Insight Crime Investigation
and Analysis of Organized Crime
Wilson Center
Investigative Team
Steven Dudley
Deborah Bonello
Jaime Lopez-Aranda
Mario Moreno
Tristan Clavel
Bjorn Kjelstad
Juan Jose Restrepo
Prologue
In October 2017, President Donald Trump declared the opioid epidemic a national
public health emergency, citing record deaths from opioids and expressing a belief that
his administration could end “the opioid epidemic”. As part of his strategy, the
President claimed that “90% of the heroin in America comes from south of the border”
and called for the construction of a border wall to stem the flow.
While it is true that a large percentage of the heroin sold in the United States comes
from Mexico, the message mussed the larger point. By far, the fastest growing class of
opioid-caused deaths in 2017 was fentanyl and similar drugs. According to the Centers
for Disease Control and Prevention, 70,273 people died from drug overdoses. Of these,
28,466 involved fentanyl or a similar synthetic drug. Horrifically, this was a 45%
increase over 2016.
While we can debate the potential effectiveness of a border wall in stopping overall
drug flows into the United States, the trouble with fentanyl is that, due to its highly
concentrated nature, it can be transported easily, in small quantities, and can have a
devastating impact on public health. As this publication by the Mexico Institute and
InSight Crime emphasizes, Mexican anti-narcotics policy has been slow to recognize the
horrific potential of Fentanyl and bilateral cooperation on the drug has not kept up with
the explosive development of the market.
It is vital that Mexican public policy-makers and their US counterparts engage in
conversations focusing on counter-fentanyl planning and strategy in order to develop
effective means of addressing the problem of the drug in Mexico and in the United
States. As a recent Wilson Center Mexico Institute publication by Eric Olson has argued,
a common solution to a shared problem must be found:
“The principles of shared responsibility and bilateral collaboration are
fundamentally important to successful security cooperation. Illicit economies,
whether smuggling drugs, humans, or other products, do not respect borders, so
it is essential for both countries to work together to address these complex
problems. The United States and Mexico should reaffirm their commitment to
the framework of shared responsibility for addressing the security challenges
that threaten both countries.”
This timely publication by the Mexico Institute and Insight Crime hopes to provide both
analysis and recommendations for policy-makers. As Mexico’s new government begins
to modify its public security and anti-narcotics strategy, an informed public debate will
be essential to finding long-term effective solutions.
Duncan Wood, PhD
Director, Mexico Institute
February 2019
Executive Summary
Since surging into the market in 2013, fentanyl has become the most lethal category of
opioid in the United States. The Centers for Disease Control and Prevention (CDC)
estimated that more than 47,000 people died from an opioid overdose in 2017 in the
United States—28,000 of those deaths were due to synthetic opioids, which the CDC
says is largely the result of the uptick in abuse of fentanyl.
This investigation sought to better situate Mexico’s role in the fentanyl trade. Chinese
companies produce the vast majority of fentanyl, fentanyl analogues, and fentanyl
precursors, but Mexico is becoming a major transit and production point for the drug
and its analogues as well, and Mexican traffickers appear to be playing a role in its
distribution in the United States.
To investigate Mexico’s role, we found we had to look at the entire distribution chain.
InSight Crime employed two researchers in Mexico, two in the United States, and two
in Colombia who combed all the databases, scoured through judicial documents, filed
freedom of information requests, and executed dozens of interviews in Mexico and the
United States with law enforcement, prosecutors, health specialists, and others. The
result is a nuanced picture but one with troubling implications for the future of drug
trafficking and drug consumption.
While seemingly dominated by two large criminal groups in Mexico, the fentanyl trade
requires vast networks of smaller subcontractors who specialize in importing,
producing, and transporting synthetic drugs. Both large and small organizations appear
to be taking advantage of the surge in popularity of the drug, which is increasingly laced
into other substances such as cocaine, methamphetamine, and marijuana—very often
without the end-user knowing it. To be sure, rising seizures of counterfeit oxycodone
pills laced with fentanyl illustrate that the market is maturing in other ways as well.
Fentanyl potency also opens the door to entrepreneurs who bypass Mexico
altogether, obtaining their supplies directly from China and selling them on the dark
web. There is little public understanding of the prevalence of this part of the trade and
even less of its medium- and long-term implications. The low barrier of entry into this
market and its high returns make for a frightening future in which synthetic drugs of all
types could proliferate.
Major Findings
Fentanyl lends itself to drug trafficking in many respects and therefore may
represent how the drug trade might move in the future to more portable and
intoxicating synthetic substances.
Fentanyl is potent. Small amounts means less risk in the production and
transport process but still significant profits.
Production of fentanyl is also relatively simple and cheap, opening the door for
smaller groups to enter the trade using small spaces and moving small
quantities over the dark web.
China produces nearly all of the fentanyl, fentanyl analogues, and fentanyl
precursors in the world, although India—with its large chemical
infrastructure—appears poised to make an entry into the market, and Mexican
traffickers are starting to produce it as well using precursors obtained mostly
in China.
Mexico is a growing transit and production point for fentanyl, with most of the
product entering via the ports of Manzanillo and Lázaro Cárdenas.
Mexico’s two largest criminal organizations—the Sinaloa Cartel and the Jalisco
Cartel New Generation (Cartel de Jalisco Nueva Generación - CJNG)—are the
most important Mexican purveyors of the drug and its precursors, although
smaller criminal organizations and contractors may play significant roles in
production and transport of the drug along the distribution chain.
It is not clear how much Mexico-sourced fentanyl is being consumed in the
United States. There are conflicting accounts of how much is arriving directly
from China versus how much is coming via Mexico.
US authorities say Dominican traffickers are the main suppliers to end consumers in the Northeast of the US, although Mexican trafficking networks do
play a significant role.
Heroin and fentanyl are often trafficked together, but fentanyl and
methamphetamine may have more in common in the production phase and are
increasingly seen at the end-user stage.
Legacy criminal organizations with experience importing chemicals for
methamphetamine production from Asia seem to be the best-positioned to take
advantage of this surge in fentanyl use.
Mexico’s government does not see fentanyl as an important issue yet and has
not devoted significant resources towards finding the principal drivers of the
trade inside its borders.
Part I
Origins of the Epidemic
Fentanyl is a highly potent synthetic opioid meant to curb pain. Abuse in the United
States began in earnest in 2014, after a long period of over prescription of pain
medications that led users from the pharmacies to the streets. Although there is some
indication that India is entering the fentanyl market, production is almost solely the
domain of China, where regulation is lax, and small and large criminal organizations
have long-established ties to international networks or are connecting to customer
bases via the internet and direct mail services. China also exports precursor chemicals
to Mexico for the illicit production of the drug, a topic we will cover in Part II.
Fentanyl-The US Epidemic
The earliest reports of US fentanyl overdoses trace back to the 1970s during the first
heroin epidemic.1 Given their potency, fentanyl and its analogues occupied a small
percentage of the total illicit drug supply in the United States over the next few
decades—save for two brief spates of overdose deaths in 1991 and 2006. But, starting
in the late 1990s with the overprescribing of addictive prescription pain medications,
opioid addiction took root in the United States.2 Given that addiction is a progressive
disease 3 and due to the lack of sufficient treatment options in the United States, people
who developed opioid use disorders because of prescription pain medication misuse
began switching to administering heroin towards the start of this decade.4
Most public health leaders and advocates interviewed for this study believed that the
next logical step for people with heroin use disorders was fentanyl misuse, with some
maintaining that stronger synthetic opioids and fentanyl analogues represent a logical
next step after fentanyl. Still, there is considerable debate concerning whether users are
aware they are taking fentanyl. Given the similar effects the drug provokes in users, it
is difficult to differentiate.
What’s more, as we will describe, production is increasingly coming in pill form, usually
counterfeit oxycodone or other prescription opioids, giving rise to the idea that many
end users think they are consuming prescription pain medications when they first
consume fentanyl. Research also suggests that some users may have moved straight
from prescription painkillers to fentanyl, skipping the heroin step altogether, although
data is preliminary and anecdotal at this stage.
Data from the Drug Enforcement Administration National Forensic Laboratory
Information System (NFLIS) indicates a drastic increase in reports of fentanyl and
fentanyl-family exhibits—samples from law enforcement drug seizures sent for testing
at forensic labs—during this decade. From less than 700 in 2012, fentanyl exhibit
reports exploded to more than 32,000 in 2016.5 Along with overdose death figures,
emergency department data and interviews, exhibit reports point to 2014 as the year
of the outbreak of what has become an epidemic: the latest NFLIS report chronicled
56,530 fentanyl and fentanyl-analogues exhibits during 2017, nearly doubling 2016’s
exhibits.
6
Furthermore, the latest available NFLIS data also indicates that fentanyl’s market share
is growing within the illicit opioid consumption market. While fentanyl came in second
behind oxycodone as the most submitted narcotic analgesic in 2016,7 data for 2017 shows that fentanyl exhibit reports outnumber those for prescription pain medications,
even without counting fentanyl analogues.8
This surge in fentanyl exhibits closely tracks with fentanyl-related overdoses, which
appear to have spiked since 2014, when the 4,200 fentanyl-related deaths represented
less than 9 percent of lethal overdoses that year.9 The CDC has not published standalone figures for fentanyl-related deaths in more recent years. But the center’s data
shows that overdose deaths related to synthetic opioids other than methadone—a
category dominated by deaths due to illicitly manufactured fentanyl— have risen
significantly both as a proportion of total overdose deaths and in gross quantity.10 The
CDC estimates that this fentanyl-dominated category may be responsible for over
30,000 deaths through the 12-month period ending May 2018, highlighting a fentanyl
overdose epidemic within a global US drug overdose epidemic that is predicted to have
claimed more than 71,000 lives in the same time period.
11
Fentanyl and Precursor
Production in China
According to US officials, China is the principal source country of illicit fentanyl, fentanyl
analogues, and fentanyl precursors found in the United States.12 Some US officials claim
that China produces more than 90 percent of the world’s fentanyl.13 The US-China
Economic and Security Review Commission has also said that Chinese companies are
responsible for exporting various fentanyl-related products including “raw fentanyl,
fentanyl precursors, fentanyl analogues, fentanyl-laced counterfeit pills like oxycodone,
and pill presses and other machinery necessary for fentanyl production.”14
China’s role in supplying the majority of synthetic opioids to the American market is
directly linked to its vast, poorly regulated pharmaceutical and chemical industries.
Over the years, China has risen to become the second biggest pharmaceutical industry in the world behind the United States, bringing in an annual revenue of $122 billion.15
At the same time, China has become the world’s number one exporter of active
pharmaceutical ingredients (API’s) and inert substances.16
The current fentanyl overdose epidemic is almost entirely attributed to illicitly
manufactured fentanyl, and not to the diversion of legal, pharmaceutical fentanyl from
China or from the United States, according to the CDC and DEA.
17 Instead, US officials
believe that pharmaceutical or chemical companies produce fentanyl as a third-shift
operation at Chinese pharmaceutical factories in southern China.18 Officials also believe
that Chinese transnational criminal organizations, along with other smaller criminal
actors use diverted chemicals to manufacture fentanyl in rural clandestine labs.
An estimated 160,000 chemical companies are currently operating either legally or
illegally in China, according to the US Department of State.19 Like with the
pharmaceutical industry, China’s chemical industry suffers from poor regulation, thus
allowing fentanyl precursor chemicals such as ANPP and NPP to be diverted into
clandestine labs by criminal groups.20 A lack of oversight paired with administrative
inefficiencies has also allowed illegal chemical factories to spring up and manufacture
significant quantities of precursors.
21
From China, pure powdered fentanyl, fentanyl pills, and fentanyl precursors are either
sent to Mexico or mailed directly to the United States, often with pill presses and
binding agents.
22 23 When sending fentanyl in any form or pill presses, Chinese groups
will often mislabel the product in order to avoid detection.24
Illicit Networks in China
The movement of fentanyl from clandestine labs and precursor chemicals to Chinese
ports is a dynamic that was not the purview of this report and one that requires further
investigation. According to the DEA, it is difficult to track the origin of precursor
chemicals or clandestinely-produced fentanyl because of the intricate network of
freight forwarding companies commonly employed by criminal groups to conceal the
origin of the product—a strategy often used by criminal groups moving drugs and
contraband around the world in shipping containers in order to hide their trail.25
Criminal groups will also purposefully mislabel fentanyl and fentanyl-analogues,
precursor chemicals and pill presses when shipping in order to evade inspection—the
DEA in Mexico claims that all fentanyl entering Mexican ports in shipping containers is
mislabeled.26 In May 2015, for example, 46 kilograms of fentanyl and 26 kilograms of
acetyl fentanyl destined for Mexico were seized by Chinese customs officials. Chinese
officials later learned that the illicit cargo had gone through five different freight
forwarding companies before arriving at customs.27
China has attempted to control the development of countless numbers of fentanyl
analogues and precursor chemicals. But implementation of these initiatives has proven
difficult as law enforcement and drug investigators struggle to keep track of high levels
of pharmaceutical and chemical output.28 Furthermore, as fentanyl addiction and
overdose deaths are not problems in China, it currently takes scheduling and
interdiction actions at the behest of the United States, making this relationship
dependent on the changing dynamics of the US-China relationship.
29
But some positive efforts are being made, and United States officials said that the
bilateral relationship with China on this issue is open and developing. In 2015, the
Chinese Food and Drug Administration made 116 psychoactive substances, along with
six fentanyl analogues, controlled substances, and in February 2018, newly created
controls on five fentanyl precursors including ANPP and NPP went into effect.30
The impact that these controls will have on limiting the diversion of fentanyl precursor
to clandestine laboratories, or the export of said chemicals to criminal groups in Mexico
and the United States, remains to be seen.
CASE STUDY
A China Chemical Plant
In October, 2017, two Chinese men—Xiaobing Yan and Jian Zhang—were indicted for
conspiring to manufacture and distribute “large quantities” of fentanyl and fentanyl
analogues in the United States.31 Although they used multiple names and company
identities over a period of six years, investigators were able to trace the fentanyl shipments
back to four clandestine labs and two chemical plants in China. It was the first known
indictment of Chinese nationals for the production of fentanyl.
The two chemical plants operated by Yan “were capable of producing ton quantities of
fentanyl and fentanyl analogues,” according to an official US Department of Justice press
release.32 Apart from the two Chinese nationals, 19 others were indicted for conspiring to
distribute the illicitly-produced fentanyl and fentanyl analogues throughout the United
States.
The indictments also provide further evidence of the substances exported from China
directly to the United States and with Canada as a transshipment point, and shed light
into how quickly Chinese groups can alter fentanyl-family substances to escape scheduling
efforts.
Yan closely monitored scheduling decisions and law enforcement activities to modify the
structure of his chemical analogues to avoid detection.33 He exported these fentanyl
analogues, as well as fentanyl, directly to the United States via mail. The second indictment
suggests a similar narrative. This individual operated four labs and exported fentanyl,
fentanyl analogues, as well as pill presses, stamps, and other materials to shape fentanyl
into pills in the United States.34
India – Emerging Fentanyl Producer?
In September 2018, Indian authorities arrested three people, including a Mexican
national, in possession of 10 kilograms of fentanyl hydrochloride, a salt form of the
synthetic opioid.
35 Investigators told local media that the fentanyl was produced at a
chemical factory in India run by the two Indian suspects.
