Crossing Borders: The Evolution and Impact of Tren de Aragua

This article explores the origins, evolution, and transnational operations of Tren de Aragua, a Venezuelan gang that has grown from prison-based roots into a powerful, violent, and adaptable criminal organization with global reach. It examines how systemic corruption, weak governance, and state complicity have enabled the gang’s expansion, highlighting its deep entanglement with political power and the broader implications for regional and international security.

Introduction

As debates over migration and crime intensify in the United States, Tren de Aragua has emerged at the forefront of political discussions.[1] Once confined to Venezuela’s prison system, the gang has rapidly expanded its operations across Latin America and now into the United States, raising alarm among policymakers and law enforcement.[2] Its involvement in diverse criminal activities, such as human smuggling, money laundering, and drug trafficking, has made it a focal point in debates over border security and transnational criminal threats, prompting calls for stronger measures to curb its influence.[3] In fact, at one point in 2024, United States (US) federal authorities were conducting over 100 investigations connected to the gang.[4] Its evolution follows patterns seen in other transnational criminal organizations, where systemic instability and state complicity enable expansion and diversification of criminal enterprises.[5] Tren de Aragua employs extreme violence and extensive corruption to maintain control, infiltrating political and law enforcement structures while destabilizing communities and threatening regional security.[6] This paper examines the group’s origins, expansion, operational strategies, and transnational impact, assessing both the threats it poses and the effectiveness of countermeasures taken to disrupt its activities.

Origins in Venezuela’s Prison System

Tren de Aragua originated at the crossroads of labor unrest and criminal consolidation. The name Tren de Aragua, meaning “Train of Aragua,” traces its origins to labor unions involved in an unfinished railway project intended to connect central and western Venezuela.[7] Some of these union members drifted into criminal activity, leading to their eventual imprisonment.[8] Héctor Rusthenford Guerrero Flores, known as “Niño Guerrero,” played a pivotal role in shaping Tren de Aragua into its current form while imprisoned in Tocorón for a 17-year sentence for murder and drug trafficking.[9] He reportedly wielded so much influence that he could enter and leave the prison at will before he became a permanent inmate:[10] “Within a decade of his arrival, Guerrero would be in charge of every single aspect of the prison.”[11]

Under Guerrero’s leadership, the gang became more structured and expanded its ranks by recruiting members from within Venezuela’s prison system.[12] Inside Tocorón, Tren de Aragua solidified its control by imposing a tax known as “the cause,” which required inmates to pay for protection and privileges.[13] The penalties for non-payment were ruthless: “The first time you don’t pay, they shoot your wrist. The second time, your ankle. A third time, and you face the death penalty.”[14] These brutal tactics, often recorded and circulated, cemented Tren de Aragua’s rule through fear.[15] As a result, Tocorón became one of Venezuela’s most infamous prisons and Tren de Aragua’s headquarters. With state complicity and rampant corruption, the gang transformed Tocorón into its luxurious headquarters, complete with a zoo, swimming pool, playground, gym, restaurants, a nightclub, and even a betting parlor for horse races.[16] Guards were bribed, families visited freely, and the prison functioned as a fortified criminal enclave.[17] Structural decay, overcrowding, and absent oversight allowed Tren de Aragua to rule unchallenged.[18]

Territorial Expansion among State Complicity

Tren de Aragua’s prison-honed violence continues to define its operations in and beyond Tocorón’s walls.[19]Guerrero consolidated his power through territorial control in central Venezuela, particularly in Macary, Aragua, the state’s capitol, where his criminal rise began in Maracay with the 2005 killing of a police officer.[20] By then, Tren de Aragua was already known for kidnappings, extortion, and bribery.[21] Even after his 2010 arrest for drug trafficking,[22] Guerrero’s grip on Maracay held firm, with Tren de Aragua enforcing curfews, stealing vehicles, and extorting residents.[23] In San Vicente, a large community in Macaray, a local woman described her neighborhood as “a prison without bars,” reflecting Tren de Aragua’s control over all aspects of daily life, including schools, justice, and even home decorations.[24] From Aragua, the group expanded its territorial control into Lara, Trujillo, Sucre, Miranda, Guárico, Carabobo, and Bolívar[25]—building a criminal economy that links street-level networks to prison strongholds.[26]

