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Brokers: Lynchpins of the Precursor Chemical Flow to Mexico

When Ana Gabriela Rubio Zea contacted her chemical suppliers in China on behalf of a new client, she needed to make a convincing pitch to ensure the deal would go […]

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When Ana Gabriela Rubio Zea contacted her chemical suppliers in China on behalf of a new client, she needed to make a convincing pitch to ensure the deal would go through.

It was September 2021, and she was brokering a purchase for 25 kilograms of 1-BOC-4-Piperidone, a chemical substance that the Sinaloa Cartel needed to manufacture fentanyl.

“We are the biggest in Mexico, so we can purchase a lot [of chemicals],” she told her would-be suppliers in text messages intercepted by US authorities and detailed in a later indictment.

*This article is part of a two-year investigation that tracked the supply chain of precursor chemicals that aid in the production of methamphetamine and fentanyl in Mexico. Read the other articles of the investigation here and the full report here.

The chemicals were enough to produce something in the range of 25 kilograms of pure fentanyl, which could make around 15 million counterfeit pills. But in the larger scheme of things, the deal was a drop in the bucket. In a typical year, InSight Crime estimates that criminal groups produce and distribute something between 3 and 4.5 tons in the United States, as we detailed in our recent report on precursor chemicals.

Anti-drug officials have singled out the Sinaloa Cartel and its different factions, accusing them of pioneering this large-scale fentanyl production and being largely responsible for the record quantities trafficked into the United States. The flood has led to record numbers of overdose deaths there, making groups like the Sinaloa Cartel the centerpiece of US counter-drug efforts. But it is brokers like Rubio Zea who appear to power the system and make it hum by sourcing precursor chemicals, the base ingredients used to process synthetic drugs like powdered fentanyl.

Rubio Zea’s Chinese contacts were convinced, and a deal was struck. The chemical was shipped via air from Suzhou, a city west of Shanghai in Jiangsu province — part of a region in eastern China where, after web scraping company records InSight Crime determined the majority of precursor-producing companies in this country operate — to the city of Guadalajara in western Mexico.

But when the chemicals arrived in Guadalajara, law enforcement intercepted the order. Shortly thereafter, an undercover US Drug Enforcement Administration (DEA) agent established contact with Rubio Zea and began negotiating another one-kilogram chemical shipment. Unbeknownst  to her, that order was sent to a mailbox belonging to the covert agent at an undisclosed location.

The seizures became the core of the US indictment against her. In March 2023, Guatemalan authorities arrested Rubio Zea in Guatemala City on a provisional request from the United States. The following month, the Southern District of New York made public an indictment against her, various members of the Sinaloa Cartel, and some of their Chinese associates for three criminal charges related to trafficking fentanyl.

Her arrest was the latest part of a calculated campaign to strike at the heart of the Chapitos faction of the Sinaloa Cartel. The Chapitos network is run by some of the sons of the group’s jailed former leader, Joaquín Guzmán Loera, alias “El Chapo.” Rubio Zea’s capture followed the January 2023 arrest of Ovidio Guzmán López, one of those sons who US prosecutors have made the face of their fight against fentanyl.

But while Gúzman López’s extradition to Chicago in September garnered all the headlines, Rubio Zea’s arrest and subsequent extradition to the United States to face charges was equally symbolic. She — and other brokers like her — are the pistons of a large, industrial engine. They are also one of the few bottlenecks in the vast chemical distribution chain.

The Role of Brokers

At its core, a broker is an intermediary that acts on behalf of others in exchange for a fee or commission. This can include negotiating the terms of a contract, facilitating the sale of a precursor chemical, or directly selling these substances to synthetic drug producers.

They operate in the middle of the supply chain of synthetic drugs, which is best described as an hourglass, as InSight Crime illustrated in our recent report about precursor chemicals. The greatest number of actors are found at the top and bottom of the chain. Brokers connect the legal and illegal chemical producers in places like China, India, and Germany with those involved in trafficking the powerful synthetic drug from Mexico to consumers in the United States.

There is likely a more limited number of actors in the brokers category, as they are not only in charge of linking different players in multiple countries, but they also act as the bridge between the mostly legal world of chemical production and the Mexican underworld. This makes them the bottleneck of the supply chain, and a key target for law enforcement officials looking to disrupt the flow of precursor chemicals and synthetic drugs.