The arrest startled but did not surprise US authorities contacted by InSight Crime. India,
along with China, provides the bulk of chemical precursors used in the manufacturing
of methamphetamine in Mexico. To be sure, as we detail later in this report, we believe
that organizations who have traditionally dealt in methamphetamine are some of the
best positioned to take advantage of the burgeoning fentanyl trade.
Part II
Fentanyl – The Mexico Gateway
Mexico is by far the most important gateway for fentanyl and precursor chemicals into
the region via ship. It is also a hub of production and export of fentanyl to the United
States. Myriad Mexican criminal organizations appear to be managing the processing,
storage, and shipment of fentanyl, although two in particular—the Jalisco Cartel New
Generation (Cartel de Jalisco Nueva Generación – CJNG) and the Sinaloa Cartel—seem
to exert control over the transport into the United States.
Mexico – Ports of Entry
For several reasons outlined in this section, US officials believe that Mexico is the main
hub of transit and production of fentanyl in the hemisphere. To begin with, several
maritime ports in Mexico have long played a major role in the illegal importation of
chemical precursors for the manufacturing of illicit drugs, sometimes leading to major
violence in those areas. Maritime ports handle large volumes of merchandise and a
significant portion of international trade, particularly between Asia and Mexico, which makes them logistically ideal for both legal and illegal trading of large volume
substances.
Mexico has 22 maritime ports that reported register cargo movement in 2016 (the last
year for which there is complete yearly data). Out of the 22, the 10 largest account for
84 percent of the total import-export tonnage. However, there is little indication that
many or even most ports are actually used for illegal chemical precursor trafficking, and
even less that they are being used to introduce fentanyl products. In fact, 3 of the 10
major ports account for over 87 percent of the total chemical precursor seizures by the
Navy between 2007 and 2018: Manzanillo, which accounts for the lion’s share of
seizures, Lázaro Cárdenas, and Veracruz.36
Most of the fentanyl or its ingredients arriving from China via containers is being hidden
in plain sight by being mislabeled, according to DEA sources in Mexico City. The main
ports being used are those on the Pacific coast—Manzanillo in the state of Colima and
Lázaro Cárdenas in Michoacán.
The concentration of trafficking activity in these ports points to longstanding control of
them by organized crime groups. According to the Secretary of the Navy (Secretaría de
Marina – SEMAR), there has been little effective oversight of the ports.
37 Two former
high-ranking Federal Police officials who were directly involved in several operations
in and around Lázaro Cárdenas from 2008 to 2015 corroborated this sentiment.38 The
police said their investigations revealed widespread corruption and intimidation
amongst the civilian port managers and a “marked reticence” to implement basic
counter narcotic measures and to denounce illegal or suspicious activities, which
extended to the customs officials attached to the port. The officials also emphasized that
at least one criminal group, the Familia Michoacana, was engaged in illegal mineral
exports through the port, as was widely reported at the time.
A former high-ranking official from the Ministry of the Interior (Secretaría de
Gobernación – SEGOB) confirmed there was also evidence of collusion and intimidation
in Manzanillo port and gave credence to reports that a significant amount of the
violence around the port has long been related to illegal chemical precursor trafficking
by local and national criminal groups. However, he emphasized that investigating
customs and port officials and civilian employees without unduly disrupting legal commerce proved to be extraordinarily difficult, as there were a number of large legal
firms that were suspected of some level of involvement in illicit activities.
39
The fentanyl is packed and shipped with other drugs. These poly-drug loads are transported by land, air or sea north to the US border where they cross in individual vehicles, container trucks, or via “mules.” Officials once believed that fentanyl was mixed with white powder heroin or camouflaged as heroin in Mexico. (Experts and law enforcement say that fentanyl cannot be combined with black tar heroin.) However, the most recent seizures show that this rarely happens anymore at the wholesale level. Instead, the fentanyl is moved on its own and mixed with other drugs once it is inside the United States. 40
Fentanyl is also pressed into pill form in Mexico for transport and distribution as counterfeit oxycodone or other prescription opioids. Some portion may arrive from China already in pill form, so no further processing is needed. These counterfeit pills bear all the markings of popular prescription pain medications—US prosecutors referred to them as “pressed blues” because they look like blue oxycodone pills—but actually contain fentanyl. The pills give the criminal organizations broader access to the large prescription drug user population, which expands their market share and profit opportunities.41
This counterfeit pill form appears to be the current vehicle of choice. Of nine fentanyl seizures in August 2018 along the San Diego border, for instance, five were in pill form, significantly more than in previous months. Overall, US authorities along the San Diego-Tijuana border say that counterfeit pills represented more than 30 percent of the total fentanyl seizures in FY2018, up from five percent in FY 2017. They believe this upward trend will continue, since many fentanyl users are not purposely seeking the dangerous drug, and it generates such high returns. According to the Fentanyl Working Group, a collection of law enforcement agencies working out of the San Diego area, one kilogram of fentanyl, which costs $32,000, can make one million counterfeit pills with a street value of $20 million.42
The criminal market for counterfeit drugs is already huge and has relatively low barriers of entry. The United Nations estimates that as much as one-third of the world’s prescription drugs are counterfeit.43 In the case of Mexico, initial indications were that smaller criminal groups operating along the US-Mexico border were establishing “pharma cartels” and peddling their drugs over the internet. The larger criminal groups were taxing them for their operations, rather than exerting control at that time. That may change, especially as the larger criminal groups lose hegemony in other criminal markets and look to compete in new markets like fentanyl.
Seizure data suggests that the key trafficking route in Mexico is through the Baja California – California border area. Seizures by Mexican law enforcement have been concentrated around its northwest border with the United States, as well as Jalisco, Michoacán, and Sinaloa.44 Although still not a priority for law enforcement in Mexico (bilateral efforts to improve Mexico’s attention to the fentanyl problem and capacity to detect it are currently in full throttle), authorities have been seizing more fentanyl year on year, and there is enough data to illustrate a pattern.
Seizure figures acquired by InSight Crime via freedom of information requests show that the Federal Police and the army seized less than a kilogram of powdered fentanyl in 2013 and none in 2014. However, seizures spiked to nearly 43 kilograms in 2015 and rose to more than 114 kilograms through mid-2018. In terms of fentanyl-laced pills, none were reported until authorities seized some 36,000 in 2017, and over 33,000 through July 2018.
Seizure data from the US parallels that of Mexico. During 2016 and 2017, 75 percent of
the total poundage of fentanyl seized by US Customs and Border Protection (CBP) was
at the Southwest border. What’s more, fentanyl seizures by US officials on the US-Mexico border are skyrocketing, suggesting a sharp uptick in fentanyl trafficking from
Mexico. Law enforcement officials along the Southwest border have seen a 700 percent
increase in seizures, going from 6 seizures in 2015 to 54 in 2017. Part of this was the
result of training dogs to sniff out the fentanyl, but part was an increase in the amounts
being transported through this corridor.
Publicly available seizure data from the CBP, Homeland Security Investigations (HSI), and local level law enforcement suggests equally significant increases in fentanyl seizures nationwide. CBP’s Office of Field Operations and Border Patrol surpassed total fentanyl seizures for FY 2017 during the first months of FY 2018, and seizures have also increased in proportion to total heroin seizures. Additionally, Homeland Security Investigations reported 2,400 pounds of fentanyl seized in FY 2017.45
Local law enforcement agencies and federal agencies at the local level have similarly
reported drastic increases in fentanyl seizures over the last few years. The Office of the
Special Narcotics Prosecutor for the City of New York seized 35 pounds of fentanyl in
2016, and then 670 pounds in 2017, the vast majority of which (491 pounds) was pure
fentanyl not cut with any other substances.46
Though publicly available seizure data is hard to find, the trends suggested from an analysis of CBP, HSI, and SNP data all match up with increases in overdose, emergency department, and fentanyl use data nationwide. In looking through all these data sources, it is clear that the fentanyl epidemic has significantly worsened over the last few years, and much of that fentanyl is being manufactured or is transiting Mexico.
To be sure, some US sources believe that fentanyl is already a significant and growing revenue stream for Mexico’s criminal organizations. The perception that Mexican transnational criminal organizations (TCOs) are consciously taking advantage of an opportunity to traffic more fentanyl is backed up by wiretaps obtained by the Office of the Special Prosecutor in New York City that have found evidence that Mexican groups are hoping to capitalize on the widespread opioid addiction in the United States by trafficking fentanyl. 47
Across the board, reports and sources indicate that Mexican TCOs are intelligent enough to recognize fentanyl trafficking as a strong opportunity to increase their profit margins significantly. A DEA analysis of fentanyl profitability found that one kilogram of heroin stands to net around $80,000, while a kilogram of 99 percent pure fentanyl could net anywhere between $1,280,000 and $1,920,000.48
Trafficking in Mexico via Air Routes
Several cases of fentanyl seizures in airports, primarily in the Tijuana International Airport suggest that Mexican criminal groups are increasingly utilizing air routes—via parcel services—to transport fentanyl from places like Sinaloa and Mexico City and to airports located close to the US-Mexico border. Cases of fentanyl seizures at airports seem to suggest that the majority of fentanyl being trafficked within Mexico via air routes is in pill form.
In January 2018, members of Mexico’s Federal Police (Policía Federal – PF) and army (Secretaría de la Defensa Nacional – SEDENA) seized 1,500 fentanyl pills in the parcel area of the Tijuana International Airport, which has direct flights to Asia. The pills had allegedly been sent from Culiacán, Sinaloa.49 In March, authorities seized 300 fentanyl pills that were allegedly transported via parcel service from Mexico City to the Tijuana Airport.50
One of the reasons why criminal groups may be increasingly looking to transport fentanyl via air routes could be due to the small volumes of the drug that is trafficked compared to other drugs such as heroin and methamphetamine, which are usually shipped in greater quantities. Air routes are also quicker and, given the difficulty of inspecting thousands of packages that pass through airports on a daily basis, the risk of seizure is relatively limited. Finally, criminal groups of the type outlined below, have long trafficked illicit drugs through airports and therefore have both the contacts and the wherewithal to move fentanyl through these same spaces.
A senior DEA Mexico source told InSight Crime that they believe “the big cartels— CJNG and Sinaloa—are trafficking in large amounts because they control big swathes of land. They got all the contacts in China. They’re running their methamphetamine all the way over into China and Japan. They’ve got all the contacts already and the power.” A separate DEA source told InSight Crime in an email that, “Since the cartels have well established routes of entry into the US especially with heroin and methamphetamine…the trend we’ve noticed is fentanyl has often been infused or commingled with heroin shipments bound for the Northeast coast of the US.” 51
Former drug agents concur. Mike Vigil, who worked for the DEA in Mexico for over a decade, said, “Sinaloa and Jalisco New Generation are the ones primarily involved because they control the ports and have a nexus with the Chinese. For example, the CJNG controls Lázaro Cárdenas and Manzanillo, and also Veracruz. The Sinaloa Cartel controls a larger amount of [other] ports.”52
For its part, the CJNG is a conglomeration of criminal organizations. The core of the group traces its lineage to the Valencia brothers, an entrepreneurial family that formed what was once known as the Milenio Cartel. The Milenio Cartel has long specialized in the import and transport of precursor chemicals to produce and transport methamphetamine. After being displaced in the mid-2000s from their nominal headquarters, Michoacán, the Valencia brothers started operating from Jalisco. There they teamed up with remnants of a group that had worked with Ignacio “Nacho” Coronel, another specialist in methamphetamine production who had long worked with the Sinaloa Cartel.
Since its emergence, the CJNG has arguably become Mexico’s largest criminal organization. Using a combination of aggressive military tactics against its rivals and a promise of less predatory criminal activities with the public, the group has spread to a half dozen Mexico states. Among their target areas are Tijuana, the principal entry point for fentanyl to the United States; Guerrero, a key heroin production point for white powder heroin; Colima, home to the Manzanillo port, and Michoacán, a methamphetamine production hub.
CJNG’s background in methamphetamine and strong presence in states such as Michoacán, Colima, and Guerrero make it particularly well placed to deal in fentanyl. Manzanillo and Lázaro Cárdenas ports are thought to be at least partially controlled by the CJNG or groups closely allied to it. Michoacán also gives the group access to a network of ready methamphetamine producers, which may give it an added advantage in this market. Guerrero gives it access to white powder heroin production, which it can use to mix with fentanyl and export to the United States.
Some security analysts and officials also believe that recent violence in Mexico might be due to TCO efforts to aggressively expand into the United States heroin market— evidenced by sharp increases in opium poppy cultivation in Mexico from 2014 to 2017—and their recent efforts to move synthetic opioids like fentanyl.53 Mexican TCO's have apparently innovated and changed their opioid production processes in the last few years to move away from the traditional black or brown heroin they provided to cities in the western United States, and towards the more potent white powder heroin that had found a market in the Eastern states, 54 which is the type of heroin that can be cut with fentanyl.
Rivalries for markets and territory between the Sinaloa Cartel and CJNG have also been a major source of conflict and violence in Mexico in recent years, and some experts believe that the fentanyl market could be creating new battle lines. Since 2014, for instance, homicides have spiked in states such as Nayarit and Colima, two areas in dispute. In the small Pacific state of Nayarit, during the first six months of 2018, there was a 310 percent increase in homicides when compared to same time period in 2017. The small western Mexico state of Colima saw homicides rise by more than 900 percent in 2016, year on year.55 Security officials alleged that the catalyst of that violence was a feud between the Sinaloa Cartel, CJNG, and a faction of the Zetas for control of the Pacific port of Manzanillo.
CJNG is not monolithic. Currently, a splinter group of the CJNG known as the Nueva Plaza is battling the CJNG and Sinaloa in and around the Jalisco capital of Guadalajara for control over criminal economies.56 If it splinters, as other groups have, violence will likely worsen.
The fight, in part, stems from the fact that the Sinaloa Cartel—one of Mexico’s most storied criminal organizations—utilizes many of the same trafficking corridors along Mexico’s southwest border as CJNG. The Sinaloa Cartel also competes fiercely for these ports of entry and has established ties to Chinese precursor markets that produce methamphetamine as illustrated by the case of Zhenli Ye Gon, the accused methamphetamine producer who allegedly mislabeled the supplies that came through Mexican ports.57
Born in the traditional epicenter of opium and marijuana production, the Sinaloa Cartel was originally a group of families famously led by Joaquin “El Chapo” Guzman, Ismael “El Mayo” Zambada and the Beltrán Leyva brothers, who combined forces from production point to market. Its tentacles reached deep into the security forces and political circles making it the most formidable criminal organization in the country, until the CJNG began cutting into its power base, and authorities arrested or killed many of its leaders.
The fight between the two organizations is considerable in Tijuana, the key crossing point for fentanyl and the place where the umbrella group thesis gets its most significant empirical legs. The concentration of seizures at the San Diego port of entry, along with the similar composition, make-up, and markings on these seizures, point to the control of a small number of organizations like Sinaloa and CJNG, law enforcement officials in San Diego told InSight Crime.
