case W&G obtained three concessions: 

1. DGZF-051/04: for using and occupying a surface of land less than 1 hectare of federal maritime-terrestrial zone all along with the constructions under development in El Ermitaño estuary. 

2. DGZF-374/04: surface of 4.3 hectares for ornament use 

3. DFZF-375/04: surface of 2 hectares of beach for solely for hotel purposes

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Immediately after acquiring Hotelito Desconocido, W&G Arquitectos transferred two of the concessions to a subsidiary (a second entity created for the assignment of Hotelito's resources) called HD Collection.

HD Collection was founded on November 24, 2009 in Tepatitlán, Jalisco, while in the presence of public notary Cayetano Casillas y Casillas. On February 2, 2010, nearly two months after its formation, HD Collection sold a huge part of its stocks to Wendy Dalaithy Amaral Arevalo. She became Chairman of the Board of Directors of that company.

There were now three different businesses:

1. W&G Arquitectos: Manages Hotelito Desconocido and HD Collection

2. Hotelito Desconocido

3. HD Collection: Manages Hotelito Desconocido's public land assets (a practice commonly referred to as Compañía espejo, or "Mirror company").

The transferred concessions were DGZF-375/04 and DFZF-374/04.

In order to transfer such an asset an authorization was needed. José Luis Gutiérrez Miranda, general director of the Federal Maritime-Terrestrial and Coastal Zones Department of the Secretary for Environment and Natural Resources (SEMARNAT), granted the permission for transferring the concessions from Hotelito Desconocido to HD Collection.

It was during mid-2009 when W&G tried to expand by acquiring even larger amounts of land. These terrains were located at the protected natural area of Santuario Playa de Mismaloya, a special zone since it was essential for the preservation of maritime turtles.

The requests for these two new concessions were handed on April 3, 2009, by W&G to Jose Luis Gutierrez Miranda; the first one wanted a 5,577,1 square meters parcel and the second one requested 5,330,9 squared meters. Both of them were for purely ornament use.

Tomatlan's Public Works Department approved the project on February 26, 2009 and asked the SEMARNAT for permission to grant the concessions. The Protected Natural Areas National Commission (CONANP) intervened and encouraged SEMARNAT to deny the concessions to W&G through an internal memorandum on March 16, 2010. In the end SEMARNAT officially denied the concession on August 11, 2010.

The refusal was possible because of the legal battle waged by local fishermen from the town of Tomatlán who were constantly harassed by Hotelito Desconocido managers. The hotel staff forbid them from working in the area.

In the past, the local fishers arranged a deal with MMC, the previous owner of Hotelito Desconocido: they were able to fish in the area during off-season and during high season they would be compensated with a fixed amount of money for each day they did not operate. As the fishermen later exposed after W&G acquired Hotelito Desconocido, the deal was broken, and they did not receive any kind of payment during high season.

On March 24, 2011, three of these brave men from the town of Loreto where kidnapped in Guadalajara while attending a meeting with public officials from National Water Commission (Conagua). Their current whereabouts are unknown.

Hotelito Desconocido, the boutique hotel owned by the CJNG where Tobares worked. One of the chefs who worked there, Federico Tobares, was kidnapped and remains missing.

During this time W&G's shareholders varied significantly.

On December 28, 2007, nearly one month after Hotelito Desconocido's purchase, María Emilia Arévalo Monzón, another of Wendy Dalaithy’s cousins, acquired 16,500 stocks for MXN$16.5 million.

On January 31, 2008. Julio Alberto Castillo Rodríguez (AKA El Ojo de Vidrio) acquired 36,898 stocks for MXN$36.9 million. Castillo Rodriguez is married to Jessica Johanna Oseguera Cervantes, El Mencho's daughter.

On January 1, 2012, María Emilia Arévalo Monzón was removed from W&G in the middle of a restructuring process due supposedly to the scarcity of resources the company was suffering when she sold her stocks.

On December 31, 2012, Castillo Rodríguez sold his stocks at W&G for MXN$11.1 million. Considering that he had bought them for MXN$36.9 million, he ended up losing MXN$25,807,682. This factor, together with the fact that he waited until the last day of 2012 to make the sale, might indicate that the whole operation was planned since the beginning.

Castillo Rodriguez sold his stocks to three parties:

1. Wendy Dalaithy (at that time she was the director and main stockholder)

2. María del Carmen Arevalo Monzon (the second stockholder at the time of W&G foundation)

3. Maribel Torre Suárez

On January 28, 2013 Wendy Dalaithy Amaral Arevalo sold all his stocks at W&G. She had accumulated 39,000 stocks. Her stocks were liquidated, and she was paid with real estate properties owned by W&G.