But the role of brokers has largely been overshadowed by narratives and security strategies that focus on kingpins and “cartels,” the catch-all phrase so often used to describe complex criminal networks like the Chapitos or the Jalisco Cartel New Generation (Cartel de Jalisco Nueva Generación – CJNG), which US authorities have also linked to the fentanyl trade.

Rather than single, vertically integrated criminal groups, these networks are made up of numerous independent chemical and drug producers, wholesalers, retailers, transporters, and, of course, brokers. The role of these larger drug trafficking organizations is mostly limited to managing the cross-border transport of synthetic drugs in their final form, a fundamental and costly endeavor that accounts for their high returns. But they are only one part of this distribution chain.

Despite their importance, brokers are seldomly prosecuted. An exhaustive review of judicial records in Mexico and the United States by InSight Crime investigators found that Rubio Zea is one of only a handful of precursor chemical brokers who have been indicted in criminal cases involving Mexican organized crime networks. And even in her case, Rubio Zea’s name is all but lost amid the 22 others named in the charging documents.

After US Hearing on Fentanyl, is it Time to Retire the Word ‘Cartel’?

However, her value cannot be understated. Brokers typically handle a variety of chemical substances that are required for synthetic drug production, from chemicals that are loosely regulated to precursors and pre-precursors with stricter controls. This typology can be thought of as a pyramid, where the most regulated chemicals and substances that are the hardest to obtain sit at the top, and the least regulated and most bountiful sit at the bottom. As regulators and law enforcement restrict access to the chemicals at the top, brokers and synthetic drug producers innovate and use more chemicals from the bottom part of the pyramid.

It is the broker’s job to navigate these regulations or, if necessary, manipulate or even ignore them. For sourcing these substances in innovative and sometimes illegal ways, brokers are typically paid a fixed percentage of the value of a given chemical shipment, according to two former US law enforcement officials who handled complex drug trafficking cases. That percentage, they explained, depends on the type of chemical substance, the level of difficulty in acquiring it, and the quantity.

We have identified four types of brokers. Some of them do not necessarily do anything illegal, according to dozens of interviews carried out by InSight Crime with government officials and extensive fieldwork in Sinaloa and Michoacán, two of Mexico’s synthetic drug production hotspots.

Rubio Zea, for example, can be described as a facilitator — someone who connects suppliers and buyers. This means sharing contacts, negotiating prices and quantities, or facilitating the sale and delivery of a precursor chemical to a drug-production cell. With her expertise and connections to Chinese chemical suppliers, the drug traffickers she allegedly worked with were able to access essential ingredients needed to manufacture fentanyl.

Other brokers act more as wholesalers, purchasing quantities of chemical substances, stockpiling them at informal warehouses or bodegas, and distributing them among different drug production networks. Wholesalers can gather essential chemicals sourced from within Mexico and purchase precursors and pre-precursors from chemical suppliers in chemical production hubs like China, India, or Germany, according to InSight Crime interviews with several synthetic drug producers in Sinaloa and Michoacán.

There are also employees at chemical plants who divert small amounts of essential chemical substances from their workplace for criminal groups. They often use insider knowledge about those businesses and their understanding of internal regulations to broker sales without raising suspicions.

Finally, at ports of entry, there are customs brokers who can be key in facilitating the importation of any chemical substance. These individuals are crucial for accessing permits, sorting paperwork, and ensuring shipments that may appear suspect fly under the radar.

When obtaining chemical substances, the strength of the connections between these types of brokers and criminal groups, as well as how many drug traffickers they might work with, can vary. Determining the number of clients largely hinges on the type of broker and the specific synthetic drug producer involved in the relationship, as will be detailed across the following sections. In general terms, the decision likely revolves around a negotiation involving risk calculations, required resources, and trust.

For example, when brokers are working with networks that are directly affiliated with a criminal organization, they may not need to seek multiple clients, as more sophisticated criminal networks can offer a more sustainable and relatively secure business relationship. This appears to have been the case for Rubio Zea. Presumably, the networks associated with the Chapitos and their allies possessed sufficient resources and a robust organizational structure to maintain steady production, thus requiring her services on a more regular basis.