Further inland, US officials assert that the Sinaloa Cartel controls critical distribution hubs in Phoenix, Los Angeles, Denver, and Chicago.58 It is from these hubs that heroin and fentanyl get broken down for further distribution and transportation usually via the highway system. 59 The DEA also notes, however, that both Mexican TCO's have started to utilize New Jersey as a transshipment point for heroin and fentanyl headed to Pittsburgh.60
Some cases in the United States have even been traced back to the Sinaloa Cartel. In the Southern District of Ohio, for example, a federal grand jury charged 12 individuals in a narcotics and money laundering conspiracy that allegedly distributed fentanyl from Mexico in Middletown, Ohio and sent proceeds back to the Sinaloa Cartel in Mexico.61 And in the Northern District of the same state, 20 people were indicted—allegedly with links to the Sinaloa Cartel—for their role in a fentanyl, heroin, and cocaine trafficking enterprise.62 A third case involved a part of the Sinaloa Cartel tagged the Gil Organization, reportedly headed by Jose Ruben Gil, which allegedly “turned the City of Buffalo into ground zero for fentanyl/heroin trafficking in NY State; fuelling drug addiction, overdoses and violent crime.”63 (See Case Study 2 – Gil Organization)
However, the connections made between distributors in the United States and the Sinaloa Cartel are not elaborated on in these legal cases, and it is notable that the CJNG has yet to appear in a fentanyl-related indictment. Some Mexican officials told InSight Crime that this is related to the simplistic notions of how criminal organizations work in Mexico.
“Sure, we are all Sinaloa. Why not?” a high-ranking judicial official, who spoke to InSight Crime on condition of anonymity, quipped.
The official pointed to the example of El Chapo whose involvement in the day-to-day operations of his suppliers and distributors was minimal, and the fact that there were continuous and significant frictions with his alleged partners in the Sinaloa Cartel.64 This complexity is reflected in our second thesis.
The cargo arrived from Mexico into San Diego and was then flown to Buffalo, where it was divided for distribution in various parts of New York,65 and, US authorities say, “turned the City of Buffalo into ground zero for fentanyl/heroin trafficking in NY State; fuelling drug addiction, overdoses and violent crime.”66
Specifically, the indictment says that “the pallets bearing illegal narcotics were secreted in containers sealed with foam or spray insulation to avoid detection by law enforcement.” Sea cucumbers are not consumed in large quantities in the northeast United States, a red flag for investigators.
Still, for a while, passing off the drugs as sea cucumber minimized the risk of searches by border authorities, noted the Albuquerque Journal in a series of reports on the Sinaloa Cartel.67 “Each port has a limited budget to pay for ‘spoilage’ during unsuccessful drug searches, so without specific information or indicators of drugs in the load of seafood, the (frozen) loads get processed rapidly,” the report said.
The organization also set up four front companies—three in California (Triton Foods Inc, Kamora Investment Enterprises, Fresh Choice Produce), and one in the State of New York (Corral Seafoods LLC)—to conceal its trafficking activities. The structure used these entities’ bank accounts to deposit and launder some $20 million in drug proceeds in a single year.68
US agents linked the network to the Sinaloa Cartel. Gil, a former mayor of the Izúcar de Matamoros town in Puebla, Mexico, had ties to the cartel, US authorities said. 69 “The Sinaloa Cartel’s reach from Mexico into US cities is most evident in this investigation,” DEA Special Agent in Charge James J. Hunt said.
However, authorities gave no details of what this connection was and refer to the organization as the “Gil/Aguirre DTO” in the indictment in which seventeen individuals were charged, 70 15 of which had been convicted by December 2018.71
A total of 8.5 kilograms of fentanyl were seized during the investigation, but authorities said the Gil network “trafficked thousands of kilograms of illegal narcotics, including heroin, fentanyl, and cocaine throughout the United States.” 72
The case demonstrated the agility of the larger Mexican drug trafficking networks. As the fentanyl market emerged, the alleged cartel affiliates could easily accommodate the drugs in their poly-drug loads.
There were also parts of the larger umbrella groups that specialized in methamphetamine prior to the fentanyl boom, namely the aforementioned Nacho Coronel, who was a top member of the Sinaloa Cartel and was killed in a shootout with Mexican military in July 2010; 74 and the Valencia brothers, who ran the Milenio Cartel and operated out of Michoacán prior to the emergence of the Familia Michoacana. Portions of both Nacho Coronel’s old organization and the Mileno Cartel are the core of the CJNG, but there are undoubtedly others who work primarily for the Sinaloa Cartel and others that remain independent.
The reconfiguration of these criminal groups is near constant. And while it is easy for crime analysts, law enforcement, and prosecutors to place them in large groups, the truth is that these are fluid relationships subject to a large number of changing variables. In fact, over the last several years, it is clear that the traditionally hierarchical drug trafficking organizations in Mexico have been replaced by flatter, more nimble organizations that are loosely networked. Within this framework, it is likely that Sinaloa and the CJNG outsource aspects of production and trafficking to smaller criminal groups.75 Sinaloa, in particular, is believed to operate with an increasingly horizontal structure in which local and regional gangs that specialize in particular operations are subcontracted for their services.76
Which of these subcontractors service the fentanyl distribution chain is harder to say. At first glance, it would appear that there is an overlap between the fentanyl and methamphetamine markets. Mexican groups with longstanding ties to the Chinese precursor chemical industry would seem to have a distinct advantage in this market for three reasons. First, these groups understand and have connections to the precursor chemical market in China (and India). Second, these groups already have established networks to transport and offload precursor chemicals in Mexico, and to transport and process the chemicals in clandestine laboratories. Third, these groups have established infrastructure in Mexico that can produce fentanyl relatively easily, according to both US and Mexico law enforcement sources consulted for this report.77
Mexico – Production and Transport
Once it arrives in Mexico, pure fentanyl is diluted or mixed with inert matter such as
lactose, dipyrone, or acetaminophen. The precursor chemicals that are imported are
moved to storage and production points in and around Mexico City, Guadalajara, and
Culiacán, according to US and Mexico law enforcement. As detailed in a later section,
groups that have traditionally imported precursors and processed methamphetamine
seem best positioned to take advantage of this market. The fentanyl is packed and shipped with other drugs. These poly-drug loads are transported by land, air or sea north to the US border where they cross in individual vehicles, container trucks, or via “mules.” Officials once believed that fentanyl was mixed with white powder heroin or camouflaged as heroin in Mexico. (Experts and law enforcement say that fentanyl cannot be combined with black tar heroin.) However, the most recent seizures show that this rarely happens anymore at the wholesale level. Instead, the fentanyl is moved on its own and mixed with other drugs once it is inside the United States. 40
Fentanyl is also pressed into pill form in Mexico for transport and distribution as counterfeit oxycodone or other prescription opioids. Some portion may arrive from China already in pill form, so no further processing is needed. These counterfeit pills bear all the markings of popular prescription pain medications—US prosecutors referred to them as “pressed blues” because they look like blue oxycodone pills—but actually contain fentanyl. The pills give the criminal organizations broader access to the large prescription drug user population, which expands their market share and profit opportunities.41
This counterfeit pill form appears to be the current vehicle of choice. Of nine fentanyl seizures in August 2018 along the San Diego border, for instance, five were in pill form, significantly more than in previous months. Overall, US authorities along the San Diego-Tijuana border say that counterfeit pills represented more than 30 percent of the total fentanyl seizures in FY2018, up from five percent in FY 2017. They believe this upward trend will continue, since many fentanyl users are not purposely seeking the dangerous drug, and it generates such high returns. According to the Fentanyl Working Group, a collection of law enforcement agencies working out of the San Diego area, one kilogram of fentanyl, which costs $32,000, can make one million counterfeit pills with a street value of $20 million.42
The criminal market for counterfeit drugs is already huge and has relatively low barriers of entry. The United Nations estimates that as much as one-third of the world’s prescription drugs are counterfeit.43 In the case of Mexico, initial indications were that smaller criminal groups operating along the US-Mexico border were establishing “pharma cartels” and peddling their drugs over the internet. The larger criminal groups were taxing them for their operations, rather than exerting control at that time. That may change, especially as the larger criminal groups lose hegemony in other criminal markets and look to compete in new markets like fentanyl.
Seizure data suggests that the key trafficking route in Mexico is through the Baja California – California border area. Seizures by Mexican law enforcement have been concentrated around its northwest border with the United States, as well as Jalisco, Michoacán, and Sinaloa.44 Although still not a priority for law enforcement in Mexico (bilateral efforts to improve Mexico’s attention to the fentanyl problem and capacity to detect it are currently in full throttle), authorities have been seizing more fentanyl year on year, and there is enough data to illustrate a pattern.
Seizure figures acquired by InSight Crime via freedom of information requests show that the Federal Police and the army seized less than a kilogram of powdered fentanyl in 2013 and none in 2014. However, seizures spiked to nearly 43 kilograms in 2015 and rose to more than 114 kilograms through mid-2018. In terms of fentanyl-laced pills, none were reported until authorities seized some 36,000 in 2017, and over 33,000 through July 2018.
Publicly available seizure data from the CBP, Homeland Security Investigations (HSI), and local level law enforcement suggests equally significant increases in fentanyl seizures nationwide. CBP’s Office of Field Operations and Border Patrol surpassed total fentanyl seizures for FY 2017 during the first months of FY 2018, and seizures have also increased in proportion to total heroin seizures. Additionally, Homeland Security Investigations reported 2,400 pounds of fentanyl seized in FY 2017.45
Though publicly available seizure data is hard to find, the trends suggested from an analysis of CBP, HSI, and SNP data all match up with increases in overdose, emergency department, and fentanyl use data nationwide. In looking through all these data sources, it is clear that the fentanyl epidemic has significantly worsened over the last few years, and much of that fentanyl is being manufactured or is transiting Mexico.
To be sure, some US sources believe that fentanyl is already a significant and growing revenue stream for Mexico’s criminal organizations. The perception that Mexican transnational criminal organizations (TCOs) are consciously taking advantage of an opportunity to traffic more fentanyl is backed up by wiretaps obtained by the Office of the Special Prosecutor in New York City that have found evidence that Mexican groups are hoping to capitalize on the widespread opioid addiction in the United States by trafficking fentanyl. 47
Across the board, reports and sources indicate that Mexican TCOs are intelligent enough to recognize fentanyl trafficking as a strong opportunity to increase their profit margins significantly. A DEA analysis of fentanyl profitability found that one kilogram of heroin stands to net around $80,000, while a kilogram of 99 percent pure fentanyl could net anywhere between $1,280,000 and $1,920,000.48
Trafficking in Mexico via Air Routes
Several cases of fentanyl seizures in airports, primarily in the Tijuana International Airport suggest that Mexican criminal groups are increasingly utilizing air routes—via parcel services—to transport fentanyl from places like Sinaloa and Mexico City and to airports located close to the US-Mexico border. Cases of fentanyl seizures at airports seem to suggest that the majority of fentanyl being trafficked within Mexico via air routes is in pill form.
In January 2018, members of Mexico’s Federal Police (Policía Federal – PF) and army (Secretaría de la Defensa Nacional – SEDENA) seized 1,500 fentanyl pills in the parcel area of the Tijuana International Airport, which has direct flights to Asia. The pills had allegedly been sent from Culiacán, Sinaloa.49 In March, authorities seized 300 fentanyl pills that were allegedly transported via parcel service from Mexico City to the Tijuana Airport.50
One of the reasons why criminal groups may be increasingly looking to transport fentanyl via air routes could be due to the small volumes of the drug that is trafficked compared to other drugs such as heroin and methamphetamine, which are usually shipped in greater quantities. Air routes are also quicker and, given the difficulty of inspecting thousands of packages that pass through airports on a daily basis, the risk of seizure is relatively limited. Finally, criminal groups of the type outlined below, have long trafficked illicit drugs through airports and therefore have both the contacts and the wherewithal to move fentanyl through these same spaces.
Illicit Networks in Mexico
The data, interviews, and review of the case files has led us to two intertwining theses
about who is responsible for the import, production, and transport of fentanyl to the
United States via Mexico. Each of these is based on limited data, as well as fragmented
and often anecdotal sources of information. Although it is our best current
approximation of the major trends in this dynamic market, it is by no means definitive.
Still, it provides us with a base from which to debate the evolution of this dangerous
drug market, which could be a game changer for drug trafficking organizations
worldwide.
Thesis 1: Mexico Umbrella Groups
There is a widespread consensus among all the US law enforcement officials
interviewed for this report that the Jalisco Cartel New Generation (Cartel de Jalisco
Nueva Generación - CJNG) and the Sinaloa Cartel in Mexico are the principal groups
responsible for the import and production, and its transport to the United States. These
two organizations can be considered umbrella groups: loosely knit networks with the
contacts, infrastructure, and wherewithal to move poly-drug loads across the stretch of
territory that represents the highest risk. This puts them in a unique position to control
this portion of the distribution chain and thus secure a good amount of its profit. A senior DEA Mexico source told InSight Crime that they believe “the big cartels— CJNG and Sinaloa—are trafficking in large amounts because they control big swathes of land. They got all the contacts in China. They’re running their methamphetamine all the way over into China and Japan. They’ve got all the contacts already and the power.” A separate DEA source told InSight Crime in an email that, “Since the cartels have well established routes of entry into the US especially with heroin and methamphetamine…the trend we’ve noticed is fentanyl has often been infused or commingled with heroin shipments bound for the Northeast coast of the US.” 51
Former drug agents concur. Mike Vigil, who worked for the DEA in Mexico for over a decade, said, “Sinaloa and Jalisco New Generation are the ones primarily involved because they control the ports and have a nexus with the Chinese. For example, the CJNG controls Lázaro Cárdenas and Manzanillo, and also Veracruz. The Sinaloa Cartel controls a larger amount of [other] ports.”52
For its part, the CJNG is a conglomeration of criminal organizations. The core of the group traces its lineage to the Valencia brothers, an entrepreneurial family that formed what was once known as the Milenio Cartel. The Milenio Cartel has long specialized in the import and transport of precursor chemicals to produce and transport methamphetamine. After being displaced in the mid-2000s from their nominal headquarters, Michoacán, the Valencia brothers started operating from Jalisco. There they teamed up with remnants of a group that had worked with Ignacio “Nacho” Coronel, another specialist in methamphetamine production who had long worked with the Sinaloa Cartel.
Since its emergence, the CJNG has arguably become Mexico’s largest criminal organization. Using a combination of aggressive military tactics against its rivals and a promise of less predatory criminal activities with the public, the group has spread to a half dozen Mexico states. Among their target areas are Tijuana, the principal entry point for fentanyl to the United States; Guerrero, a key heroin production point for white powder heroin; Colima, home to the Manzanillo port, and Michoacán, a methamphetamine production hub.
CJNG’s background in methamphetamine and strong presence in states such as Michoacán, Colima, and Guerrero make it particularly well placed to deal in fentanyl. Manzanillo and Lázaro Cárdenas ports are thought to be at least partially controlled by the CJNG or groups closely allied to it. Michoacán also gives the group access to a network of ready methamphetamine producers, which may give it an added advantage in this market. Guerrero gives it access to white powder heroin production, which it can use to mix with fentanyl and export to the United States.
Some security analysts and officials also believe that recent violence in Mexico might be due to TCO efforts to aggressively expand into the United States heroin market— evidenced by sharp increases in opium poppy cultivation in Mexico from 2014 to 2017—and their recent efforts to move synthetic opioids like fentanyl.53 Mexican TCO's have apparently innovated and changed their opioid production processes in the last few years to move away from the traditional black or brown heroin they provided to cities in the western United States, and towards the more potent white powder heroin that had found a market in the Eastern states, 54 which is the type of heroin that can be cut with fentanyl.