The government’s tolerance of criminal enterprises like Tren de Aragua reflected a broader pattern of state dysfunction under President Nicolás Maduro. Since taking office in 2013,[27] Maduro has consolidated power through repression and corruption,[28] driving the country from “partly free”[29] to “not free,”[30] according to Freedom House. According to the US State Department, “Maduro and his inner circle dismantle Venezuelan democracy piece by piece.” [31] As institutions and the rule of law crumble, criminal groups like Tren de Aragua flourish, as official corruption is a key enabler of transnational criminal activity.[32] In 2023, a heavily publicized raid on Tocorón prison—meant to project Maduro’s strength ahead of the 2024 elections[33]—failed to capture Guerrero and other gang leaders, who were reportedly warned about the raid after negotiating with the government in advance.[34] Although his whereabouts remain unknown, Guerrero continues to oversee Tren de Aragua’s operations despite the loss of its primary base in Venezuela.[35]

Shutting down Tocorón prison did not dismantle Tren de Aragua. Although their headquarters was eliminated, the gang’s leaders and international networks remained active, allowing operations to continue.[36] The seizure of Tocorón deprived Guerrero of “the cause,” a major source of illicit revenue.[37] However, the gang swiftly adapted by exploiting the profit potential in immigration.[38] As of June 2024, more than 7.7 million Venezuelans have fled the country due to economic collapse and Maduro’s authoritarian rule.[39] Tren de Aragua has capitalized on this mass exodus, expanding its influence beyond Venezuela’s borders[40] and showcasing how a single weak jurisdiction can create a loophole that undermines the integrity of the entire international system.[41] Investigators in Chile and Peru estimate that a portion of Tren de Aragua’s criminal earnings abroad—totaling approximately $15 million annually[42]—flows back to Guerrero through remittances and small bank transfers, enabling the gang to evade financial authorities.[43]

Tren de Aragua is the only Venezuelan gang to successfully expand its influence beyond national borders.[44]Defined by adaptability, brutality, and a vast criminal portfolio, the gang engages in over 20 illicit activities, including drug trafficking, illegal mining, extortion, migrant smuggling, human trafficking for sexual exploitation, and kidnapping.[45] While many regional criminal groups rely heavily on drug revenue, Tren de Aragua has cultivated a more diversified and opportunistic economic portfolio—one that capitalizes on institutional weaknesses, porous borders, and vulnerable populations. Migrant smuggling and extortion are especially lucrative; the gang dominates key migration corridors, charging for passage and leveraging violence to control routes.[46] Its trafficking operations are tightly interwoven with prostitution rings.[47] To maintain discipline internally and project dominance externally, Tren de Aragua often records and disseminates videos of its killings, turning brutality into a strategic weapon.[48] Tren de Aragua’s economic model sets it apart from many traditional organized crime groups, relying less on drug trafficking and more on diversified, opportunistic income streams that exploit structural vulnerabilities across the region. This convergence of decentralized finance, asymmetric violence, and psychological warfare not only fuels the gang’s expansion, but also renders it uniquely resilient in the face of law enforcement crackdowns.

Their expansion into illicit markets beyond Venezuela—and even Latin America—has not only fueled insecurity and rising homicide rates in countries like Peru, Chile, and Colombia but has also contributed to broader transnational crime networks.[49] Tren de Aragua first drew attention in Peru around 2019 when authorities discovered dismembered bodies[50]—evidence of what Peru’s National Police intelligence director called “another level of cruelty and of organization.”[51] In Chile and along its border with Bolivia, Tren de Aragua has established a foothold,[52] while in Colombia, it has battled rival groups for control of key border crossings with Venezuela.[53] Regional officials and security forces have noted the gang’s readiness to employ targeted violence to eliminate rival gangs.[54] In October 2023, US authorities announced the first arrest of an alleged member of the Tren de Aragua in the United States.[55] While authorities’ methods for identifying Tren de Aragua members or their connections to the broader organization remain unclear, reports of their activities have surfaced in at least ten US states.[56] The lack of cooperation from the Venezuelan government, which provides no data on suspected criminals entering the United States, has led some law enforcement officers to label Tren de Aragua as “ghost criminals,” with little to go on aside from confessions or tattoos for identification.[57]