That said, Mexican officials have also identified brokers who allegedly collaborated with several criminal organizations, including the Sinaloa Cartel and CJNG, rivals which constantly vie for territory and market control, according to a senior Mexican naval intelligence official interviewed by InSight Crime. However, having multiple clients requires these brokers to invest more time and resources, increasing their risk of exposure and potential threats to their security, particularly in environments of intense criminal competition and heightened law enforcement activity.

Finally, some brokers may choose to engage with a greater number of small- and medium-sized producers that are not necessarily affiliated with major criminal organizations, according to InSight Crime interviews with independent fentanyl producers in Sinaloa. These producers typically use brokers only at the initial stages of their production project — for example, to establish contact with foreign chemical suppliers — or to purchase smaller amounts of chemicals at retail prices in Mexico. In these cases, the relationships between brokers and their clients tend to be shorter, thereby reducing the risks mentioned above.

Facilitators: Brokering Contacts Abroad

For the precursor and pre-precursor chemicals that are subject to tight international controls, criminal networks often rely on highly specialized brokers who have managed to secure access to suppliers. These are what we call facilitators.

Facilitators are acquainted with different actors in the global chemical industry, ideally fluent in a foreign language, and willing to travel, according to an extensive review of court records, as well as interviews with synthetic drug producers and high-ranking officials from Mexico’s navy and National Guard. More than anything, facilitators offer access and engender trust.

Rubio Zea, for example, was sought after because of her alleged contacts with Chinese chemical suppliers, specifically Suzhou Xiaoli Pharmatech Co., Ltd (SXPC), a pharmaceutical manufacturing company established in 2017. The company claims it handles “catalysts, pharmaceutical intermediates, and functional silicone materials.” But US prosecutors say it manufactures fentanyl precursors. Her point of contact at SXPC was supposedly Kun Jiang, a sales representative accused of being one of Rubio Zea’s “primary sources of supply.” The company he worked for, however, only reported exporting organic chemicals to a company based in Russia, according to the Altana Atlas, a dynamic map of global supply chains.

Rubio Zea also reportedly had connections to sales representatives at Wuhan Shuokang Biological Technology Ltd., also known as SK Biotech. In addition to negotiating sales of precursor chemicals, US authorities allege that one of the representatives charged in the same indictment, Yonghao Wu, also provided Rubio Zea with “efficient preparation methods” for how best to synthesize illicit fentanyl. This information may have also been highly prized by the networks associated with the Chapitos. During interviews with InSight Crime, one coordinator overseeing dozens of synthetic drug laboratories in Sinaloa mentioned the “kits” sent from China included detailed recipes and instructions.

While it is not clear how she initiated the relationship with the Chinese suppliers, what this contact meant for the Chapitos was direct access to a crucial chemical ingredient. 1-BOC-4-Piperidone, the chemical Rubio Zea was obtaining when authorities were intercepting her communications in September 2021, is a pre-precursor used to produce 4-anilino-N-phenethylpiperidine (ANPP), one of the main precursor chemicals used to manufacture fentanyl.

The chemical has no known legal uses besides the production of medical-grade fentanyl. But as of January 2024, 1-BOC-4-Piperidone was not included in Mexico’s precursor law, nor was it on the watch list of dual-use chemicals. However, illicit fentanyl producers in Sinaloa told InSight Crime in September 2023 that they are actively importing this particular pre-precursor to produce ANPP.

US officials also allege that Rubio Zea promoted her ability to safely deliver precursors without detection from customs officials by arranging for those chemicals to be disguised in food containers or packaged alongside legal chemicals. This is something that Chinese purveyors also frequently advertise, and clandestine fentanyl producers in Sinaloa told InSight Crime they often provide.

The person Rubio Zea projected herself to be publicly, according to business records and her LinkedIn and Instagram accounts, was more aligned with a young jet-setter operating out of Guatemala who traveled in luxury around the United States, Europe, and China than that of a clandestine chemical broker. She is fluent in multiple languages and has a degree in aerospace engineering from an Italian university.

She also had ties to other legal industries that handle chemical products. She is listed, for example, as the owner of Dosi-Veloz de Guatemala, a “Diesel injection laboratory and workshop” founded in 1975. In addition, she appears as legal representative of IGIGI Technologies. Created in July 2019, the company manufactures disposable and biodegradable bags and straws made from starch and corn.