Rivalries for markets and territory between the Sinaloa Cartel and CJNG have also been a major source of conflict and violence in Mexico in recent years, and some experts believe that the fentanyl market could be creating new battle lines. Since 2014, for instance, homicides have spiked in states such as Nayarit and Colima, two areas in dispute. In the small Pacific state of Nayarit, during the first six months of 2018, there was a 310 percent increase in homicides when compared to same time period in 2017. The small western Mexico state of Colima saw homicides rise by more than 900 percent in 2016, year on year.55 Security officials alleged that the catalyst of that violence was a feud between the Sinaloa Cartel, CJNG, and a faction of the Zetas for control of the Pacific port of Manzanillo.
CJNG is not monolithic. Currently, a splinter group of the CJNG known as the Nueva Plaza is battling the CJNG and Sinaloa in and around the Jalisco capital of Guadalajara for control over criminal economies.56 If it splinters, as other groups have, violence will likely worsen.
The fight, in part, stems from the fact that the Sinaloa Cartel—one of Mexico’s most storied criminal organizations—utilizes many of the same trafficking corridors along Mexico’s southwest border as CJNG. The Sinaloa Cartel also competes fiercely for these ports of entry and has established ties to Chinese precursor markets that produce methamphetamine as illustrated by the case of Zhenli Ye Gon, the accused methamphetamine producer who allegedly mislabeled the supplies that came through Mexican ports.57
Born in the traditional epicenter of opium and marijuana production, the Sinaloa Cartel was originally a group of families famously led by Joaquin “El Chapo” Guzman, Ismael “El Mayo” Zambada and the Beltrán Leyva brothers, who combined forces from production point to market. Its tentacles reached deep into the security forces and political circles making it the most formidable criminal organization in the country, until the CJNG began cutting into its power base, and authorities arrested or killed many of its leaders.
The fight between the two organizations is considerable in Tijuana, the key crossing point for fentanyl and the place where the umbrella group thesis gets its most significant empirical legs. The concentration of seizures at the San Diego port of entry, along with the similar composition, make-up, and markings on these seizures, point to the control of a small number of organizations like Sinaloa and CJNG, law enforcement officials in San Diego told InSight Crime.
Further inland, US officials assert that the Sinaloa Cartel controls critical distribution hubs in Phoenix, Los Angeles, Denver, and Chicago.58 It is from these hubs that heroin and fentanyl get broken down for further distribution and transportation usually via the highway system. 59 The DEA also notes, however, that both Mexican TCO's have started to utilize New Jersey as a transshipment point for heroin and fentanyl headed to Pittsburgh.60
Some cases in the United States have even been traced back to the Sinaloa Cartel. In the Southern District of Ohio, for example, a federal grand jury charged 12 individuals in a narcotics and money laundering conspiracy that allegedly distributed fentanyl from Mexico in Middletown, Ohio and sent proceeds back to the Sinaloa Cartel in Mexico.61 And in the Northern District of the same state, 20 people were indicted—allegedly with links to the Sinaloa Cartel—for their role in a fentanyl, heroin, and cocaine trafficking enterprise.62 A third case involved a part of the Sinaloa Cartel tagged the Gil Organization, reportedly headed by Jose Ruben Gil, which allegedly “turned the City of Buffalo into ground zero for fentanyl/heroin trafficking in NY State; fuelling drug addiction, overdoses and violent crime.”63 (See Case Study 2 – Gil Organization)
However, the connections made between distributors in the United States and the Sinaloa Cartel are not elaborated on in these legal cases, and it is notable that the CJNG has yet to appear in a fentanyl-related indictment. Some Mexican officials told InSight Crime that this is related to the simplistic notions of how criminal organizations work in Mexico.
“Sure, we are all Sinaloa. Why not?” a high-ranking judicial official, who spoke to InSight Crime on condition of anonymity, quipped.
The official pointed to the example of El Chapo whose involvement in the day-to-day operations of his suppliers and distributors was minimal, and the fact that there were continuous and significant frictions with his alleged partners in the Sinaloa Cartel.64 This complexity is reflected in our second thesis.
CASE STUDY
A Sinaloa Connection
Between June 2013 and August 2016, José Ruben Gil and his network moved poly-drug
loads—including fentanyl—into the United States by passing them off as sea cucumber. The cargo arrived from Mexico into San Diego and was then flown to Buffalo, where it was divided for distribution in various parts of New York,65 and, US authorities say, “turned the City of Buffalo into ground zero for fentanyl/heroin trafficking in NY State; fuelling drug addiction, overdoses and violent crime.”66
Specifically, the indictment says that “the pallets bearing illegal narcotics were secreted in containers sealed with foam or spray insulation to avoid detection by law enforcement.” Sea cucumbers are not consumed in large quantities in the northeast United States, a red flag for investigators.
Still, for a while, passing off the drugs as sea cucumber minimized the risk of searches by border authorities, noted the Albuquerque Journal in a series of reports on the Sinaloa Cartel.67 “Each port has a limited budget to pay for ‘spoilage’ during unsuccessful drug searches, so without specific information or indicators of drugs in the load of seafood, the (frozen) loads get processed rapidly,” the report said.
The organization also set up four front companies—three in California (Triton Foods Inc, Kamora Investment Enterprises, Fresh Choice Produce), and one in the State of New York (Corral Seafoods LLC)—to conceal its trafficking activities. The structure used these entities’ bank accounts to deposit and launder some $20 million in drug proceeds in a single year.68
US agents linked the network to the Sinaloa Cartel. Gil, a former mayor of the Izúcar de Matamoros town in Puebla, Mexico, had ties to the cartel, US authorities said. 69 “The Sinaloa Cartel’s reach from Mexico into US cities is most evident in this investigation,” DEA Special Agent in Charge James J. Hunt said.
However, authorities gave no details of what this connection was and refer to the organization as the “Gil/Aguirre DTO” in the indictment in which seventeen individuals were charged, 70 15 of which had been convicted by December 2018.71
A total of 8.5 kilograms of fentanyl were seized during the investigation, but authorities said the Gil network “trafficked thousands of kilograms of illegal narcotics, including heroin, fentanyl, and cocaine throughout the United States.” 72
The case demonstrated the agility of the larger Mexican drug trafficking networks. As the fentanyl market emerged, the alleged cartel affiliates could easily accommodate the drugs in their poly-drug loads.
Thesis 2: Multi-layered Import,
Production, and Transport Networks
The reality of the Mexican underworld is that there is a plethora of smaller
organizations that are subcontracted by the umbrella groups like the Sinaloa Cartel and
the CJNG. These include remnants of organizations that once specialized in the import
of precursors, and the production and export of methamphetamine, such as the Familia Michoacana or the Knights Templar.73 Parts of both of those organizations were subsumed by the CJNG and the Sinaloa Cartel or continue to operate independently,
Mexican and US law enforcement told InSight Crime. There were also parts of the larger umbrella groups that specialized in methamphetamine prior to the fentanyl boom, namely the aforementioned Nacho Coronel, who was a top member of the Sinaloa Cartel and was killed in a shootout with Mexican military in July 2010; 74 and the Valencia brothers, who ran the Milenio Cartel and operated out of Michoacán prior to the emergence of the Familia Michoacana. Portions of both Nacho Coronel’s old organization and the Mileno Cartel are the core of the CJNG, but there are undoubtedly others who work primarily for the Sinaloa Cartel and others that remain independent.
The reconfiguration of these criminal groups is near constant. And while it is easy for crime analysts, law enforcement, and prosecutors to place them in large groups, the truth is that these are fluid relationships subject to a large number of changing variables. In fact, over the last several years, it is clear that the traditionally hierarchical drug trafficking organizations in Mexico have been replaced by flatter, more nimble organizations that are loosely networked. Within this framework, it is likely that Sinaloa and the CJNG outsource aspects of production and trafficking to smaller criminal groups.75 Sinaloa, in particular, is believed to operate with an increasingly horizontal structure in which local and regional gangs that specialize in particular operations are subcontracted for their services.76
Which of these subcontractors service the fentanyl distribution chain is harder to say. At first glance, it would appear that there is an overlap between the fentanyl and methamphetamine markets. Mexican groups with longstanding ties to the Chinese precursor chemical industry would seem to have a distinct advantage in this market for three reasons. First, these groups understand and have connections to the precursor chemical market in China (and India). Second, these groups already have established networks to transport and offload precursor chemicals in Mexico, and to transport and process the chemicals in clandestine laboratories. Third, these groups have established infrastructure in Mexico that can produce fentanyl relatively easily, according to both US and Mexico law enforcement sources consulted for this report.77
As noted, there are numerous organizations with background in the importation of the
chemicals needed to make methamphetamine and the production of that drug in Mexico
that has likely helped them establish the contacts and knowledge base that makes a step
into the fentanyl market the next logical one. What’s less clear is whether this step has
been taken, and there is little publicly available information to make that
determination.
Authorities seized a fentanyl lab in Mexico in Culiacán, Mexico, in 2017, but destroyed it before US officials could inspect it and no further information was provided. 78 In September 2018, Mexican and US counterdrug authorities raided what they said was the first ever carfentanil/fentanyl laboratory in Baja California, arresting two suspected associates of the Sinaloa Cartel, including a Bulgarian biochemist. (See Case Study 3 – A Mexican Carfentanil/Fentanyl Factory) The small laboratory was allegedly producing counterfeit pills, which were being shipped to the US Northeast for sale; it did not appear to be producing methamphetamine or any other drugs. And in December 2018, the Attorney General’s Office said authorities made a third seizure of a lab in northwest Mexico City where they arrested four suspects and seized chemicals; no information was given about the capacity of the lab or its potential purveyors.79 These are the only known fentanyl drug laboratory seizures in Mexico.
Nonetheless, there is anecdotal evidence of a symbiotic relationship between methamphetamine and fentanyl amongst end-users. In some instances, law enforcement officials in the United States spoke of methamphetamine being a path to fentanyl. Other evidence points to users moving from fentanyl to methamphetamine, with opioid abuse evolving into methamphetamine use in some areas.80 In some of the states hit hardest by fentanyl, particularly Ohio and Kentucky, methamphetamine seizures and treatment admissions have more than doubled from 2014 to 2017 81 — thus keeping pace with ascendant fentanyl markets in those states.
However, determining the exact network responsible for the movement of precursors and production of fentanyl in Mexico is difficult since there are so few seizures in Mexico of drug loads or labs containing fentanyl. Mixing fentanyl into any of these drug supply chains could happen at various junctures of the distribution chain by whomever has access to that particular supply of drugs. And since the poly-drug seizures at the US border include heroin and methamphetamine, it is hard to know which legacy groups are responsible for fentanyl production.
To further complicate matters, transport networks may be subcontracted, according to Mexican law enforcement. They indicated that the Sinaloa Cartel and other major trafficking groups may be paying a fee to the traditionally powerful criminal operation in Tijuana, the Arellano Felix Organization, to use that smuggling corridor or their networks. For its part, the CJNG seems to have taken a more belligerent approach towards the same corridor. 82 To a much lesser extent, what’s left of the Beltrán Leyva Organization (BLO) might also be involved through the formation of alliances with CJNG, Juarez Cartel, and remnants of the Zetas to move drugs across the border and maintain distribution points in Phoenix, Los Angeles, Chicago, and Atlanta.83
In general, Mexican authorities downplay the importance of fentanyl. Significantly, interviews with Mexico law enforcement suggest that fentanyl is still not a priority for the Federal Police or the Defense Secretary when it comes to seizing drugs and attacking major trafficking organizations. Neither do they believe that it is a major source of income or line of activity for Mexico’s criminal organizations.
A high-ranking official in the Federal Police described the income stream of the major Mexican criminal organizations as still primarily dominated by cocaine and heroin trafficking and a fast-shrinking marijuana business, while smaller, second tier organizations have grown more dependent on extortion and retailing. Another official in the Federal Police agreed with this assessment but warned that given the dynamic nature of illicit markets, the situation might change in the near future, as the fragmentation of the criminal organizations continues. Both officials and another high ranking officer from Attorney General’s Office (Procuraduría General de la República – PGR) concurred.84
To be sure, the opioid market in Mexico is already going through a period of upheaval, which could be related to the surge in fentanyl and further illustrates the fragmented nature of these criminal organizations. Prices of opium gum, the sticky paste that is the source of heroin, have dropped considerably in recent months,85 enough that some producers are turning to marijuana.86 One theory of the drop is that criminal groups are shifting to fentanyl,87 but any conclusions would be premature. There has been a four- fold rise in poppy production since 2013, according to DEA estimates,88 which could account for a similar drop in opium gum prices.89 In the oversupplied market, buyers may be squeezing suppliers, which again, suggests a much more atomized market with multiple tiers than single-tiered, monolithic groups controlling the entire value chain. The era of the all-controlling cartel may be at an end.
The investigations led to seizures in California and uncovered connections between Kulkin’s network and the Sinaloa Cartel, including strains of other Sinaloa-related distribution networks operating in the United States. In August 2018, US counterdrug agents, working with Mexican authorities, developed a strategy to arrest Kulkin in Mexico, as well as other parts of his distribution network in Massachusetts.
In September 2018, after locating his apartment in Mexicali, Mexican authorities arrested Ivan Arredondo-Ramirez who tried to bribe his way to freedom before being taken into custody. Arredondo-Ramirez later admitted to being Kulkin’s boss. Soon after, authorities arrested Kulkin and found the carfentanil/fentanyl laboratory. There they seized as much as 20,000 counterfeit pills and a pill press, among other items, which Arredondo-Ramirez and Kulkin allegedly used to produce counterfeit pills, which they sold in the US.
The case illustrates two important aspects of the fentanyl trade. First, that networks can be small, subsets of larger criminal organizations. Second, that these small subsets— operating in relatively small labs—can feed large markets.
That said, conversations with officials across all branches of the US government
indicate that fentanyl misuse, either purposeful or not, is larger than what current
estimates would suggest. This assertion is backed up by overdose data that indicates
drastic increases in synthetic opioid-related deaths, a category dominated by fentanyl,
as well non-fatal overdoses. Since 2014, emergency department non-fatal overdose
visit data suggests increases related to fentanyl in the past few years, and rising rates
of fentanyl-family substance seizure samples nationwide similarly suggest a growing
market.
93 Additionally, in interviews with public health officials and advocates, it was
suggested that the potential size of the fentanyl market could be an increasingly
significant portion of the 2.1 million people with opioid use disorders given the nature
of addiction as a disease and market saturation of fentanyl in certain regions of the
country.
The current fentanyl epidemic is largely concentrated in regions of the country where white powder heroin and prescription pill misuse dominates the market—Appalachia and the Northeast. In a 2016 CDC study, for instance, Northeastern states reported the highest percentage of opioid overdose deaths involving fentanyl, ranging from 60–90 percent of all opioid overdose deaths; midwestern states also exhibited high percentages of opioid overdose deaths involving fentanyl. In many of these states, deaths from fentanyl alone have started to outnumber deaths from fentanyl cut into other substances, potentially suggesting a unique fentanyl and fentanyl analogue market.94 95 These regions of the country have similarly seen the largest increases in non-fatal opioid-related emergency department visits 96 and fentanyl seizures. 97
The most critical exceptions to this rule happen in the Northeastern United States. In Massachusetts and Connecticut, the epicenter of the US fentanyl epidemic, Dominican TCOs serve as mid-level distributors for cocaine and white powder heroin, which is the type of heroin cut with fentanyl. Dominican TCOs obtain multi-hundred kilogram quantities of heroin, heroin cut with fentanyl, and cocaine from Mexican wholesalers in New York City and other hubs, which they then sell in increments to local street gang clients for local street sales.99 DEA sources in Mexico also told InSight Crime that Dominican TCOs go to the US-Mexico border and have even traveled to Mexico to get the fentanyl.