By 2013 the situation had reached a new limit. A lot of people knew something abnormal was happening with Hotelito Desconocido. The fishermen disappearances, the fact that several convoys of black hummers where constantly being spotted all around the area, the arrival of helicopters carrying mysterious packages and the private parties being held inside the complex, indicated that a drug cartel was running the business.

At this point two of the main stockholders of W&G decided to dissociate themselves from the entity. On September 30, 2013, they were removed from W&G and the liquidation of their stocks was compensated with Hotelito Desconocido. In other words, in other to leave W&G they were paid with the hotel's equity.

María del Carmen Arevalo Monzon received 60% of Hotelito Desconocido and the other 40% became property of Maribel Torre Suarez.

By 2015, CJNG had already become an international organization. Their ruthless tactics and their turf war against rival cartels were well-known and many of their top bosses were publicly identified. During this year, the US Treasury Department and the DEA started focusing on their financial structure and indictments against CJNG and Cuinis members.

Due to this higher attention levels, Torres Suarez and Arevalo Monzon decided to sell Hotelito Desconocido before it was designated as a CJNG/Los Cuinis laundering front.

On May 20, 2015, they sold Hotelito to Inmobiliaria Anfe (Anfe Real Estate Agency), founded on December 15, 2014, in Zapopan (another CJNG hub) before Public Notary nº 38 by Luis Angel Orendain and Juan Gabriel Fernandez Sanchez.

The company's purpose, as signed by the notary, was to engage in: "real estate development, purchase, leasing, renting, administration and maintenance of resort, residential, commercial or hybrid properties".

It almost seems that the statutes were deliberately designed for the purchase of Hotelito Desconocido.  The initial capital was, again, the required legal minimum of MXN$50,000, which belonged Orendain (60 percent) and Juan Gabriel Fernandez Sanchez (40 percent).

On May 18, just two days before purchasing Hotelito Desconocido, Inmobiliaria Anfe expanded its capital for another MXN$50,000,000. 95 percent of this amount was provided by Orendain (thus making him the main stockholder and virtual owner of Hotelito) and the remaining 5 percent by Fernandez Sanchez.

On August 19, 2015, the US Treasury Department indicted 8 people (among them Abigael Gonzalez Valencia, Wendy Dalaithy Amaral Arevalo and El Mencho) and 15 different companies (including Hotelito Desconocido, W&G Arquitectos, HD Collection and Arenas de Loreto, a seaside resort attached to the hotel's complex).

One day earlier, on August 18, Inmobiliara Anfe received a notification from Mexico's Attorney General's Office (PGR) stating that Hotelito Deconocido was going to be seized due to the upcoming US government indictment.

The assets owned by Inmobiliaria Anfe related with Hotelito Desconocido purchase were frozen and the complex was placed under federal jurisdiction.

Immediately after the seizure Orendain filed a lawsuit against the PGR's decision. He claimed he had nothing to do with the activities of the previous owners and that he had bought the property legally. The demand is still being discussed in the tribunals, but we must take into account that in most cases like this it is usually decided in favor of the complainant.

There are basically two ways for a criminal organization to recover assets that were frozen or seized for money laundering:

1.   The first one is to let it be confiscated by the authorities and wait until the asset is held in public auction. The criminal group can then send a legal representative (generally a lawyer or a businessman) which offers the highest bid using the cartel's money.

2.   Legally sell the asset just before the confiscation to an accomplice who is posing as an unfortunate buyer. After the property is confiscated under the new owner, they can claim they did not know anything about the previous owner and have the asset return to them.

In Mexico, assets confiscated or frozen are oftentimes re-sold through public auctions. It is common for drug cartels to send lawyers or businessmen working for them to purchase those assets back

 

It is likely that Orendain, the current owner of Hotelito Desconocido, is thereby tied to Los Cuinis. It is reasonable to suspect that Orendain was told to buy off Hotelito Desconocido after the money laundering suspicions started to surface. Inmobiliaria Anfe was created a few months prior to Hotelito Desconocido's confiscation, and it is possible that Los Cuinis gave the funds to Inmobiliaria Anfe through some kind of compensation mechanism to buy Hotelito Desconocido in the event that it was confiscated.

This is the story of one of the CJNG and Cuinis's major money laundering cases. Nevertheless, this is only the tip of the iceberg.

According to official data, when a money laundering network is cracked only a partial fraction of the whole scheme is discovered. The rest of it is immediately sold or disguised under new legal names or under corporate re-shaping methods.

It would be foolish to suggest that Hotelito Desconocido's operation was a big part of the cartel's portfolio. It was likely only a very tiny fraction of their empire.