Guatemalan officials said she also operated an unidentified import-export company that was used to “conceal, hide, and promote” her alleged purchases of precursor chemicals. Authorities did not specify whether they were referring to Dolsi-Veloz or IGIGI Technologies, or another company altogether. And Guatemala’s Attorney General’s Office denied InSight Crime’s request to access her case file or the information submitted by US authorities prior to her arrest.

IGIGI Technologies, which uses I-Eco as its trade name, once publicized its work and promoted its products on a company Facebook page. But not long after the capture of Rubio Zea, all brands and information related to the company were removed. Guatemala is a major hub for precursors used for illicit purposes. However, based on the available evidence, none of the seized precursor chemical shipments brokered by Rubio Zea passed through Guatemala.

Brokers, More Than Mexico’s ‘Cartels’, Key to Precursor Flow

Rubio Zea was just one of several brokers facilitating contact with Chinese chemical suppliers for the fentanyl production networks associated with the different factions of the Sinaloa Cartel. The previously mentioned laboratory coordinator from Sinaloa who claimed to be associated with the Chapitos as well as networks linked to Ismael Zambada García, alias “El Mayo,” told InSight Crime he obtained the required chemicals through deals another facilitator orchestrated in China. This facilitator, he explained, worked closely with several networks associated with the Chapitos and was one of the few within the organization authorized to communicate directly with Chinese suppliers.

The laboratory coordinator, on the other hand, had never made any contact with them.

“I just have to tell [the broker] how much I need, and they make sure to get it,” he told InSight Crime, adding that payments to the suppliers were managed by someone from the criminal organization.

For their part, the facilitator also stayed updated on regulatory changes, the coordinator told InSight Crime, ensuring that the different producers associated with the Chapitos had access to alternative chemicals when certain substances became too difficult to obtain. For example, the laboratory coordinator mentioned that the broker ensured his production cell obtained access to 4-piperidone and 1-BOC-4-piperidone as soon as ANPP came under strict international controls.

When working with smaller independent networks, the role of facilitators is more limited. They may choose to work with multiple clients. One independent fentanyl producer in Culiacán, for example, told InSight Crime that when he began to produce the synthetic opioid, he also relied on a facilitator. He was introduced to this facilitator, he explained, by another independent producer already in the business.

The facilitator organized conference calls involving the fentanyl producer and potential suppliers from a chemical plant in Germany. After addressing logistical concerns and presumably conducting a virtual tour of the facilities, the deal was finalized.

A similar negotiation allegedly occurred when this facilitator connected the producer with other chemical suppliers in China. Using encrypted messaging platforms like WhatsApp and Telegram, they agreed on the chemicals, quantities, and frequency of shipments. Once the contact was established, the broker’s job was done. The fentanyl producer then maintained direct communication with the suppliers and paid them via bank transfers or using cryptocurrency.

The independent producer claimed he did not have the adequate resources to constantly pay a middleman and preferred handling business himself, even if that meant assuming the risks of seizures or possibly arrest. The decision also meant maintaining a permanent association with suppliers in China and Germany who had proven reliable.

“I wouldn’t know how to choose [new suppliers]. The current ones are all I have,” he told InSight Crime.

Wholesalers: Stockpiling and Distribution

In places like Sinaloa, Jalisco, and Michoacán, synthetic drug production has become so widespread that networks of brokers have organized chemical purchases in Mexico and abroad before distributing them to local producers. We refer to these brokers as wholesalers.

Wholesalers require greater investment in their operations, as they source the substances themselves or through their intermediaries, risking exposure and seizures. Our fieldwork in drug production epicenters in Mexico suggests that wholesalers generally work in urban centers, such as Culiacán, Guadalajara, and Uruapan, and distribute chemicals to various networks operating in the surrounding areas.

To obtain chemical substances, wholesalers have traditionally used legitimate businesses or front companies that are registered and legally authorized to operate in the chemical or pharmaceutical industries, import-export, or other manufacturing activities, according to US court documents and sanctions reviewed by InSight Crime, as well as our interview with the Naval Intelligence officer mentioned above. Given how few judicial cases there are in Mexico, it’s unclear which industry is most susceptible to the formation of front companies used for this purpose. After the chemicals are stockpiled, they are then sold to criminal groups.