Meanwhile, in Venezuela, officials have reacted with surprise to the gang’s growing notoriety abroad. In September 2023, Maduro’s government claimed it had dismantled the group after reclaiming control of Tocorón prison.[58] In July 2024, Foreign Minister Yván Gil went even further, dismissing Tren de Aragua as a “fiction created by the international media.”[59] However, the gang has been described as Venezuela’s “tool of asymmetric warfare to destabilize countries while maintaining plausible deniability.”[60] It has long been suspected of operating on behalf of the Venezuelan regime, with its members allegedly carrying out political destabilization efforts in countries with significant Venezuelan communities.[61] More recently, Tren de Araguais believed to be targeting individuals deemed a threat to Maduro’s government.[62] In January 2025, Maduro was sworn in for a third term as Venezuelan president despite evidence of election loss.[63] The same month, Chile released a police report that deduced “Venezuela wanted a dissident [in Chile] dead and hired Tren de Aragua gang to kill him.”[64]

Such allegations of state utilization illustrate the deep entanglement between political power and organized crime, positioning Venezuela as a paradigmatic case of ‘criminal capture,’ where transnational organized crime is leveraged as a tool of statecraft, and elements of state power become embedded within the operational framework of criminal organizations.[65] Governments in developing countries like Venezuela face the greatest risk of “criminal capture,” as limited resources must be stretched across numerous urgent and competing priorities.[66] In Venezuela’s case, the state has “substituted the resources it does not have for tolerance towards illegal activities.”[67] The Venezuelan state is nearly bankrupt, and illicit activities provide what the government cannot—payment.[68] What may have started as a means to an end has become an objective in itself; decades of illicit activity have enriched elites and empowered security forces.[69] Over time, those in power manipulate laws, policies, and regulations to serve their own interests, resulting in full state capture.[70]

Violence and Corruption: Tren de Aragua’s Dual Strategy

A retired US Drug Enforcement Administration agent expressed, “What sets [Tren de Aragua] apart is the level of violence. They’re aggressive, they’re hungry and they don’t know any boundaries because they’ve been allowed to spread their wings without any confrontation from law enforcement until now.”[71] While Tren de Aragua’s violent acts often make headlines, forcing authorities to respond, its corrupt dealings operate more discreetly, allowing the gang to embed itself within institutions and maintain long-term operations. In this way, Tren de Aragua straddles both a parasitic and predatory relationship with society—using corruption to infiltrate and manipulate political and economic systems while wielding violence to dominate illicit markets and challenge state authority when necessary.[72] As Tren de Aragua has grown, it has strategically embedded itself within local criminal economies, developed transnational financial networks, used cryptocurrency for money laundering, and established connections with other formidable crime groups.[73] Its transnational reach has elevated Tren de Aragua from a regional criminal group to “an actor in international relations;” its capacity to amass substantial financial resources, evade law enforcement detection, and strategically use corruption to influence public officials gives it considerable leverage in political affairs.[74]

Tren de Aragua’s transformation reflects its adaptability and ability to exploit weak governance, corruption, and illicit economies to expand its influence. Historically, the gang operated under a centralized, hierarchical structure led by Guerrero, supported by two key lieutenants—collectively known as “the three daddies.”[75]The tripartite leadership oversees operations through a network of trusted subordinates and country-specific cells.[76] Even as the group expanded, it maintained a clear chain of command, reinforced by lieutenants known as “luceros” who managed local operations on the ground. Despite Guerrero’s disappearance, the gang maintains control through a network of luceros who manage local operations.[77] Another key operative oversees part of the gang’s activities through the Somos el Barrio JK Foundation, a pseudo-social community front that helps funnel resources and maintain public influence.[78] Additionally, Tren de Aragua maintains satellite gangs as auxiliary forces to provide recruitment pipelines and logistical support.[79]

Security forces in Peru, Chile, and Colombia indicate that despite the gang’s geographic expansion, Tren de Aragua has preserved its hierarchical structure, with Guerrero remaining in command.[80] Judicial records reveal that several of the gang’s lieutenants have been assigned to different cells across the region, with some even rotating between multiple countries to maintain coordination.[81] Tren de Aragua has forged extensive connections with organized crime networks and prison-based gangs both within Venezuela and abroad, establishing agreements of non-aggression and even revenue-sharing partnerships.[82] These loosely affiliated structures may operate independently or in overlapping territories, contributing to confusion over which crimes are committed by core members and which are attributed to unaffiliated criminal franchises. At the same time, globalization has enabled Tren de Aragua’s transnational growth while complicating law enforcement responses. The gang has leveraged the cross-border movement of goods, people, and capital to build international financial networks, smuggle migrants, and launder money—often using cryptocurrency.[83]As states prioritize open markets and regional integration, criminal organizations like Tren de Aragua exploit these very systems to traffic illicit goods, finance operations, and evade detection with increasing ease.[84]