In Appalachia, the local-level distribution is a little more diffuse. Interviews with local law enforcement in Hamilton County and Kentucky indicate that Mexican-sourced heroin, cocaine, and methamphetamine cut with fentanyl, as well as fentanyl in powder and pill form, typically comes in from Chicago and then spreads to cities like Toledo,Columbus, Cincinnati, and south to West Virginia.100 In smaller Appalachian communities, local drug peddling organizations tend to be composed of family units. They obtain fentanyl in small quantities from Mexican nationals in larger cities, bring it back to their communities, and then rely on people with substance use disorders for local street sales.101 These smaller, family-run distribution networks typically do not target their sales; whatever they are supplied with will inevitably find a market, though there’s evidence to suggest that they target communities with pill problems when they sell counterfeit pills with fentanyl.102
The DEA also believes that criminal groups have moved beyond cutting white powder heroin with fentanyl. These days it is increasingly more common for fentanyl to be mixed with adulterants and sold as heroin, with no heroin present in the product.103 This observation is backed up by the NFLIS data which shows fentanyl-only exhibits far outstripped heroin cut with fentanyl exhibits in 2016.104
Interviews with local law enforcement and public health officials in these regions
suggest that fentanyl-family substances have become a dominant and unique substance
in local opioid markets, and that criminal groups are also strategically cutting it into
ascendant local prescription pill, cocaine, and methamphetamine markets to create a
larger opioid and fentanyl dependent population.105 106 According to Dr. Nora Volkow,
the Director of the National Institute of Drug Abuse, “Fentanyl is being used to lace a
wide variety of drugs, including marijuana, and because of the [high] addictiveness
of…something like fentanyl, you will rapidly become dependent on that drug. And then that leads you to crave it, even though you don’t know it is the opioid, you’ll crave the
drug you had that sensation with.”107
This view is echoed by a local law enforcement official in Hamilton County, Ohio. “Half of the methamphetamine and crack cocaine overdoses [in Hamilton County] have had fentanyl in them,” the official said. “Synthetic opiates are the money-makers for most of the cartels since it is what most people are addicted to and you can hit different demographics by starting to mix fentanyl with cocaine and methamphetamine.” 108
Notably, according to the 2018 National Drug Threat Assessment, it is the criminal wholesalers in the US, and not Mexico, who appear to be lacing the drugs in the US with fentanyl. “Although fentanyl is often seized as a part of poly-drug loads (generally cocaine, heroin, and methamphetamine), fentanyl mixtures with other illicit drugs are very uncommon at the wholesale level,” the DEA wrote. “This indicates the mixing of fentanyl with other illicit drugs is most frequently done inside the United States and is not representative of any definitive Mexican TCO strategy.”
It is also important to note that Mexico-sourced fentanyl does not dominate the market in Appalachia, and likely not in the Northeast. Interviews with law enforcement in Appalachia suggested what is likely a fairly evenly split local market between fentanyl brought in via mail and Mexican-sourced fentanyl.109 110 It is likely a similar situation in the Northeast.
Still, the Mexican TCOs are hoping to use fentanyl to further capitalize on widespread opioid addiction in the United States.111 This is clearest in its increasing production and distribution of counterfeit pills, but they are also undoubtedly aware of the potential of using fentanyl as an additive for other drugs as well. Given the potency and highly addictive nature of fentanyl, studies and testimony from people with opioid use disorders indicate that over time people are willing to take fentanyl 112 or actively seek it out, 113 and that they seek to counteract it is lethality by controlling their dosage or consuming it in groups where there might be naloxone present.114
Authorities also executed a warrant to search his apartment on Pleasant Valley Street, Methuen, where they found another 30 kilograms of fentanyl, most of it wrapped in one kilogram-sized packages and hidden throughout the apartment. The drugs, the Justice Department said, were worth an estimated $29 million. In addition, they found a 9mm Millennium G2 handgun, ammunition, and a gas mask.
While surveilling the apartment, authorities also observed and arrested José Rodríguez, when he arrived with $20,000—what US prosecutors say was “half of the transportation costs of a narcotics shipment” to Morell-Oneill.
The pair are part of a slew of Dominican nationals who are spread throughout the Northeast, increasingly in small towns like Methuen, population 50,000, and Lawrence, population 80,000, which one DEA officer described as the “epicenter” of fentanyl distribution where Dominicans come in using false IDs as Morrell-Oneill did. “They own the land,” the officer told InSight Crime of the Dominicans.
The officer said the Dominican networks use a rudimentary process—magic bullet blenders, an industrial strength air purifier, and a “narcan” 116—to lace heroin with fentanyl or simply eliminate the heroin altogether, since the fentanyl is so strong. “Pretty soon, you will stop hearing about heroin,” he said. “They’re never going back to heroin.”
A kilo of fentanyl can yield as much as $1.3 million, while a kilo of heroin might yield $75,000, the agent said. Given the profit margins, Mexican organizations may be moving into the wholesale business in the Northeast, both the DEA and US prosecutors say.
Authorities are worried that a violent power struggle has already begun. “We know who is going to win that fight,” a US prosecutor said, referring to the firepower of the Mexican groups.
36s
Despite the low seizure count, it is likely that maritime trafficking of fentanyl directly into the United States is a transport method that’s utilized—though probably at far lower rates than mail or land ports of entry on the Southwest border. For example, in June 2018, Customs and Border Protection officials seized 110 pounds of fentanyl at the Port of Philadelphia.119 The fentanyl was discovered by a CBP narcotics detector dog in a shipment of iron oxide that arrived from China. 120
This is the only instance of maritime fentanyl trafficking found by InSight Crime, though given how it recent it was, it could indicate efforts by Chinese groups to move fentanyl in larger quantities directly into the United States. What’s more, authorities consulted about this seizure could not say whether it was an anomaly or the norm.
Furthermore, recent indictments cited in Part I suggest that Chinese nationals have set up regional distribution networks in the United States that are responsible for broader distribution of fentanyl and fentanyl analogues sent via mail, then negotiated and moved via the dark web on the domestic level.124 Finally, there’s also some evidence of fentanyl and precursors getting sent to individuals near the Southwest border, brought into Mexico to be cut into the heroin, cocaine, and methamphetamine supply chain, and then brought back to the United States, though it is unclear how pervasive this is. 125
In sum, fentanyl trafficked to the US directly from China is significant, and there is still no consensus on whether land-based or postal fentanyl is responsible for the bulk of the fentanyl consumed in the US. Local law enforcement in Ohio and Kentucky, for example, told InSight Crime that fentanyl trafficked via mail might be just as significant a portion of their local fentanyl supply as fentanyl trafficked via the southwest border via Mexico. 126 127 For its part, the US-China Economic and Security Review Commission, in its November 2018, report, stated simply: “China remains the largest source of illicit fentanyl and fentanyl-like substances in the United States.” 128
However, federal authorities in San Diego and New Hampshire contradicted this assessment.129 Indeed, numerous government officials and counterdrug agents throughout the region, 130 as well as prominent public health advocates, have also said Mexican groups are behind the bulk of the fentanyl arriving to the US. 131
Part of the debate stems from data collection. Although trafficked in smaller quantities, fentanyl delivered via mail from China is largely already in powder form 132 and averages 90 percent purity, thus making it far more potent and likely more profitable than fentanyl brought across the southwest border, which has an average of 7 percent purity.133 Nonetheless, seizure data does not reflect this massive difference in purity; instead, CBP measures them as if they were equal, law enforcement officials told InSight Crime.
In either case, Chinese online sellers of fentanyl explicitly prefer shipping via express mail services, which are largely governed by the postal administration and include the United States Postal Service and China Post.134 This preference is for two prominent reasons: the United States Postal Service handles four times the amount of incoming mail than do express consignment carriers like DHS, FedEx, or UPS combined; and the United States Postal Service is not yet able to obtain advanced electronic data on all incoming packages, which makes detection of illicit substances far more difficult.135
Customs and Border Protection seizure data confirms this preference. Fentanyl seizures from USPS packages far outpace seizures from express consignment carriers, although the total weight of seizures on express consignment carriers was twice that of express mail. This suggests that larger fentanyl mail shipments might be sent through consignment carriers like DHS, FedEx, and UPS.136
Interviews and testimony from federal government officials indicate that the trafficking of fentanyl via mail could represent “the future of the drug problem in America,” and the democratization of drug trafficking.137 It is the opinion of some that the current fentanyl epidemic could be a watershed moment where the hierarchical drug trafficking organizations that have traditionally dominated the drug trade may no longer have a monopoly on the supply of illicit drugs.138
In some respects, fentanyl is like the computer microchip market. There is the potential of producers to create smaller and smaller analogues, reducing the need to use large criminal infrastructures to ship the product to its consumers. This is already happening: Carfentanil, a fentanyl analogue, is an estimated 100 times more potent than fentanyl, and has been detected in places as disparate as San Diego and New Hampshire.139 Reports of carfentanil have also risen from none in 2015, to over 6,000 incident reports in 2017.140
2. Specifically, to help combat the trafficking of fentanyl and its analogues, Mexico could: increase capacity to detect and test for fentanyl and its analogues at its laboratories and where it seizes drugs; beef up detection at its ports for fentanyl and precursors; and open the door to inspections of seized laboratories and chemicals.
3. Pressure China to participate more actively in criminal investigations to deter Chinese producers and exporters, and actively update precursor watchlists and prohibitions. As the President’s Commission on Combating Drug Addiction and the Opioid Crisis wrote, “We are losing this fight predominately through China. This must become a top tier diplomatic issue with the Chinese; American lives are at stake and it threatens our national security.”141
4. Invest in research and data collection to better understand this drug trafficking phenomenon. In many ways, fentanyl represents the democratization of drug trafficking, offering small and large groups myriad ways of exploiting markets. However, the data on production, trafficking, and consumption is sparse at best. https://www.insightcrime.org/wp-content/uploads/2019/02/Fentanyl-Report-InSight-Crime-19-02-11.pdf
Authorities seized a fentanyl lab in Mexico in Culiacán, Mexico, in 2017, but destroyed it before US officials could inspect it and no further information was provided. 78 In September 2018, Mexican and US counterdrug authorities raided what they said was the first ever carfentanil/fentanyl laboratory in Baja California, arresting two suspected associates of the Sinaloa Cartel, including a Bulgarian biochemist. (See Case Study 3 – A Mexican Carfentanil/Fentanyl Factory) The small laboratory was allegedly producing counterfeit pills, which were being shipped to the US Northeast for sale; it did not appear to be producing methamphetamine or any other drugs. And in December 2018, the Attorney General’s Office said authorities made a third seizure of a lab in northwest Mexico City where they arrested four suspects and seized chemicals; no information was given about the capacity of the lab or its potential purveyors.79 These are the only known fentanyl drug laboratory seizures in Mexico.
Nonetheless, there is anecdotal evidence of a symbiotic relationship between methamphetamine and fentanyl amongst end-users. In some instances, law enforcement officials in the United States spoke of methamphetamine being a path to fentanyl. Other evidence points to users moving from fentanyl to methamphetamine, with opioid abuse evolving into methamphetamine use in some areas.80 In some of the states hit hardest by fentanyl, particularly Ohio and Kentucky, methamphetamine seizures and treatment admissions have more than doubled from 2014 to 2017 81 — thus keeping pace with ascendant fentanyl markets in those states.
However, determining the exact network responsible for the movement of precursors and production of fentanyl in Mexico is difficult since there are so few seizures in Mexico of drug loads or labs containing fentanyl. Mixing fentanyl into any of these drug supply chains could happen at various junctures of the distribution chain by whomever has access to that particular supply of drugs. And since the poly-drug seizures at the US border include heroin and methamphetamine, it is hard to know which legacy groups are responsible for fentanyl production.
To further complicate matters, transport networks may be subcontracted, according to Mexican law enforcement. They indicated that the Sinaloa Cartel and other major trafficking groups may be paying a fee to the traditionally powerful criminal operation in Tijuana, the Arellano Felix Organization, to use that smuggling corridor or their networks. For its part, the CJNG seems to have taken a more belligerent approach towards the same corridor. 82 To a much lesser extent, what’s left of the Beltrán Leyva Organization (BLO) might also be involved through the formation of alliances with CJNG, Juarez Cartel, and remnants of the Zetas to move drugs across the border and maintain distribution points in Phoenix, Los Angeles, Chicago, and Atlanta.83
In general, Mexican authorities downplay the importance of fentanyl. Significantly, interviews with Mexico law enforcement suggest that fentanyl is still not a priority for the Federal Police or the Defense Secretary when it comes to seizing drugs and attacking major trafficking organizations. Neither do they believe that it is a major source of income or line of activity for Mexico’s criminal organizations.
A high-ranking official in the Federal Police described the income stream of the major Mexican criminal organizations as still primarily dominated by cocaine and heroin trafficking and a fast-shrinking marijuana business, while smaller, second tier organizations have grown more dependent on extortion and retailing. Another official in the Federal Police agreed with this assessment but warned that given the dynamic nature of illicit markets, the situation might change in the near future, as the fragmentation of the criminal organizations continues. Both officials and another high ranking officer from Attorney General’s Office (Procuraduría General de la República – PGR) concurred.84
To be sure, the opioid market in Mexico is already going through a period of upheaval, which could be related to the surge in fentanyl and further illustrates the fragmented nature of these criminal organizations. Prices of opium gum, the sticky paste that is the source of heroin, have dropped considerably in recent months,85 enough that some producers are turning to marijuana.86 One theory of the drop is that criminal groups are shifting to fentanyl,87 but any conclusions would be premature. There has been a four- fold rise in poppy production since 2013, according to DEA estimates,88 which could account for a similar drop in opium gum prices.89 In the oversupplied market, buyers may be squeezing suppliers, which again, suggests a much more atomized market with multiple tiers than single-tiered, monolithic groups controlling the entire value chain. The era of the all-controlling cartel may be at an end.
CASE STUDY –
A Mexicali Fentanyl Production Facility
In January 2018, US authorities began investigating a Bulgarian biochemist named Antov
Petrov Kulkin who was allegedly running a small carfentanil/fentanyl laboratory in
Mexico. Working undercover, multiple US counterdrug agents in New England, California,
Santo Domingo, and Tijuana began interacting with the network. Eventually, they
conducted confidential undercover source meetings in Santo Domingo and Tijuana, and
undercover pill purchases in California. The investigations led to seizures in California and uncovered connections between Kulkin’s network and the Sinaloa Cartel, including strains of other Sinaloa-related distribution networks operating in the United States. In August 2018, US counterdrug agents, working with Mexican authorities, developed a strategy to arrest Kulkin in Mexico, as well as other parts of his distribution network in Massachusetts.
In September 2018, after locating his apartment in Mexicali, Mexican authorities arrested Ivan Arredondo-Ramirez who tried to bribe his way to freedom before being taken into custody. Arredondo-Ramirez later admitted to being Kulkin’s boss. Soon after, authorities arrested Kulkin and found the carfentanil/fentanyl laboratory. There they seized as much as 20,000 counterfeit pills and a pill press, among other items, which Arredondo-Ramirez and Kulkin allegedly used to produce counterfeit pills, which they sold in the US.
The case illustrates two important aspects of the fentanyl trade. First, that networks can be small, subsets of larger criminal organizations. Second, that these small subsets— operating in relatively small labs—can feed large markets.