Ludim Zamudio Lerma and Luis Alfonso Zamudio Lerma are examples of alleged wholesalers. Weeks before Rubio Zea’s arrest in Guatemala’s capital city, the US Treasury Department sanctioned the brothers, as well as several Culiacán-based companies owned by or linked to the family, for allegedly supplying precursor chemicals to networks associated with the Chapitos for the production of fentanyl and methamphetamine.

Among the businesses targeted were a pharmacy and an import-export company, both of which appeared to be legitimate entities on paper. US authorities alleged the pharmacy and the import-export business operated on behalf of the Zamudio Lerma brothers and “regularly” received chemical shipments from exporters in China.

Some of these appear on the Altana Atlas. One of the companies, REI Compañía Internacional, S.A. de C.V., received 32 tons of N-Methylformamide from eastern China every month between July and October 2020. They also received 20 tons of tartaric acid and reported imports of several unrelated products, such as batteries and dog toys. Both N-Methylformamide and tartaric acid, however, can be used to produce methamphetamine.

Another brother accused of having links to these precursor chemical operations, Jorge Alberto Zamudio Lerma, was the former head of Culiacán’s General Hospital from 2017 to 2019. Despite the sanctions, REI Compañía Internacional has denied the accusations and none of the Zamudio Lerma brothers have been charged with any crimes in Mexico or the United States, according to a review of court records in both countries.

The Zamudios are not the only wholesaler network authorities have accused of allegedly procuring large quantities of chemicals for crime groups. Other Mexican businesses facing similar allegations, such as Corporativo y Enlace Ram and Corporativo Escomexa, also operated in the import-export sector. In fact, the Mexican government’s National Intelligence Center (Centro Nacional de Inteligencia – CNI) investigated both companies for supposedly supplying the Sinaloa Cartel and CJNG with key substances like ANPP, propionyl chloride, and aniline from India and other Asian countries.

Between March 2016 and November 2023, Corporativo y Enlace Ram, which is registered in the Mexican state of Jalisco, handled thousands of transactions involving products ranging from plastics and nuclear reactors to electrical machinery and pharmaceutical products, according to the Altana Atlas. That same data showed that Corporativo Escomexa, which is also registered in Jalisco, handled less than 500 transactions in 2016. But in September of that year, they received a pill press machine and more than 500 kilograms of lactose monohydrate powder, microcrystalline cellulose, and copovidone from a company in India. All of these substances are typically used as filler or binding agent when pressing real or counterfeit pharmaceutical pills, which are laced with fentanyl.

Neither of these companies replied to InSight Crime’s requests for comment.

How Fentanyl is Synthesized in Mexico

However, the practice of wholesalers using front companies to import chemicals may be changing. The laboratory coordinator interviewed by InSight Crime in Culiacán emphasized that increased regulatory pressure and scrutiny over the private sector, particularly in the chemical and pharmaceutical industries, has made it more difficult to rely on front companies to import chemicals.

This claim is partly supported by official data. Mexico’s Federal Commission for the Protection against Sanitary Risks (Comisión Federal para la Protección contra Riesgos Sanitarios – Cofepris), the main government agency in charge of health regulations and monitoring pharmaceuticals and chemical products, sanctioned 526 companies in 2015 for violating the General Health Law. In 2022, the number of companies sanctioned by health authorities grew to 1,419, according to data obtained by InSight Crime. And during the first days of 2024, Cofepris and the navy closed down 14 establishments in Culiacán for what authorities called the “irregular commercialization” of chemical substances.

Moreover, Mexico’s Finance Ministry also appears to have stepped up efforts to combat front companies. Since 2015, tax authorities have identified and sanctioned over 12,700 companies that were “allegedly non-existent.”

According to a representative of Mexico’s Pharmaceutical Industry Association (Cámara Nacional de la Industria Farmacéutica – CANIFARMA) who spoke to InSight Crime, it is very difficult for someone to create a front company to get access to precursor chemicals given all the steps they must first take to justify obtaining the permits to do so.

As a result, the clandestine laboratory coordinator said, wholesalers may now resort to smuggling precursors and pre-precursors into the country, rather than attempting to import them through legal channels. This was echoed by a methamphetamine producer InSight Crime spoke to in Michoacán, who is associated with one of the many criminal groups that operate in that state.

