Alleged ‘Pure Narco’ of Colombia’s Gulf Clan Linked to Broad Corporate Network, Luxury Real Estate Projects In Medellín

Alleged ‘Pure Narco’ of Colombia’s Gulf Clan Linked to Broad Corporate Network, Luxury Real Estate Projects In Medellín
Insights 9 minute READ 06/03/2021

A recently arrested alleged Colombian drug trafficker connected to one of the country’s largest transnational criminal organizations is linked to multiple luxury real estate development projects in and around Medellín as well as cattle breeding and hazardous waste companies, according to public records.

The arrest and findings are the latest example of a growing trend in Colombian organized crime, namely, the increasing preference of Colombian drug traffickers to operate under the radar and to legitimize their wealth by enmeshing themselves in the legitimate business community.

Various forms of publicly available information in Colombia, such as corporate and tax records from regional chambers of commerce, can be highly effective in unveiling the legal structures associated with these individuals.

Colombian authorities arrest alias “Andrea,” or “Falcón”

On May 22, Colombia’s Attorney General’s Office (Fiscalía General de la Nación, FGN) announced the indictment of Colombian national Juan José Valencia Zuluaga (alias Falcón, Andrea), on various charges including drug trafficking and money laundering.

The FGN accused Valencia Zuluaga of being one of the “pure narcos” (narcos puros) of the Gulf Clan, one of the country’s most powerful transnational criminal organizations, and for serving as the “principal actor in cocaine shipments sent from Colombia’s Caribbean coast to the United States, countries in Central America, and Europe,” according to the official press release.

Apart from coordinating drug shipments, Valencia Zuluaga also allegedly served as a key financial operator for the organization and was responsible for moving upwards of $16 million per month in illicit drug proceeds, according to the FGN.

The announcement by the FGN came days after Colombian news outlets first reported that Valencia Zuluaga had been arrested on May 7th in a $16 million mansion in the municipality of Rionegro, just east of Medellín, in the department of Antioquia.

Corporate records and other public information suggest that despite Valencia Zuluaga’s alleged role in coordinating cocaine shipments and money laundering on behalf of the Gulf Clan, he has become deeply enmeshed in Medellín’s business community, specifically through links to luxury real estate development projects, cattle ranching companies, and a waste disposal company.

Links to luxury real estate development projects

Valencia Zuluaga’s connection to luxury real estate projects in and around Medellín is via Acyonex S.A.S., a real estate development and construction firm based out of the Select Building (Edificio Select), in the upscale Medellín district of El Poblado.

Valencia founded Acyonex under his birth name Juan David Valencia Zuluaga, along with his father Juan José Valencia Cardona and one other person in August 2014, according to corporate filings from the Medellín Chamber of Commerce. At the time of incorporation, Valencia was listed as the 50 percent shareholder, legal representative, and general manager. The subscribed and paid-up capital at the time of incorporation was an estimated $50,000, based on the August 2014 exchange rate.

A company filing for Acyonex S.A.S. dated Aug. 29, 2019

Fig. 1: A company filing for Acyonex S.A.S. dated Aug. 29, 2019, listing Juan José Valencia Zuluaga and his father Juan José Valencia Cardona as the 50 and 25 percent shareholders, respectively.

Acyonex is connected to five ongoing luxury real estate projects, ranging from high-rise apartment buildings, to residential complexes both in Medellín and the surrounding area, according to the company’s website which was taken down days after the FGN announcement. However, the extent of the company’s direct involvement is unclear based on available public records.
A cached version of Acyonex’s website

Fig. 2: A cached version of Acyonex’s website showing the five residential projects in and around Medellín that the company is purportedly linked to.

Acyonex is also a shareholder of at least two additional real estate investment firms, both of which may provide more insight into Acyonex’s — and by extension, Valencia Zuluaga’s— involvement in the previously mentioned real estate projects.