Part III
Fentanyl - The Destination
This section covers the different ways in which fentanyl arrives to the United States for
consumption. Though there’s a lack of clarity in determining how much of which
fentanyl-family product is exported the most and which route it takes, related data
seems to illustrate that fentanyl coming via Mexico is surging but that Mexican criminal
groups play a limited role at the distribution level in areas where fentanyl is most
prevalent. Instead, they seem to rely on Dominican networks, who have long dominated
the heroin market in the northeast. In addition, pure fentanyl and fentanyl analogues,90
as a powder or in pill form, are also being sent from China directly to the United States
via mail or to Canada, a transshipment point for small quantities of the drug.
91 92 Given
the speed with which the synthetic opioid market is maturing, this second form of
trafficking may represent a far greater medium- and long-term threat.
Scope and Geography of the Problem
It is important to begin this section by declaring that there are no reliable estimates for
illicit fentanyl use in the United States. This is related to the newness of the drug, as well
as wide disparities of training of drug agents, sniffing dogs, medical professionals and
others who deal with fentanyl. It is difficult to detect because it comes in small
quantities, and is often camouflaged in other drugs. US law enforcement and health
professionals are only beginning to see the signs on both the seizure side and the
overdose side, the two data points most important to determining the scope of the
problem.The current fentanyl epidemic is largely concentrated in regions of the country where white powder heroin and prescription pill misuse dominates the market—Appalachia and the Northeast. In a 2016 CDC study, for instance, Northeastern states reported the highest percentage of opioid overdose deaths involving fentanyl, ranging from 60–90 percent of all opioid overdose deaths; midwestern states also exhibited high percentages of opioid overdose deaths involving fentanyl. In many of these states, deaths from fentanyl alone have started to outnumber deaths from fentanyl cut into other substances, potentially suggesting a unique fentanyl and fentanyl analogue market.94 95 These regions of the country have similarly seen the largest increases in non-fatal opioid-related emergency department visits 96 and fentanyl seizures. 97
Distribution Networks
in the United States
Once fentanyl crosses the US-Mexico border, it typically moves inland to a distribution
center where it is packaged and shipped via truck or private vehicle to the markets in
Appalachia and the East Coast.98 US law enforcement sources said that Mexican TCOs
control the fentanyl as it moves within the United States and exert control over the
distribution in larger cities—though there are critical exceptions to that rule. US
indictments corroborate this sentiment, despite the complexities of the Mexican market
outlined above. The most critical exceptions to this rule happen in the Northeastern United States. In Massachusetts and Connecticut, the epicenter of the US fentanyl epidemic, Dominican TCOs serve as mid-level distributors for cocaine and white powder heroin, which is the type of heroin cut with fentanyl. Dominican TCOs obtain multi-hundred kilogram quantities of heroin, heroin cut with fentanyl, and cocaine from Mexican wholesalers in New York City and other hubs, which they then sell in increments to local street gang clients for local street sales.99 DEA sources in Mexico also told InSight Crime that Dominican TCOs go to the US-Mexico border and have even traveled to Mexico to get the fentanyl.
In Appalachia, the local-level distribution is a little more diffuse. Interviews with local law enforcement in Hamilton County and Kentucky indicate that Mexican-sourced heroin, cocaine, and methamphetamine cut with fentanyl, as well as fentanyl in powder and pill form, typically comes in from Chicago and then spreads to cities like Toledo,Columbus, Cincinnati, and south to West Virginia.100 In smaller Appalachian communities, local drug peddling organizations tend to be composed of family units. They obtain fentanyl in small quantities from Mexican nationals in larger cities, bring it back to their communities, and then rely on people with substance use disorders for local street sales.101 These smaller, family-run distribution networks typically do not target their sales; whatever they are supplied with will inevitably find a market, though there’s evidence to suggest that they target communities with pill problems when they sell counterfeit pills with fentanyl.102
The DEA also believes that criminal groups have moved beyond cutting white powder heroin with fentanyl. These days it is increasingly more common for fentanyl to be mixed with adulterants and sold as heroin, with no heroin present in the product.103 This observation is backed up by the NFLIS data which shows fentanyl-only exhibits far outstripped heroin cut with fentanyl exhibits in 2016.104
This view is echoed by a local law enforcement official in Hamilton County, Ohio. “Half of the methamphetamine and crack cocaine overdoses [in Hamilton County] have had fentanyl in them,” the official said. “Synthetic opiates are the money-makers for most of the cartels since it is what most people are addicted to and you can hit different demographics by starting to mix fentanyl with cocaine and methamphetamine.” 108
Notably, according to the 2018 National Drug Threat Assessment, it is the criminal wholesalers in the US, and not Mexico, who appear to be lacing the drugs in the US with fentanyl. “Although fentanyl is often seized as a part of poly-drug loads (generally cocaine, heroin, and methamphetamine), fentanyl mixtures with other illicit drugs are very uncommon at the wholesale level,” the DEA wrote. “This indicates the mixing of fentanyl with other illicit drugs is most frequently done inside the United States and is not representative of any definitive Mexican TCO strategy.”
It is also important to note that Mexico-sourced fentanyl does not dominate the market in Appalachia, and likely not in the Northeast. Interviews with law enforcement in Appalachia suggested what is likely a fairly evenly split local market between fentanyl brought in via mail and Mexican-sourced fentanyl.109 110 It is likely a similar situation in the Northeast.
Still, the Mexican TCOs are hoping to use fentanyl to further capitalize on widespread opioid addiction in the United States.111 This is clearest in its increasing production and distribution of counterfeit pills, but they are also undoubtedly aware of the potential of using fentanyl as an additive for other drugs as well. Given the potency and highly addictive nature of fentanyl, studies and testimony from people with opioid use disorders indicate that over time people are willing to take fentanyl 112 or actively seek it out, 113 and that they seek to counteract it is lethality by controlling their dosage or consuming it in groups where there might be naloxone present.114
CASE STUDY
A Dominican Connection
On October 22, 2018, authorities pulled over a Dominican national identifying himself as
Angel Javier Morell-O'neill as he drove in Methuen, Massachusetts. They had been
investigating him since June 2018, according to a Justice Department press release.115
They searched his car and found two kilograms of fentanyl in the passenger seat. Authorities also executed a warrant to search his apartment on Pleasant Valley Street, Methuen, where they found another 30 kilograms of fentanyl, most of it wrapped in one kilogram-sized packages and hidden throughout the apartment. The drugs, the Justice Department said, were worth an estimated $29 million. In addition, they found a 9mm Millennium G2 handgun, ammunition, and a gas mask.
While surveilling the apartment, authorities also observed and arrested José Rodríguez, when he arrived with $20,000—what US prosecutors say was “half of the transportation costs of a narcotics shipment” to Morell-Oneill.
The pair are part of a slew of Dominican nationals who are spread throughout the Northeast, increasingly in small towns like Methuen, population 50,000, and Lawrence, population 80,000, which one DEA officer described as the “epicenter” of fentanyl distribution where Dominicans come in using false IDs as Morrell-Oneill did. “They own the land,” the officer told InSight Crime of the Dominicans.
The officer said the Dominican networks use a rudimentary process—magic bullet blenders, an industrial strength air purifier, and a “narcan” 116—to lace heroin with fentanyl or simply eliminate the heroin altogether, since the fentanyl is so strong. “Pretty soon, you will stop hearing about heroin,” he said. “They’re never going back to heroin.”
A kilo of fentanyl can yield as much as $1.3 million, while a kilo of heroin might yield $75,000, the agent said. Given the profit margins, Mexican organizations may be moving into the wholesale business in the Northeast, both the DEA and US prosecutors say.
Authorities are worried that a violent power struggle has already begun. “We know who is going to win that fight,” a US prosecutor said, referring to the firepower of the Mexican groups.
Maritime Fentanyl Trafficking
in the United States
A vast majority of the fentanyl seized by Customs and Border Patrol is seized at ports
of entry on the Southwest border and international mail service centers. In fact, less than one percent of the fentanyl seizures made between 2016 and 2017 by CBP
involved a transport method other than mail or traditional land trafficking transport
methods.
117 Of the hundreds of seizures made in 2016 and 2017, only seven fentanyl
seizures were made at ports of entry that were not on the southwest border or at
international mail facilities.118 36s
Despite the low seizure count, it is likely that maritime trafficking of fentanyl directly into the United States is a transport method that’s utilized—though probably at far lower rates than mail or land ports of entry on the Southwest border. For example, in June 2018, Customs and Border Protection officials seized 110 pounds of fentanyl at the Port of Philadelphia.119 The fentanyl was discovered by a CBP narcotics detector dog in a shipment of iron oxide that arrived from China. 120
This is the only instance of maritime fentanyl trafficking found by InSight Crime, though given how it recent it was, it could indicate efforts by Chinese groups to move fentanyl in larger quantities directly into the United States. What’s more, authorities consulted about this seizure could not say whether it was an anomaly or the norm.
Postal Services and the Dark Web
The current fentanyl overdose epidemic in the United States has also introduced a novel
method for the trafficking of illicit substances: directly to the consumer via mail after
an online or dark web purchase. Thousands of Americans are purchasing small
quantities of fentanyl, precursors, and analogues online121 and having them sent
directly to their homes via mail for personal consumption or distribution among a close
circle of acquaintances.122 123 Furthermore, recent indictments cited in Part I suggest that Chinese nationals have set up regional distribution networks in the United States that are responsible for broader distribution of fentanyl and fentanyl analogues sent via mail, then negotiated and moved via the dark web on the domestic level.124 Finally, there’s also some evidence of fentanyl and precursors getting sent to individuals near the Southwest border, brought into Mexico to be cut into the heroin, cocaine, and methamphetamine supply chain, and then brought back to the United States, though it is unclear how pervasive this is. 125
In sum, fentanyl trafficked to the US directly from China is significant, and there is still no consensus on whether land-based or postal fentanyl is responsible for the bulk of the fentanyl consumed in the US. Local law enforcement in Ohio and Kentucky, for example, told InSight Crime that fentanyl trafficked via mail might be just as significant a portion of their local fentanyl supply as fentanyl trafficked via the southwest border via Mexico. 126 127 For its part, the US-China Economic and Security Review Commission, in its November 2018, report, stated simply: “China remains the largest source of illicit fentanyl and fentanyl-like substances in the United States.” 128
However, federal authorities in San Diego and New Hampshire contradicted this assessment.129 Indeed, numerous government officials and counterdrug agents throughout the region, 130 as well as prominent public health advocates, have also said Mexican groups are behind the bulk of the fentanyl arriving to the US. 131
Part of the debate stems from data collection. Although trafficked in smaller quantities, fentanyl delivered via mail from China is largely already in powder form 132 and averages 90 percent purity, thus making it far more potent and likely more profitable than fentanyl brought across the southwest border, which has an average of 7 percent purity.133 Nonetheless, seizure data does not reflect this massive difference in purity; instead, CBP measures them as if they were equal, law enforcement officials told InSight Crime.
In either case, Chinese online sellers of fentanyl explicitly prefer shipping via express mail services, which are largely governed by the postal administration and include the United States Postal Service and China Post.134 This preference is for two prominent reasons: the United States Postal Service handles four times the amount of incoming mail than do express consignment carriers like DHS, FedEx, or UPS combined; and the United States Postal Service is not yet able to obtain advanced electronic data on all incoming packages, which makes detection of illicit substances far more difficult.135
Customs and Border Protection seizure data confirms this preference. Fentanyl seizures from USPS packages far outpace seizures from express consignment carriers, although the total weight of seizures on express consignment carriers was twice that of express mail. This suggests that larger fentanyl mail shipments might be sent through consignment carriers like DHS, FedEx, and UPS.136
Interviews and testimony from federal government officials indicate that the trafficking of fentanyl via mail could represent “the future of the drug problem in America,” and the democratization of drug trafficking.137 It is the opinion of some that the current fentanyl epidemic could be a watershed moment where the hierarchical drug trafficking organizations that have traditionally dominated the drug trade may no longer have a monopoly on the supply of illicit drugs.138
In some respects, fentanyl is like the computer microchip market. There is the potential of producers to create smaller and smaller analogues, reducing the need to use large criminal infrastructures to ship the product to its consumers. This is already happening: Carfentanil, a fentanyl analogue, is an estimated 100 times more potent than fentanyl, and has been detected in places as disparate as San Diego and New Hampshire.139 Reports of carfentanil have also risen from none in 2015, to over 6,000 incident reports in 2017.140
Recommendations
1. Pressure Mexico to put fentanyl higher on the agenda. Fentanyl is not a
priority for law enforcement in Mexico, and there is little indication that this will
change in the near future. When approached, Mexico’s federal forces told InSight
Crime that fentanyl was not a priority and that they did not believe it was a
significant part of Mexican TCO’s criminal portfolios. The issue is long-term:
fentanyl may be just the first of many synthetic drug scourges to come. 2. Specifically, to help combat the trafficking of fentanyl and its analogues, Mexico could: increase capacity to detect and test for fentanyl and its analogues at its laboratories and where it seizes drugs; beef up detection at its ports for fentanyl and precursors; and open the door to inspections of seized laboratories and chemicals.
3. Pressure China to participate more actively in criminal investigations to deter Chinese producers and exporters, and actively update precursor watchlists and prohibitions. As the President’s Commission on Combating Drug Addiction and the Opioid Crisis wrote, “We are losing this fight predominately through China. This must become a top tier diplomatic issue with the Chinese; American lives are at stake and it threatens our national security.”141
4. Invest in research and data collection to better understand this drug trafficking phenomenon. In many ways, fentanyl represents the democratization of drug trafficking, offering small and large groups myriad ways of exploiting markets. However, the data on production, trafficking, and consumption is sparse at best. https://www.insightcrime.org/wp-content/uploads/2019/02/Fentanyl-Report-InSight-Crime-19-02-11.pdf
Notes
25 Drug Enforcement Administration, “Counterfeit Prescription Pills Containing Fentanyls: A Global
Threat,” July 2016. Available at:
https://www.dea.gov/sites/default/files/docs/Counterfeit%2520Prescription%2520Pills.pdf
26 Ibid.
27 Ibid.
28 US-China Economic and Security Review Commission, “Fentanyl: China’s Deadly Export to the United
States,” February 2017. Available at:
https://www.uscc.gov/sites/default/files/Research/USCC%20Staff%20Report_FentanylChina%E2%80%99s%20Deadly%20Export%20to%20the%20United%20States020117.pdf
29 CNBC, “China says the US domestic opioid market is the crux of the crisis,” 25 June 2018. Available at:
https://www.cnbc.com/2018/06/25/china-says-the-us-domestic-opioid-market-is-the-crux-of-thecrisis.html
30 US Department of State, Bureau of International Narcotics and Law Enforcement Affairs, “2018
International Narcotics Control Strategy Report (INCSR),” March 2018. Available at:
https://www.state.gov/documents/organization/278759.pdf
38 InSight Crime interview, Federal Police officials, 22 July 2018.
39 InSight Crime interview, high-ranking SEGOB official, 15 July 2018.
40 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20final%20low%20resolution.pdf
41 Ibid.
42 US Attorney’s Office, Southern District of California, “County’s Top Law Enforcers Issue Dire Warning about Fentanyl, Carfentanil as Deaths and Border Seizures Spike,” 6 October 2017. Available at: https://www.justice.gov/usao-sdca/pr/county-s-top-law-enforcers-issue-dire-warning-aboutfentanyl-carfentanil-deaths-and
43 The Partnership for Safe Medicines, “UNODC Conference Highlights Fake Drugs Distributed By Organized Crime,” 12 March 2013. Available at: https://www.safemedicines.org/2013/03/unodcconference-highlights-fake-drugs-distributed-by-organized-crime-521.html
44 Based on FOIA requests to Mexico’s Marines, Defense Department, Attorney General’s Office, and Federal Police, as well as media reports.