Whether wholesalers acquired chemicals illegally or legally, they appear to stockpile these substances at informal bodegas located in warehouses, small stores, restaurants, pharmacies, and other small-sized businesses that do not attract attention from authorities. Both independent producers and large criminal networks may source some or all of their chemicals from here.

“You can find them on any street corner,” an independent fentanyl cook in Culiacán, who sources all the chemicals he needs specifically from wholesaler networks, said of the bodegas. “I tell them I need X [chemical] and they give it to me. And if they don’t have it at the moment, they’ll get it for me.”

The other independent fentanyl producer interviewed in Culiacán also manufactures methamphetamine. He told InSight Crime that some wholesalers distribute a complete “meth kit” for approximately $400,000 Mexican pesos (around $23,500). This kit includes all the required substances to produce around 130 kilograms of methamphetamine.

Employees at Chemical Companies: Diversion

Highly regulated pre-precursor and precursor chemicals administered by experienced brokers like Rubio Zea are frequently the focus of authorities, but employees of chemical companies often sell other, less regulated substances to criminals. These employees play active and passive roles in diverting essential chemical substances due to threats of violence or financial incentives. Still, in most cases, the employees must have a strong understanding of the company’s internal controls, national regulations, and what conduct might arouse suspicion.

Mexico has a vibrant chemical industry. Thousands of Mexican companies produce, import, transport, distribute, or use essential chemical substances for legitimate purposes, according to business registration records accessed by InSight Crime. They are involved with cosmetics, international pharmaceuticals, cleaning products, agrochemicals, pesticides, residual management, or manufacturing flavors and fragrances.

However, given the scarcity of investigations and judicial cases in Mexico, it is hard to know which industry is most susceptible to diversion and to what extent companies from each industry are colluding with synthetic drug trafficking networks. Drug producers interviewed by InSight Crime said they had more contact with small- and medium-sized companies, rather than large international corporations.

On paper, Mexico has a very robust framework in place to monitor the flow of precursor chemicals handled by such companies. It is party to several international agreements to combat drug trafficking and has standardized controls for precursor chemicals. In addition, the country has an exhaustive list of chemicals subjected to routine monitoring and regulation that is not far from what the United States has in place.

However, in practice, Mexico faces many challenges. For example, due to corruption and a lack of internal oversight and due diligence, some mid- and small-sized Mexican companies may not know, may not care, or may not have the time to find out who their clients are, especially when it comes to essential chemical substances that are not strictly regulated.

For instance, InSight Crime investigators attempted to buy small quantities of acetone, tartaric acid, and sodium hydroxide — all chemicals that are monitored or regulated in Mexico for use in several legal industries but can also be used to produce methamphetamine and fentanyl — at chemical distributors near an agricultural region in Jalisco. We also contacted vendors of acetic acid, acetonitrile, and pill-pressing machines that advertised their products on the e-commerce platform Mercado Libre. In both cases, InSight Crime investigators did not face any questioning about what they planned to use the products for, nor were they required to provide personal information.

In addition, it is not uncommon for some chemical company employees to sell substances over the counter that should technically only be marketed through a strict oversight process, according to a former Cofepris official. These sales rarely arouse internal alarm or attention from regulatory agencies, especially considering the small quantities needed.

To understand the dimensions of the problem, consider acetic acid and sodium hydroxide. Both are used as essential chemical substances to produce fentanyl. If we assume that they are needed in equal measure to produce 3 tons of fentanyl to satisfy US consumption, that represents roughly 0.0012% of the total amount of both substances legally imported into Mexico in 2022, according to data gathered by Mexico’s National Chemical Industry Association (Asociación Nacional de la Industria Química – ANIQ) and the Altana Atlas.

“A company could easily justify where those quantities went. For example, these could be written down as residues,” said the former Cofepris official.

Still, experts told InSight Crime that most employees involved in chemical diversion likely know exactly what they are doing, even if they’ve been coerced or threatened to do so or could make a case for plausible deniability. Three sources in Michoacán, who work as methamphetamine producers for several different criminal groups, mentioned that they obtain substances like benzyl alcohol, toluene, benzene, and sodium hydroxide directly from authorized chemical distributors across Mexico.

All of these substances are known for their use in the production of methamphetamine, yet employees at these establishments play a crucial role in brokering access to these essential chemicals that also have legal uses. According to one of the methamphetamine producers, these brokers purchase the substances on behalf of the company themselves before informally reselling them to criminal actors.