In November 2018, a Medellín-based real estate development company called Zambia Natural S.A.S. registered with the Medellín Chamber of Commerce and listed Acyonex as a 40 percent shareholder. Zambia Natural shares a name with a luxury apartment building that is currently under construction in the El Poblado district of Medellín, and that Acyonex previously listed as one of its projects on its website.

A 40 percent co-shareholder of Zambia Natural S.A.S. — Creando Proyectos S.A.S. — was awarded an urbanization and construction license by the municipality of Medellín in November 2019, thus paving the way for the construction of the 17-story apartment building.

A letter from the municipality of Medellín approving the urbanization and construction application from Creando Proyectos S.A.S. for the construction of a 17-story apartment building in Medellín Articles of incorporation for Zambia Natural S.A.S., showing Acyonex, a company co-owned by Juan José Valencia Zuluaga

Fig. 3: Left: A letter from the municipality of Medellín approving the urbanization and construction application from Creando Proyectos S.A.S. for the construction of a 17-story apartment building in Medellín. Right: Articles of incorporation for Zambia Natural S.A.S., showing Acyonex, a company co-owned by Juan José Valencia Zuluaga, as the 40 percent shareholder, along with Creando Proyectos S.A.S. and Atelier Arquitectura y Construccion S.A.S.

Acyonex and Creando Proyectos are partners in another company linked to the construction of a different apartment complex in Sabaneta, a municipality just south of Medellín, according to corporate filings from Medellín’s Chamber of Commerce.

In August 2019, a real estate company by the name of Promotora Creacyonex S.A.S.  registered with the Medellín Chamber of Commerce; Acyonex and Creando Proyectos were listed as the 70 and 30 percent shareholders, respectively.

However, the articles of incorporation filed for Promotora Creacyonex also include a subtle detail exposing the company’s links to a luxury apartment project in Sabaneta. In its tax registry filing with Colombia’s tax and customs authority (Dirección de Impuestos y Aduanas Nacionales, DIAN), Promotora Creacyonex listed “Artek Apartamentos” as its commercial name.

A snapshot of the company constitution documents for Promotora Creacyonex S.A.S., listing Creando Proyectos S.A.S. and Acyonex S.A.SA snapshot of Promotora Creacyonex’s company information filed with DIAN, Colombia’s tax and customs authority

Fig. 4: Left: A snapshot of the company constitution documents for Promotora Creacyonex S.A.S., listing Creando Proyectos S.A.S. and Acyonex S.A.S. as the founding shareholders. Right: A snapshot of Promotora Creacyonex’s company information filed with DIAN, Colombia’s tax and customs authority, which lists its commercial name as Artek Apartamentos. 

A luxury apartment project by the same name was previously listed on Acyonex’s website, and is currently listed on Creando Proyectos’ website, suggesting that both companies may be investing in the project via Promotora Creacyonex.

Finally, Promotora Creacyonex is listed as the manager — and is a likely shareholder —  of a Medellín-based company called Coworking Ottium S.A.S. This name closely resembles the name of a third luxury real estate project listed on Acyonex’s and Creando Proyectos’ website — Ottium Lifestyle. Coworking Ottium also shares an address with Creando Proyectos at the Select Building in Medellín.

However, the extent of Coworking Ottium’s connection to the Ottium Lifestyle project is unclear. An additional company called Ottium S.A.S. registered with the Medellín Chamber of Commerce in November 2018. At the time of incorporation, the company listed “Ottium Lifestyle” as its commercial name, and Creando Proyectos S.A.S. as a 45 percent shareholder.

Neither Acyonex, Creando Proyectos, nor any of the other aforementioned companies or individuals have been accused of any crimes related to Valencia Zuluaga’s alleged drug trafficking and money laundering activities.

Stakes in hazardous waste disposal firm

Beyond links to Medellín-based real estate, Acyonex also owns shares in a hazardous waste company.

In February 2017, Acyonex obtained shares (30 percent) of Pacifico Desechos Hospitalarios S.A.S. E.S.P. — a company that had previously been based out of the Pacific Coast city of Buenaventura, but moved to Medellín sometime between April 2016 and April 2017.