Prior to September 2023, Tren de Aragua conformed closely to the regional hierarchy typology: it operated under a centralized leadership structure with a clear command system extending across multiple countries.[85]Its cells—geographically dispersed across the Americas—exercised varying degrees of autonomy but largely answered to the top leadership.[86] The gang also maintained a strong social identity tied to its Venezuelan roots.[87] However, following the September 2023 raid on Tocorón, evidence suggests that the group’s centralized command has weakened. Analysts and law enforcement officials across Latin America have reported increasing fragmentation, the rise of semi-autonomous cells, and the emergence of copycat groups operating under the Tren de Aragua name without clear ties to core leadership.[88] Several groups appear to operate without direct oversight from Guerrero or his inner circle, and copycat organizations have emerged under the Tren de Aragua name, further muddying the landscape.[89] An illustrative case of Tren de Aragua’s fragmented organizational structure occurred in April 2025, when 21 Venezuelan men were indicted in Manhattan not as direct members of Tren de Aragua, but as part of a dissident faction identifying as “Anti-Tren.”[90] This group reportedly separated from the original organization and engaged in hostile actions against former affiliates.[91] Initial media coverage tended to frame this development as indicative of an emerging violent gang conflict on US territory.[92] However, the indictment more accurately reflects underlying structural dynamics within Tren de Aragua—specifically, that its decentralized and adaptable nature facilitates the emergence of semi-autonomous or rogue elements operating with limited oversight from central leadership.[93] This case highlights operational and investigative challenges arising from Tren de Aragua’sdiffuse organizational model.

The Future of Tren de Aragua

Strategies to confront Tren de Aragua have faced significant obstacles given the lack of coordinated actions by national governments. The gang’s expansion into Colombia, Peru, and Chile has disrupted local criminal landscapes, prompting increased attention from regional authorities.[94] In response to concerns over its growing influence, particularly in the United States, the US Treasury Department designated Tren de Araguaas a transnational criminal organization in July 2024.[95] Additionally, following a January 2025 Executive Order,[96] designated Tren de Aragua as a Foreign Terrorist Organization,[97] marking a significant escalation in federal counter-crime efforts. This designation enabled the use of counterterrorism tools, including asset freezes, material support charges, and enhanced interagency coordination.[98] It also paved the way for a $12 million reward for information leading to the capture of three of the gang’s top leaders.[99]

In the months that followed, US authorities intensified crackdowns through joint operations led by the Department of Homeland Security[100] and the Federal Bureau of Investigation,[101] resulting in arrests, deportations, and the disruption of Tren de Aragua-linked smuggling and extortion networks in multiple states. This increased intra-collaboration reflected growing political and media attention, with lawmakers invoking the gang’s rise in debates over border security and hemispheric migration policy.[102] However, the lack of cooperation between US and Venezuelan authorities has severely hindered law enforcement efforts.[103]Without access to Venezuelan criminal records, US officials struggle to identify suspected Tren de Araguamembers crossing the border; officers have no way to verify identities beyond relying on self-reported information.[104] This information gap has allowed some affiliated individuals to enter North America undetected, often by posing as asylum seekers. Citing Tren de Aragua’s growth and the need for information-sharing, the United States and Canada signed a Memorandum of Cooperation to intensify joint efforts.[105]

The broader international community remains noticeably absent in efforts to counter Tren de Aragua. The transnational nature of the group highlights vulnerabilities in the international system.[106] The gang exploits weak jurisdictional oversight, state disagreements on cross-border crime enforcement, and gaps in information-sharing.[107] Furthermore, unintended consequences of international sanctions on Venezuela and inconsistencies in state policies enable the gang’s entrenchment.[108] Systemic issues blur the lines between traditional law enforcement and national security concerns, making it even more challenging to dismantle Tren de Aragua’s operations.[109]

Tren de Aragua’s trajectory from a prison-based gang to a dominant transnational criminal organization underscores the evolving nature of organized crime. As “Venezuela’s most powerful homegrown criminal actor,”[110] it has successfully extended its reach across South America, marking the first time a Venezuelan gang has projected itself internationally.[111] Despite efforts to dismantle its leadership, Tren de Aragua’s ability to adapt, diversify its operations, and exploit weak governance structures has allowed it to maintain its influence.[112] However, as it continues to expand, internal fragmentation remains a potential challenge, particularly with Guerrero’s high profile limiting his mobility and restricting his direct control over international factions.[113] While Tren de Aragua’s growth has heightened security concerns and intensified policy debates in the United States, its future trajectory will depend on the effectiveness of international cooperation, law enforcement strategies, and broader efforts to address the systemic vulnerabilities that enable its operations.