“[The chemicals] only come to companies with permission,” one of the methamphetamine producers in Michoacán told InSight Crime. “Everything arrives at the port, but it’s not distributed there. The companies receive the shipments and then our people go get the products.”

This practice is not new. In 2015, the US-based company Taminco and their Mexican subsidiary admitted to selling over 22,000 gallons of monomethylamine, a pre-precursor used to produce methamphetamine, to two Mexican companies without conducting appropriate background checks. One of these companies was owned by the Taminco sales representative in Mexico, who then resold the substances to unknown buyers, according to a Bloomberg investigation.

It is unclear if Mexican authorities have detected similar cases. InSight Crime submitted an information request to Cofepris and the Attorney General’s Office about the number of registered cases of chemical diversion. Neither agency provided that information. In the United States, the DEA called InSight Crime’s information request regarding how many chemical companies the Diversion Control Division has sanctioned or fined in recent years for violating procedures related to chemical shipments and not maintaining effective controls against the theft and diversion of listed chemicals “overly broad” and declined to provide that information.

Moreover, employees at chemical companies are among the brokers who face the highest risks, including threats to their job security, potential exposure to law enforcement, and criminal violence. One of the methamphetamine producers in Michoacán, for example, told InSight Crime that when an employee at a chemical distribution center fails to cooperate, he resorts to threats or corruption. Although we could not find any public cases of murders of employees from chemical companies, the former Cofepris official and other sources from Mexico’s chemical and pharmaceutical industries told InSight Crime that employees frequently fear being threatened or kidnapped by criminal groups.

Mexico’s Laws to Regulate Chemicals Work on Paper But Not in Practice

Larger chemical companies have also faced scrutiny for diversion. In July 2021, Cofepris levied sanctions against a subsidiary of Grupo Pochteca, one of the largest chemical companies in Latin America. The disciplinary actions could have been related to anything from poor record keeping to improper reporting or diverting precursor chemicals used for drug production. It was never specified, and the company later paid a fine of about $8,000.

However, months later, in October 2021, Mexico’s Financial Intelligence Unit (Unidad de Inteligencia Financiera – UIF) froze several of that same subsidiary’s bank accounts as part of an investigation into the diversion of precursor chemicals. The company remains operational while the case is ongoing, according to court records obtained by InSight Crime. In an email, Grupo Pochteca told InSight Crime the company has never dealt with precursor chemicals. Import data from the Altana Atlas appears to support this claim.

But less than three years later, in January 2024, Mexican health officials suspended the operations of a facility in Culiacán that was run by the same Grupo Pochteca subsidiary sanctioned in 2021. The suspension was ordered due to irregularities that reportedly included selling certain chemical substances without verifying their end-use.

Customs Brokers: The ‘Eyes and Ears’

Authorities in both the United States and Mexico license and regulate individual customs brokers to assist importers and exporters in meeting federal requirements governing imports and exports. These individuals can play a fundamental role for both chemical suppliers and synthetic drug production networks when it comes to acquiring precursors for fentanyl production, according to US and Mexican law enforcement sources consulted by InSight Crime.

However, it seems the incentives for their participation and the use of them by criminal groups is lower than that of the other types of purveyors detailed above.

Customs brokers are the “eyes and ears” for authorities — and in some cases criminal groups — when monitoring what goes on at the ports, a security official at Mexico’s ANIQ told InSight Crime. If a Mexican company is importing a regulated chemical from Asia, for example, the customs agent contracted must verify the contents and proper labeling, the permits, that the authorities have been informed of the shipment, the origin and destination of its contents, and its means of travel.

In Mexico, registered customs brokers are required to coordinate with officials from the army, navy, and tax authorities to ensure the proper taxes are collected, as well as for administrative and accounting purposes, according to the country’s regulations. They are also responsible for physically inspecting the shipments they handle to ensure what they have reported and submitted to authorities is accurate.

However, they can manipulate this information using their own networks and expertise.

“They know who’s going to double-check the loads, who’s going to dig in,” said a former DEA official who worked at the agency’s Diversion Control Division, which investigates the diversion of pharmaceuticals and listed chemicals.

