Five cartel companies were born before Marina del Pilar's campaign.

On September 29, 2026, the U.S. Department of the Treasury blocked 21 individuals and 25 companies that, according to its own investigation, work for Los Mayos, the Sinaloa Cartel faction now led by Ismael Zambada Sicairos, Mayito Flaco. Among those blocked: the ex-husband of the governor of Baja California, that ex-husband's brother, a former chief of the Mexicali police, and a former acting head of the Ciudad Juárez customs office. The release contains a sentence never before printed in an official Washington document about a Mexican state government: Sinaloa Cartel-enabled narco-corruption "has reached the highest levels of the Baja California state government".

What the release does not say weighs almost as much as what it says. It does not say when those 25 companies were born. It does not say that five of them were incorporated in the four months before the campaign that put the governor in office. It does not say that an advertising agency was incorporated 27 days before the 2024 election. It does not say that the governor left the shareholder registry of one of those companies 19 days before the blocking. And it does not name a single Mexican agency among the nine U.S. institutions that took part in the investigation.

This investigation measures those things. With the official file of the Office of Foreign Assets Control (OFAC), folio by folio, date by date.

A. Treasury writes that Luis Alfonso Torres Torres, brother of the governor's ex-husband, was responsible for taking the cartel's bribes and laundering them "through companies and political campaigns". That phrase, political campaigns, is the one this investigation takes seriously.

B. Four of the 25 blocked companies sell exactly what a campaign buys: shows, event staging, audio, lighting, advertising. One was born 46 days before the 2021 gubernatorial campaign began. Another was born 27 days before the 2024 federal election.

C. If any campaign paid any of those companies, cartel money entered and exited Mexico's electoral system with an invoice. That leaves a document: the entry in the INE's Integrated Oversight System. And it leaves a judge: the one who has had Mayito Flaco's case open in the Southern District of California since 2014.

OFAC designated Carlos Alberto Torres Torres (CURP TOTC751118HBCRRR06) and Luis Alfonso Torres Torres (CURP TOTL600907HBCRRS00) under Executive Order 14059 for material support to the Sinaloa Cartel and under Executive Order 13224, as amended, for material assistance to a foreign terrorist organization. Treasury describes Carlos Torres as a "cartel-linked political operator" allied with Juan José Ponce Félix, El Ruso, head of Los Rusos in Mexicali. It states that the State Department revoked his U.S. visa in May 2025 "due to his cartel affiliation and work on behalf of the Sinaloa Cartel". And it states that he "reportedly" received monthly payments from Pedro Ariel Mendívil García.

Mendívil García was Mexicali's Director of Municipal Public Security from December 2021 to September 2024, appointed by Mayor Norma Alicia Bustamante and approved unanimously by the city council. Baja California press documented that the appointment was a recommendation from the governor. Mexican authorities arrested him in late July 2026. OFAC says he took bribes from El Ruso in exchange for cartel control of the municipal police.

Rafael Buenrostro Martín (CURP BUMR821228HBCNRF02), from Mexicali, was a legislative advisor to the Baja California state government and then a federal official: he joined Mexico's National Customs Agency on June 16, 2025, as deputy director of customs operations in Ciudad Juárez, and from November 1, 2025, served as acting head of that customs office, replacing a colonel removed amid a fuel smuggling investigation. He resigned on January 9, 2026. OFAC describes him as a close friend of Sinaloa Cartel leader José Ángel Rivera Zazueta, to whom he gave "political favors and influence" in exchange for bribes.

The September 29 action continues the one of September 18, 2025, when OFAC designated Los Mayos and the Jesús González Lomelí node in Playas de Rosarito, including a former mayor, fourteen bars and hotels, and the municipality's public transport concessionaire. This space documented that node on September 15, 2026 (HLZ-185). Treasury now designates González Lomelí's partners in Tijuana: Marco Antonio Moreno Gómez Santelices, Carlos Villela Gómez Santelices, and brothers Jerónimo Javier and Jorge Mario Vera Ayala. According to corporate records cited by the press, two of the companies blocked in 2025 were incorporated in May 2021 with Jerónimo Vera and Jorge Alberto Hank Inzunza as shareholders; Hank Inzunza has not been accused by any authority.