Pacifico Desechos Hospitalarios changed its name in February 2017 to Global DH S.A.S. E.S.P. at the same time that Acyonex acquired 30 percent of the company’s shares. Valencia Zuluaga serves as a substitute legal representative for the company.

As with Valencia Zuluaga’s real estate holdings, Global DH has not been accused of any criminal activity or of being linked to Valencia Zuluaga’s alleged drug trafficking or money laundering activities.

Links to cattle breeding companies in Antioquia and Cordoba

Valencia Zuluaga’s business ventures go beyond real estate and hazardous waste to include stakes in a pair of companies dedicated to cattle breeding/ranching.

In November 2017, Valencia Zuluaga became a minority shareholder (7.12 percent) and substitute legal representative of a cattle breeding company based in Rionegro called Lechera San Angel S.A.S. The company was founded two years prior with an overall subscribed and paid up capital of about $3,000. When Valencia joined as a shareholder in November 2017, the subscribed and paid up capital increased to $210,000.

A week after becoming a minority shareholder of Lechera San Angel in November 2017, Valencia Zuluaga became a minority shareholder (6.25 percent) and substitute legal representative of an additional cattle ranching business originally based in Medellín — Agricola Palmares S.A.S.

The company has several shared characteristics with Lechera San Angel and Valencia Zuluaga’s broader corporate network.

Agricola Palmares was registered with the Medellín Chamber of Commerce in September 2015, a mere two months before Lechera San Angel registered with the Chamber of Commerce of Eastern Antioquia. Additionally, Valencia’s father, Juan José Valencia Cardona, was one of the founding shareholders of Lechera San Angel and was the sole founding shareholder of Agricola Palmares. Valencia Cardona has not been charged with any crimes.

Like Lechera San Angel, Agricola Palmares experienced a significant injection of subscribed and paid up capital at the time of Valencia’s entrance as a minority shareholder. Agricola Palmares was founded with a total subscribed and paid up capital of $15,000. That value increased to $240,000 when Valencia became a minority shareholder in November 2017.

Furthermore, while Valencia Zuluaga only owned a minority stake in Lechera San Angel and Agricola Palmares by November 2017, both companies were and continue to be majority owned by Valencia Zuluaga’s parents.

Agricola Palmares also has links to Acyonex, Valencia Zuluaga’s Medellín-based real estate company. In November 2017 when Valencia became a minority shareholder, Agricola Palmares also changed its physical domicile from Medellín to the municipality of Buenavista, in the department of Cordoba, which is located about 200 miles north of Medellín. The change of physical domicile listed an administrative and judicial address in the Select Building in Medellín  at the same address as Fundación Acyonex, a foundation linked to Acyonex S.A.S., as well as Global DH, the hazardous waste company that is 30 percent owned by Acyonex S.A.S.

Tracing Colombia’s “pure narcos” using public records

The Colombian authorities describe Valencia Zuluaga as one of the Gulf Clan’s most important “pure narcos” — a term used to distinguish between individuals devoted solely to the business of drug trafficking and/or money laundering, and the paramilitary wing of the organization.

The term also refers to a new generation of drug traffickers that prefer to keep their illegal operations under the radar, according to a police file from Colombia’s National Police reviewed by El Tiempo. This contrasts with previous generations of Colombian drug capos like Pablo Escobar who outwardly flaunted their excesses and were widely known to be involved in drug trafficking.

The new generation of “pure narcos” — also known as the “Invisibles” — seek to limit their exposure to criminal investigations by intermingling with Colombia’s high society and passing themselves off as successful businessmen, according to the police file. Additionally, investments in legitimate business ventures not only serve to complete their façade, but can also be leveraged to launder drug proceeds.

Official public records show that Valencia Zuluaga may fit this profile quite well. While Valencia Zuluaga allegedly served as one of the Gulf Clan’s most important drug traffickers, his corporate footprint and purported links to luxury real estate development projects suggest that he may have used these as fronts to blend in with the city’s thriving business community.

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