45 US Immigration and Customs Enforcement, “Combatting the Opioid Crisis,” 22 June 2018. Available at: https://www.ice.gov/features/opioid-crisis
46 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
47 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
48 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
49 La Jornada, “Decomisan fentanilo en refacción de automóvil enviada por paquetería,” 11 January 2018. Available at: http://jornadabc.mx/tijuana/11-01-2018/decomisan-fentanilo-en-refaccion-deautomovil-enviada-por-paqueteria
50 La Jornada, “Decomisan pastillas de Fentanilo en Tijuana, BC,” 31 March 2018. Available at: http://www.jornada.com.mx/2018/03/31/sociedad/027n2soc
39 InSight Crime interview, high-ranking SEGOB official, 15 July 2018.
40 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20final%20low%20resolution.pdf
41 Ibid.
42 US Attorney’s Office, Southern District of California, “County’s Top Law Enforcers Issue Dire Warning about Fentanyl, Carfentanil as Deaths and Border Seizures Spike,” 6 October 2017. Available at: https://www.justice.gov/usao-sdca/pr/county-s-top-law-enforcers-issue-dire-warning-aboutfentanyl-carfentanil-deaths-and
43 The Partnership for Safe Medicines, “UNODC Conference Highlights Fake Drugs Distributed By Organized Crime,” 12 March 2013. Available at: https://www.safemedicines.org/2013/03/unodcconference-highlights-fake-drugs-distributed-by-organized-crime-521.html
44 Based on FOIA requests to Mexico’s Marines, Defense Department, Attorney General’s Office, and Federal Police, as well as media reports.
45 US Immigration and Customs Enforcement, “Combatting the Opioid Crisis,” 22 June 2018. Available at: https://www.ice.gov/features/opioid-crisis
46 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
47 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
48 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
49 La Jornada, “Decomisan fentanilo en refacción de automóvil enviada por paquetería,” 11 January 2018. Available at: http://jornadabc.mx/tijuana/11-01-2018/decomisan-fentanilo-en-refaccion-deautomovil-enviada-por-paqueteria
50 La Jornada, “Decomisan pastillas de Fentanilo en Tijuana, BC,” 31 March 2018. Available at: http://www.jornada.com.mx/2018/03/31/sociedad/027n2soc
51 InSight Crime email correspondence, DEA official, 26 July 2018.
52 InSight Crime interview, Mike Vigil, 27 April 2018.
53 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
54 Ibid.
55 Mimi Yagoub, “Why a 900% Spike in Murders in West Mexico State,” InSight Crime, 25 May 2016. Available at: https://www.insightcrime.org/news/brief/what-is-behind-900-spike-in-murders-inwest-mexico-state/
56 Parker Asmann, “Mexico Organized Crime-Related Executions Hit Record High: Report,” 26 July 2018. Available at: https://www.insightcrime.org/news/brief/mexico-organized-crime-executions-recordhigh/
57 Marguerite Cawley, “Meth Trafficker Sentence Highlights Asia Ties to Mexico’s Sinaloa Cartel,” InSight Crime, 4 August 2014. Available at: https://www.insightcrime.org/news/brief/meth-traffickersentence-asia-mexico-sinaloa-cartel/
58 Marguerite Cawley, “Meth Trafficker Sentence Highlights Asia Ties to Mexico’s Sinaloa Cartel,” InSight Crime, 4 August 2014. Available at: https://www.insightcrime.org/news/brief/meth-traffickersentence-asia-mexico-sinaloa-cartel/
59 InSight Crime interview, Appalachia health advocate, 18 June 2018.
60 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
61 US Southern District of Ohio, “Twelve Charged in Cincinnati in Connection to Mexico-Based Sinaloa Drug Cartel,” 8 March 2018. Available at: https://www.justice.gov/usao-sdoh/pr/twelve-chargedcincinnati-connection-mexico-based-sinaloa-drug-cartel
62 US Northern District of Ohio, “Twenty people indicted in conspiracy that brought large amounts of heroin, cocaine and fentanyl to Northeast Ohio,” 12 October 2018. Available at: https://www.justice.gov/usao-ndoh/pr/twenty-people-indicted-conspiracy-brought-large-amountsheroin-cocaine-and-fentanyl
63 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2019. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
64 InSight Crime interview, high ranking official, Mexico’s Attorney General’s Office, 2 June 2018. 65 Mike Gallagher, “The Cartels Next Door: ‘Mayor of Mexico’ ran a slick operation,” Albuquerque Journal, 14 February 2017. https://www.abqjournal.com/949253/plea-bargain-nets-valuableinfo.html
66 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
67 Mike Gallagher, “The Cartels Next Door: ‘Mayor of Mexico’ ran a slick operation,” Albuquerque Journal, 14 February 2017. https://www.abqjournal.com/949253/plea-bargain-nets-valuableinfo.html
68 13 WHAM ABC, “WNY drug bust operation lands $2.5 million in cocaine, heroin, fentanyl,” 9 August 2016. Available at: http://13wham.com/news/top-stories/wny-drug-bust-operation-lands-25-millionin-cocaine-heroin-fentanyl
69 Phil Fairbanks, “New indictment ups the ante for WNY drug network linked to Mexican cartel,” The Buffalo News, 23 August 2017. Available at: http://buffalonews.com/2017/08/23/sea-cucumbershipments-buffalo-lead-drug-arrests/
70 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
71 US Western District of New York, “Federal Jury Convicts Two Defendants of Narcotics Conspiracy Tied To The El Chapo Mexican Drug Cartel,” 20 December 2018. Available at: https://www.justice.gov/usao-wdny/pr/federal-jury-convicts-two-defendants-narcotics-conspiracytied-el-chapo-mexican-drug
72 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
73 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
74 El Mundo, “Muere 'Nacho' Coronel, uno de los narcos más buscados y poderosos de México,” 30 July 2010. https://www.elmundo.es/america/2010/07/30/mexico/1280446951.html
75 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
76 Ibid.
77 Fentanyl can be illegally synthesized in the middle of urban centers or countryside labs. The first incident of illicit domestic production on US soil, for instance, were two labs discovered in Kansas’ largest city, Wichita, in 1991. Fifteen years later in 2006, authorities were able to trace back a wave of fentanyl overdoses that left more than 1,000 dead in the United States to a single clandestine lab in Toluca, Mexico. See: Chicago Tribune, “Drug lab shut down,” 6 June 2006. Available at: http://articles.chicagotribune.com/2006-06-06/news/0606060306_1_fentanyl-fatal-overdoses-drugczar
78 Mexico Attorney General’s Office, “Inicia PGR investigación por aseguramiento de laboratorio clandestino en Sinaloa,” 23 November 2017.
79 Procuraduría General de la República, “Comunicado PGR 34/18. PGR asegura en la Ciudad de México laboratorio clandestino para elaborar fentanilo,” 12 December 2018. Available at: https://www.gob.mx/pgr/prensa/comunicado-pgr-34-18-pgr-asegura-en-la-ciudad-de-mexicolaboratorio-clandestino-para-elaborar-fentanilo
80 Rachel Martin, “In Rural Ohio, An Opioid Crisis Becomes a Methamphetamine Crisis,” National Public Radio, 5 June 2018. Available at: https://www.npr.org/2018/06/06/617422943/in-rural-ohio-anopioid-crisis-becomes-a-methamphetamine-crisis
81 Substance Abuse & Mental Health Service Administration, “Treatment Episode Data Set.” Available at: http://wwwdasis.samhsa.gov/webt/newmapv1.htm
82 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
83 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
84 InSight Crime interviews with officials at Mexico federal police and Attorney General’s Office, JuneJuly 2018.
85 Ezequiel Flores Contreras, “Sierra de Guerrero: la amapola a la baja, la violencia al alza,” Proceso, 16 October 2018. Available at: https://www.proceso.com.mx/555497/sierra-de-guerrero-la-amapola-ala-baja-la-violencia-al-alza
86 Mark Stevenson, “Mexico opium poppy growers see price drop, turn to marijuana,’ AP News, 22 June 2018. Available at: https://www.apnews.com/cb4dac96eb24420697416c68ad92105e
87 Ibid.
88 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20%5Bfinal%5D%20low%20resolution11-20.pdf
89 Mark Stevenson, “Mexico opium poppy growers see price drop, turn to marijuana,” Associated Press, 22 June 2018. Available at: https://www.apnews.com/cb4dac96eb24420697416c68ad92105e
90 US Department of Justice, “Justice Department announces indictments against Chinese manufacturers of fentanyl and other opiate Substances,” 17 October 2017. Available at: https://www.justice.gov/opa/pr/justice-department-announces-first-ever-indictments-againstdesignated-chinese-manufacturers
91 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
92 US Department of Homeland Security, “Testimony of Robert E. Perez, Executive Assistant Commissioner,” 25 May 2017. Available at: https://www.hsgac.senate.gov/imo/media/doc/Perez%20UPDATED%20Testimony.PDF
93 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Midyear Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/11674r1NFLI SMidyear2017.pdf
94 Centers for Disease Control and Prevention, “Overdose Deaths Involving Opioids, Cocaine, and Psychostimulants: United States, 2015-2016,” March 2018. Available at: http://dx.doi.org/10.15585/mmwr.mm6712a1
95 Centers for Disease Control and Prevention, “Overdose Deaths Related to Fentanyl and Its Analogs: Ohio, January–February 2017,” September 2017. Available at: http://dx.doi.org/10.15585/mmwr.mm6634a3
96 Centers for Disease Control and Prevention, “Vital Signs: Trends in Emergency Department Visits for Suspected Opioid Overdoses — United States, July 2016–September 2017”, March 2018. Available at: http://dx.doi.org/10.15585/mmwr.mm6709e1
97 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Midyear Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/11674r1NFLI SMidyear2017.pdf
98 Commission on Security and Cooperation in Europe: US Helsinki Commission, “The Opioid Crisis and the Dark Web: How Transnational Criminal Devastate US Communities,” 28 March 2018. Available at: https://www.csce.gov/sites/helsinkicommission.house.gov/files/unofficialtranscript/0328%20The%20Opioid%20Crisis%20and%20the%20Dark%20Web.pdf
99 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pd
100 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
101 InSight Crime interview, Kentucky law enforcement official, 16 July 2018.
102 Ibid.
103 Ibid.
104 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20final%20low%20resolution.pdf
105 InSight Crime interview, Pittsburgh treatment provider, 7 June 2018.
106 Dan Goldberg, “Evolving Opioid Epidemic Poses Challenge for Public Health Officials,” Politico, 17 July 2018. Available at: https://www.politico.com/story/2018/07/17/opioid-epidemic-challenge-prosummit-725976
107 Dan Goldberg, “Evolving Opioid Epidemic Poses Challenge for Public Health Officials,” Politico, 17 July 2018. Available at: https://www.politico.com/story/2018/07/17/opioid-epidemic-challenge-prosummit-725976
108 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
109 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
110 InSight Crime interview, Kentucky law enforcement official, 16 July 2018.
111 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
112 InSight Crime interview, Vancouver public health official, 6 July 2018.
113 Terry DeMio, “Fentanyl deaths up 1,000% since 2013, so much so that even heroin’s supply is dwarfed,” The Cincinnati Enquirer, 7 June 2018. See: https://www.cincinnati.com/story/news/2018/06/06/opioid-fentanyl-dwarfs-heroin-cincinnatidrug-supply-killing-more/610804002/
114 InSight Crime interview, Vancouver public health official, 6 July 2018.
115 US Department of Justice, “Thirty-Two Kilos of Fentanyl Worth $28.8 Million Seized and Two Dominican Nationals Arrested for Trafficking,” 23 October 2018. Available at: https://www.justice.gov/usao-ma/pr/thirty-two-kilos-fentanyl-worth-288-million-seized-and-twodominican-nationals-arrested
116 A common substitute name for naloxone, which is used to counteract the effects of an opioid overdose.
117 United States Senate Committee on Homeland Security and Governmental Affairs, Minority Staff Report, “Combatting the Opioid Epidemic: Intercepting Illicit Opioids at Ports of Entry,” 10 May 2018. Available at: https://www.hsgac.senate.gov/imo/media/doc/Combating%20the%20Opioid%20Epidemic%20- %20Intercepting%20Illicit%20Opioids%20at%20Ports%20of%20Entry%20-%20Final.pdf
118 Ibid.
119 US Customs and Border Protection, “Philadelphia CBP Seizes Nearly $1.7 Million in Fentanyl Shipped from Chin,” 28 June 2018. Available: https://www.cbp.gov/newsroom/local-mediarelease/philadelphia-cbp-seizes-nearly-17-million-fentanyl-shipped-china
120 Ibid.
121 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
122 InSight Crime interview, US government official, 5 June 2018.
123 InSight Crime interview, Kentucky law enforcement official, 17 July 2018.
124 US Department of Justice, “Justice Department announces indictments against Chinese manufacturers of fentanyl and other opiate Substances,” 17 October 2017. Available at: https://www.justice.gov/opa/pr/justice-department-announces-first-ever-indictments-againstdesignated-chinese-manufacturers
125 US Southern District of California, “Former Border Patrol Agency Pleads Guilty to Conspiracy to Distribute 4ANPP Used in the Manufacturing of Fentanyl,” 12 July 2018. Available at: https://www.justice.gov/usao-sdca/pr/former-border-patrol-agent-pleads-guilty-conspiracydistribute-4anpp-used-manufacturing
126 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
127 InSight Crime interview, Kentucky law enforcement official, 17 July 2018.
128 US-China Economic and Security Review Commission, “Fentanyl Flows from China: An Update since 2017,” 26 November 2018. Available at: https://www.uscc.gov/sites/default/files/Research/Fentanyl%20Flows%20from%20China.pdf
129 InSight Crime interviews, San Diego and New Hampshire federal authorities, July 2018.
130 InSight Crime email correspondence, DEA official, 26 July 2018.
131 InSight Crime interview, Public Health advocate, 12 June 2018.
132 US Department of Homeland Security, “Testimony of Robert E. Perez, Executive Assistant Commissioner,” 25 May 2017. Available at: https://www.hsgac.senate.gov/imo/media/doc/Perez%20UPDATED%20Testimony.PDF
133 US Department of Justice: Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
134 US Senate Committee on Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations: Staff Report, “Combatting the Opioid Crisis: Exploiting Vulnerabilities in International Mail,” 23 January 2018. Available at: https://www.portman.senate.gov/public/index.cfm/files/serve?File_id=12F93202-C8EC-4AF1-8A66- 181EE6716F37
135 Ibid.
136 US Senate Committee on Homeland Security and Governmental Affairs, Minority Staff Report, “Combatting the Opioid Epidemic: Intercepting Illicit Opioids at Ports of Entry,” 10 May 2018. Available at: https://www.hsgac.senate.gov/imo/media/doc/Combating%20the%20Opioid%20Epidemic%20- %20Intercepting%20Illicit%20Opioids%20at%20Ports%20of%20Entry%20-%20Final.pdf
137 Commission on Security and Cooperation in Europe: US Helsinki Commission, “The Opioid Crisis and the Dark Web: How Transnational Criminal Devastate US Communities,” 28 March 2018. Available at: https://www.csce.gov/sites/helsinkicommission.house.gov/files/unofficialtranscript/0328%20The%20Opioid%20Crisis%20and%20the%20Dark%20Web.pdf