Governor Marina del Pilar Ávila Olmeda is not designated. Her name does not appear in the SDN file. This text treats her with full presumption of innocence and records only what public documents show: she was a founding partner of Vida Orgánica Tijuana, S. de R.L. de C.V., and ceased to appear as a partner in the Tijuana Public Commerce Registry on September 10, 2026.

Vida Orgánica Tijuana's public business is an organic food market. In OFAC's official file, the company's registered line of business is something else: "Transportation and storage". Commercial folio N-2020074577. Incorporated November 9, 2020, when the current governor was mayor of Mexicali. According to the commercial registry cited by the press, it had seven founding partners and share capital of one hundred thousand pesos; the governor and her then-husband contributed fifteen thousand each.

The governor's exit was registered on September 10, 2026. OFAC's blocking came on the 29th. Nineteen days. What no report has published is the date of the shareholders' meeting that approved that transfer. A meeting can be signed months before it is registered. If the meeting took place in 2025, the exit was simply late. If the meeting took place in September 2026, the question changes size: who knew the list was coming.

Festivales Artistas Mobiliario Asesoría, alias Promociones CHF de Baja California, folio N-2021012223, official line: creative, arts and entertainment activities. Conciertos y Espectáculos Inhouse, S.A.P.I. de C.V., folio N-2023100920, incorporated January 25, 2023, same line. Wermak Publired, S.A. de C.V., folio N-2023089074, incorporated June 12, 2023, same line. Publicidad e Imagen Integral ENLA-C, line: advertising. Three from the Moreno node, one from the Buenrostro node.

A Baja California press column reported on September 30 that the State Attorney General's Office had "official advertising" contracts with Festivales Artistas Mobiliario Asesoría and Promociones CHF for audio, lighting, projection and simultaneous interpretation, with line items split up. It is a press allegation, level D, pending verification in Compranet and the National Transparency Platform. I record it because it turns the campaign hypothesis into something larger: the government hypothesis.

The document that resolves Finding 3 exists and is public by law: the INE's National Registry of Suppliers, where any campaign vendor must be registered, and the entries in the Integrated Oversight System for the 2021 gubernatorial campaign and the 2024 campaigns in Baja California. This investigation has requested that information. When it arrives, it gets published.

Inteliproof Efficient, S. de R.L. de C.V., RFC IEF201019BY7, folio N-2020075511, official line: private security. OFAC attributes it to Marco Antonio Moreno Gómez Santelices. A press review of Compranet documented that in 2024 the Baja California government's Oficialía Mayor awarded it six no-bid contracts worth 6,080,938 pesos before tax: computing equipment, digital storage, protective clothing for the Local Search Commission, and vehicle parts. Pending direct verification, but with traceable contract numbers.

The articles of incorporation cited by the press list as founding partner, alongside Moreno, Jorge Enrique Figueroa Barrozo, president of Canacintra Tijuana from 2021 to 2024 and appointed in November 2024 by the federal Ministry of Economy as coordinator of the Economic Well-Being Corridor in Baja California. Figueroa Barrozo has not been accused by OFAC or any authority. Level D: registry data, no imputation.

Inteliproof also holds federal private security permit DGSP/291-22/4718, valid through December 2026, according to the public registry of the General Directorate of Private Security as cited by the press. A company blocked by Treasury for laundering Sinaloa Cartel money holds, today, a federal license to carry weapons and guard property in Mexico.

The one who had time wins. The one who collected six no-bid awards in 2024 wins. The one who ran a federal customs office while, according to Treasury, doing favors for a Sinaloa Cartel leader wins.

The Baja California taxpayer who funded a company Washington blocked pays. The electorate that, if Finding 3 is confirmed, voted in an election where one side bought events from a cartel company pays. And the whole state pays: the release puts a name on the phrase "the highest levels of the state government", and every correspondent bank will read it before processing a wire to Mexicali or Tijuana.

There is no public evidence that any campaign paid the four companies in Finding 3. The coincidence of dates is a fact; the payment is a hypothesis with a document pending. The governor is not designated and nothing in OFAC's file implicates her. There is no proof that anyone leaked the list; there is a date nobody has requested. Figueroa Barrozo, Bustamante, Burgueño and Hank Inzunza appear through public records and appointments, not through any authority's accusation. Every person named retains the presumption of innocence without exception.