One way customs brokers could facilitate chemical shipments, according to US law enforcement sources and Mexican health officials, is by falsifying paperwork and database entries. Another way is to leverage their access to government computer systems that track shipments and log which ones may have been flagged to be seized or investigated further. Accessing this privileged information could make it easier for smugglers to identify weak points and ensure a shipment passes through undetected.

In other words, they can essentially act as a “middleman” who has “plausible deniability” if anything were to go wrong, the ex-DEA agent added.

But in Mexico, the network of customs brokers licensed by the National Customs Brokers Association (Agencia Nacional de Aduanas de México – ANAM) is small, and the number handling chemical shipments is even smaller. As of January 2024, official data obtained by InSight Crime showed there were only 815 licensed customs brokers. Of these, an even smaller number specialized in chemical products, according to our interviews with customs brokers. In contrast, in 2022, the country handled more than $600 billion worth of imported goods.

The number of licensed brokers is small, in part, because the process for getting a customs broker’s license is expensive and complicated. Applicants must be Mexican nationals, get a score higher than 85 out of 100 on an entrance exam, have no criminal convictions for crimes like robbery or murder, and pay associated fees totaling more than 70,000 pesos (around $4,000), among other qualifications.

For the small number of people who meet these requirements, working as a customs broker can be very lucrative due to the volume of business and the income that it generates. As such, customs brokers interviewed by InSight Crime said that there is little incentive to engage in illegal activity, even less so when potentially dealing with a large number of clients involved in criminal activity. What’s more, dealing with strictly regulated chemicals brings a lot of scrutiny, and customs brokers do not want to risk being audited, brokers told InSight Crime.

As of the end of 2023, a total of 91 customs brokers have had their licenses revoked, according to data obtained by InSight Crime. However, ANAM officials said those cancellations could not be considered a “penalty or administrative sanction,” as the agency does not keep detailed records of how many customs brokers have been sanctioned or had their licenses revoked due to corruption, criminal activity, or other misconduct. However, included among the offenses that could lead to a license being canceled is failing to properly report what items are being imported or importing items that are prohibited.

Lynchpins of the Precursor Supply Chain

In the early morning hours of July 20, almost exactly four months after her arrest, Guatemalan authorities transferred Rubio Zea from the Mariscal Zavala prison on the outskirts of Guatemala City to a nearby air force base.

Wearing the same gray Gucci sweatshirt she had on the day she was apprehended, they transferred Rubio Zea into DEA custody and extradited her to the United States. She arrived at the White Plains, New York airport around 10:00 pm and was driven straight to the Metropolitan Detention Center in Brooklyn.

The following day, she appeared at her first hearing to face drug trafficking charges in the Southern District of New York. Before adjourning, Judge Katherine Polk Failla asked Rubio Zea’s attorney, Kenneth Montgomery, if there was anything specific to his client that the judge should know.

He said there were a few medical issues, according to a transcript of the hearing. She needed a breast pump to care for her “very young child back at home in Guatemala,” as well as medicine for migraines she suffered.

During the mid-afternoon hearing, Rubio Zea explained that she was fluent in English and had no trouble understanding the charges levied against her. She calmly entered a not guilty plea.

There are reportedly “ongoing and productive discussions” taking place between Rubio Zea’s defense team and US prosecutors regarding a “potential pretrial resolution” to the case, according to the judge. Reached by phone, her lawyer, Montgomery, refused to comment on her case. US prosecutors also declined to comment.

The evidence against Rubio Zea is “wide-ranging,” according to court records. Prosecutors have said this includes intercepted WhatsApp communications, extracts from her i-Cloud account that contain financial statements and potentially incriminating conversations with other indicted co-conspirators, as well as records of purchases of precursor chemicals she allegedly made on behalf of the Chapitos and her efforts to disguise them.

Coupled with her possible cooperation, Rubio Zea may be key to unveiling the inner workings of the precursor chemical flow and a significant resource for authorities trying to disrupt the Chapitos’ fentanyl trafficking operations.

*InSight Crime Co-director Steven Dudley and investigators Victoria Dittmar and Sara García contributed reporting to this article. Miguel Ángel Vega also assisted with field interviews.

Altana supports InSight Crime’s research into precursor chemical flows by providing access to the Atlas, a dynamic, AI-Powered map of global supply chains, as well as to its Counternarcotics Dashboard, an AI-driven model to flag narcotics trafficking risk within global shipment and business ownership data.

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