138 Ibid.
139 InSight Crime interviews, San Diego and New Hampshire federal authorities, July 2018.
140 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Annual Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/NFLIS-DrugAR2017.pdf
141 US President’s Office, “The President's Commission on Combating Drug Addiction and the Opioid Crisis,” 1 November 2017. Available at: https://www.whitehouse.gov/sites/whitehouse.gov/files/images/Final_Report_Draft_11-1-2017.pdf
52 InSight Crime interview, Mike Vigil, 27 April 2018.
53 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
54 Ibid.
55 Mimi Yagoub, “Why a 900% Spike in Murders in West Mexico State,” InSight Crime, 25 May 2016. Available at: https://www.insightcrime.org/news/brief/what-is-behind-900-spike-in-murders-inwest-mexico-state/
56 Parker Asmann, “Mexico Organized Crime-Related Executions Hit Record High: Report,” 26 July 2018. Available at: https://www.insightcrime.org/news/brief/mexico-organized-crime-executions-recordhigh/
57 Marguerite Cawley, “Meth Trafficker Sentence Highlights Asia Ties to Mexico’s Sinaloa Cartel,” InSight Crime, 4 August 2014. Available at: https://www.insightcrime.org/news/brief/meth-traffickersentence-asia-mexico-sinaloa-cartel/
58 Marguerite Cawley, “Meth Trafficker Sentence Highlights Asia Ties to Mexico’s Sinaloa Cartel,” InSight Crime, 4 August 2014. Available at: https://www.insightcrime.org/news/brief/meth-traffickersentence-asia-mexico-sinaloa-cartel/
59 InSight Crime interview, Appalachia health advocate, 18 June 2018.
60 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
61 US Southern District of Ohio, “Twelve Charged in Cincinnati in Connection to Mexico-Based Sinaloa Drug Cartel,” 8 March 2018. Available at: https://www.justice.gov/usao-sdoh/pr/twelve-chargedcincinnati-connection-mexico-based-sinaloa-drug-cartel
62 US Northern District of Ohio, “Twenty people indicted in conspiracy that brought large amounts of heroin, cocaine and fentanyl to Northeast Ohio,” 12 October 2018. Available at: https://www.justice.gov/usao-ndoh/pr/twenty-people-indicted-conspiracy-brought-large-amountsheroin-cocaine-and-fentanyl
63 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2019. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
64 InSight Crime interview, high ranking official, Mexico’s Attorney General’s Office, 2 June 2018. 65 Mike Gallagher, “The Cartels Next Door: ‘Mayor of Mexico’ ran a slick operation,” Albuquerque Journal, 14 February 2017. https://www.abqjournal.com/949253/plea-bargain-nets-valuableinfo.html
66 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
67 Mike Gallagher, “The Cartels Next Door: ‘Mayor of Mexico’ ran a slick operation,” Albuquerque Journal, 14 February 2017. https://www.abqjournal.com/949253/plea-bargain-nets-valuableinfo.html
68 13 WHAM ABC, “WNY drug bust operation lands $2.5 million in cocaine, heroin, fentanyl,” 9 August 2016. Available at: http://13wham.com/news/top-stories/wny-drug-bust-operation-lands-25-millionin-cocaine-heroin-fentanyl
69 Phil Fairbanks, “New indictment ups the ante for WNY drug network linked to Mexican cartel,” The Buffalo News, 23 August 2017. Available at: http://buffalonews.com/2017/08/23/sea-cucumbershipments-buffalo-lead-drug-arrests/
70 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
71 US Western District of New York, “Federal Jury Convicts Two Defendants of Narcotics Conspiracy Tied To The El Chapo Mexican Drug Cartel,” 20 December 2018. Available at: https://www.justice.gov/usao-wdny/pr/federal-jury-convicts-two-defendants-narcotics-conspiracytied-el-chapo-mexican-drug
72 US Western District of New York, “17 Defendants Indicted In International Drug Trafficking Ring,” 9 August 2016. Available at: https://www.justice.gov/usao-wdny/pr/17-defendants-indictedinternational-drug-trafficking-ring
73 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
74 El Mundo, “Muere 'Nacho' Coronel, uno de los narcos más buscados y poderosos de México,” 30 July 2010. https://www.elmundo.es/america/2010/07/30/mexico/1280446951.html
75 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
76 Ibid.
77 Fentanyl can be illegally synthesized in the middle of urban centers or countryside labs. The first incident of illicit domestic production on US soil, for instance, were two labs discovered in Kansas’ largest city, Wichita, in 1991. Fifteen years later in 2006, authorities were able to trace back a wave of fentanyl overdoses that left more than 1,000 dead in the United States to a single clandestine lab in Toluca, Mexico. See: Chicago Tribune, “Drug lab shut down,” 6 June 2006. Available at: http://articles.chicagotribune.com/2006-06-06/news/0606060306_1_fentanyl-fatal-overdoses-drugczar
78 Mexico Attorney General’s Office, “Inicia PGR investigación por aseguramiento de laboratorio clandestino en Sinaloa,” 23 November 2017.
79 Procuraduría General de la República, “Comunicado PGR 34/18. PGR asegura en la Ciudad de México laboratorio clandestino para elaborar fentanilo,” 12 December 2018. Available at: https://www.gob.mx/pgr/prensa/comunicado-pgr-34-18-pgr-asegura-en-la-ciudad-de-mexicolaboratorio-clandestino-para-elaborar-fentanilo
80 Rachel Martin, “In Rural Ohio, An Opioid Crisis Becomes a Methamphetamine Crisis,” National Public Radio, 5 June 2018. Available at: https://www.npr.org/2018/06/06/617422943/in-rural-ohio-anopioid-crisis-becomes-a-methamphetamine-crisis
81 Substance Abuse & Mental Health Service Administration, “Treatment Episode Data Set.” Available at: http://wwwdasis.samhsa.gov/webt/newmapv1.htm
82 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
83 June S. Beittel, “Mexico: Organized Crime and Drug Trafficking Organizations,” Congressional Research Service, 3 July 2018. Available at: https://fas.org/sgp/crs/row/R41576.pdf
84 InSight Crime interviews with officials at Mexico federal police and Attorney General’s Office, JuneJuly 2018.
85 Ezequiel Flores Contreras, “Sierra de Guerrero: la amapola a la baja, la violencia al alza,” Proceso, 16 October 2018. Available at: https://www.proceso.com.mx/555497/sierra-de-guerrero-la-amapola-ala-baja-la-violencia-al-alza
86 Mark Stevenson, “Mexico opium poppy growers see price drop, turn to marijuana,’ AP News, 22 June 2018. Available at: https://www.apnews.com/cb4dac96eb24420697416c68ad92105e
87 Ibid.
88 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20%5Bfinal%5D%20low%20resolution11-20.pdf
89 Mark Stevenson, “Mexico opium poppy growers see price drop, turn to marijuana,” Associated Press, 22 June 2018. Available at: https://www.apnews.com/cb4dac96eb24420697416c68ad92105e
90 US Department of Justice, “Justice Department announces indictments against Chinese manufacturers of fentanyl and other opiate Substances,” 17 October 2017. Available at: https://www.justice.gov/opa/pr/justice-department-announces-first-ever-indictments-againstdesignated-chinese-manufacturers
91 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
92 US Department of Homeland Security, “Testimony of Robert E. Perez, Executive Assistant Commissioner,” 25 May 2017. Available at: https://www.hsgac.senate.gov/imo/media/doc/Perez%20UPDATED%20Testimony.PDF
93 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Midyear Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/11674r1NFLI SMidyear2017.pdf
94 Centers for Disease Control and Prevention, “Overdose Deaths Involving Opioids, Cocaine, and Psychostimulants: United States, 2015-2016,” March 2018. Available at: http://dx.doi.org/10.15585/mmwr.mm6712a1
95 Centers for Disease Control and Prevention, “Overdose Deaths Related to Fentanyl and Its Analogs: Ohio, January–February 2017,” September 2017. Available at: http://dx.doi.org/10.15585/mmwr.mm6634a3
96 Centers for Disease Control and Prevention, “Vital Signs: Trends in Emergency Department Visits for Suspected Opioid Overdoses — United States, July 2016–September 2017”, March 2018. Available at: http://dx.doi.org/10.15585/mmwr.mm6709e1
97 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Midyear Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/11674r1NFLI SMidyear2017.pdf
98 Commission on Security and Cooperation in Europe: US Helsinki Commission, “The Opioid Crisis and the Dark Web: How Transnational Criminal Devastate US Communities,” 28 March 2018. Available at: https://www.csce.gov/sites/helsinkicommission.house.gov/files/unofficialtranscript/0328%20The%20Opioid%20Crisis%20and%20the%20Dark%20Web.pdf
99 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pd
100 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
101 InSight Crime interview, Kentucky law enforcement official, 16 July 2018.
102 Ibid.
103 Ibid.
104 US Drug Enforcement Administration, “2018 National Drug Threat Assessment,” October 2018. Available at: https://www.dea.gov/sites/default/files/2018-11/DIR-032- 18%202018%20NDTA%20final%20low%20resolution.pdf
105 InSight Crime interview, Pittsburgh treatment provider, 7 June 2018.
106 Dan Goldberg, “Evolving Opioid Epidemic Poses Challenge for Public Health Officials,” Politico, 17 July 2018. Available at: https://www.politico.com/story/2018/07/17/opioid-epidemic-challenge-prosummit-725976
107 Dan Goldberg, “Evolving Opioid Epidemic Poses Challenge for Public Health Officials,” Politico, 17 July 2018. Available at: https://www.politico.com/story/2018/07/17/opioid-epidemic-challenge-prosummit-725976
108 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
109 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
110 InSight Crime interview, Kentucky law enforcement official, 16 July 2018.
111 Office of the Special Narcotics Prosecutor for the City of New York, “2017 Annual Report,” May 2018. Available at: http://www.snpnyc.org/wp-content/uploads/2018/05/SNP-AR2017.pdf
112 InSight Crime interview, Vancouver public health official, 6 July 2018.
113 Terry DeMio, “Fentanyl deaths up 1,000% since 2013, so much so that even heroin’s supply is dwarfed,” The Cincinnati Enquirer, 7 June 2018. See: https://www.cincinnati.com/story/news/2018/06/06/opioid-fentanyl-dwarfs-heroin-cincinnatidrug-supply-killing-more/610804002/
114 InSight Crime interview, Vancouver public health official, 6 July 2018.
115 US Department of Justice, “Thirty-Two Kilos of Fentanyl Worth $28.8 Million Seized and Two Dominican Nationals Arrested for Trafficking,” 23 October 2018. Available at: https://www.justice.gov/usao-ma/pr/thirty-two-kilos-fentanyl-worth-288-million-seized-and-twodominican-nationals-arrested
116 A common substitute name for naloxone, which is used to counteract the effects of an opioid overdose.
117 United States Senate Committee on Homeland Security and Governmental Affairs, Minority Staff Report, “Combatting the Opioid Epidemic: Intercepting Illicit Opioids at Ports of Entry,” 10 May 2018. Available at: https://www.hsgac.senate.gov/imo/media/doc/Combating%20the%20Opioid%20Epidemic%20- %20Intercepting%20Illicit%20Opioids%20at%20Ports%20of%20Entry%20-%20Final.pdf
118 Ibid.
119 US Customs and Border Protection, “Philadelphia CBP Seizes Nearly $1.7 Million in Fentanyl Shipped from Chin,” 28 June 2018. Available: https://www.cbp.gov/newsroom/local-mediarelease/philadelphia-cbp-seizes-nearly-17-million-fentanyl-shipped-china
120 Ibid.
121 US Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
122 InSight Crime interview, US government official, 5 June 2018.
123 InSight Crime interview, Kentucky law enforcement official, 17 July 2018.
124 US Department of Justice, “Justice Department announces indictments against Chinese manufacturers of fentanyl and other opiate Substances,” 17 October 2017. Available at: https://www.justice.gov/opa/pr/justice-department-announces-first-ever-indictments-againstdesignated-chinese-manufacturers
125 US Southern District of California, “Former Border Patrol Agency Pleads Guilty to Conspiracy to Distribute 4ANPP Used in the Manufacturing of Fentanyl,” 12 July 2018. Available at: https://www.justice.gov/usao-sdca/pr/former-border-patrol-agent-pleads-guilty-conspiracydistribute-4anpp-used-manufacturing
126 InSight Crime interview, Ohio law enforcement official, 11 July 2018.
127 InSight Crime interview, Kentucky law enforcement official, 17 July 2018.
128 US-China Economic and Security Review Commission, “Fentanyl Flows from China: An Update since 2017,” 26 November 2018. Available at: https://www.uscc.gov/sites/default/files/Research/Fentanyl%20Flows%20from%20China.pdf
129 InSight Crime interviews, San Diego and New Hampshire federal authorities, July 2018.
130 InSight Crime email correspondence, DEA official, 26 July 2018.
131 InSight Crime interview, Public Health advocate, 12 June 2018.
132 US Department of Homeland Security, “Testimony of Robert E. Perez, Executive Assistant Commissioner,” 25 May 2017. Available at: https://www.hsgac.senate.gov/imo/media/doc/Perez%20UPDATED%20Testimony.PDF
133 US Department of Justice: Drug Enforcement Administration, “2017 National Drug Threat Assessment,” October 2017. Available at: https://www.dea.gov/docs/DIR-040-17_2017-NDTA.pdf
134 US Senate Committee on Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations: Staff Report, “Combatting the Opioid Crisis: Exploiting Vulnerabilities in International Mail,” 23 January 2018. Available at: https://www.portman.senate.gov/public/index.cfm/files/serve?File_id=12F93202-C8EC-4AF1-8A66- 181EE6716F37
135 Ibid.
136 US Senate Committee on Homeland Security and Governmental Affairs, Minority Staff Report, “Combatting the Opioid Epidemic: Intercepting Illicit Opioids at Ports of Entry,” 10 May 2018. Available at: https://www.hsgac.senate.gov/imo/media/doc/Combating%20the%20Opioid%20Epidemic%20- %20Intercepting%20Illicit%20Opioids%20at%20Ports%20of%20Entry%20-%20Final.pdf
137 Commission on Security and Cooperation in Europe: US Helsinki Commission, “The Opioid Crisis and the Dark Web: How Transnational Criminal Devastate US Communities,” 28 March 2018. Available at: https://www.csce.gov/sites/helsinkicommission.house.gov/files/unofficialtranscript/0328%20The%20Opioid%20Crisis%20and%20the%20Dark%20Web.pdf
138 Ibid.
139 InSight Crime interviews, San Diego and New Hampshire federal authorities, July 2018.
140 US Drug Enforcement Administration, “National Forensic Laboratory Information System: NFLISDrug Annual Report 2017,” 2018. Available at: https://www.nflis.deadiversion.usdoj.gov/DesktopModules/ReportDownloads/Reports/NFLIS-DrugAR2017.pdf
141 US President’s Office, “The President's Commission on Combating Drug Addiction and the Opioid Crisis,” 1 November 2017. Available at: https://www.whitehouse.gov/sites/whitehouse.gov/files/images/Final_Report_Draft_11-1-2017.pdf
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