Conclusion

Tren de Aragua’s evolution from a Venezuelan prison gang into a transnational criminal powerhouse illustrates how organized crime can flourish amid weak governance, corruption, and fragmented international cooperation. Through a potent blend of violence, corruption, and strategic adaptation, the gang has infiltrated political and economic systems, expanded across borders, and challenged state authority. Its hierarchical structure and ability to exploit global economic flows—especially through tools like cryptocurrency and migrant smuggling—have solidified its position as a regional hegemon in the criminal underworld. The lack of coordinated international responses, particularly the limited collaboration between the US and Venezuela, has allowed the group to operate with impunity. Addressing the threat posed by Tren de Aragua will require a robust multilateral strategy, including improved cross-border intelligence sharing, financial tracking of illicit networks, and stronger institutional responses to corruption and organized crime. Without a unified international effort, Tren de Aragua’s influence will likely continue to grow, further destabilizing the Americas and challenging the effectiveness of current law enforcement and governance models.

Endnotes

[1] Venezuela Investigative Unit, “What We Know About Tren de Aragua’s US Presence.” InSight Crime. 4 October 2024,https://insightcrime.org/news/what-we-know-about-tren-de-araguas-us-presence/.

[2] Katie Smith, “Venezuelan gang Tren de Aragua now in 16 states: Report.” NewsNation. 25 November 2024, https://www.newsnationnow.com/crime/venezuelan-gang-tren-de-aragua-16-states-report/.

[3] “Treasury Sanctions Tren de Aragua as a Transnational Criminal Organization,” US Department of the Treasury. 11 July 2024, https://home.treasury.gov/news/press-releases/jy2459.

[4] Luis Ferré-Sadurní and Chelsia Rose Marcius, “Venezuelan Gang’s Path to U.S. Stokes Fear, Crime and Border Politics.” New York Times. 22 September 2024, https://www.nytimes.com/2024/09/22/nyregion/venezuelan-gang-aragua-crimes.html.

[5] Ibid.

[6] Venezuela Investigative Unit, “Tren de Aragua: From Prison Gang to Transnational Criminal Enterprise.” Jeremy McDermott, Peter Appleby, and Mike LaSusa, eds. InSight Crime. October 2023, pp. 5-6, https://insightcrime.org/wp-content/uploads/2023/08/Tren-de-Aragua-From-Prison-Gang-to-Transnational-Criminal-Enterprise-InSight-Crime-Oct-2023-1.pdf.

[7] Daniel Trotta and Jose Del Pino, “Explainer: What is the Venezuelan prison gang Tren de Aragua?” Reuters. 11 July 2024, https://www.reuters.com/world/americas/what-is-venezuelan-prison-gang-tren-de-aragua-2024-07-11/.

[8] Ibid.

[9] Antoinette Radford and Vanessa Buschschlüter, “Tocorón prison: Venezuela regains control of gang-run jail with pool and zoo,” BBC. 21 September 2023, https://www.bbc.com/news/world-latin-america-66873494.

[10] Ibid.

[11] Chris Dalby, Tren de Aragua: The Guide to America’s Growing Criminal Threat. Virtual: World of Crime, 2025, p. 111.

[12] Op. cit., Venezuela Investigative Unit, p. 5 at Note 6.

[13] “Venezuela: A Mafia State?” InSight Crime, 41.

[14] “The Rapid Rise of Venezuela’s ‘Tren de Aragua’ Gang Leaves Destruction and Death in Its Wake,” Organized Crime and Corruption Reporting Project (OCCRP). 9 November 2023, https://www.occrp.org/en/project/narcofiles-the-new-criminal-order/the-rapid-rise-of-venezuelas-tren-de-aragua-gang-leaves-destruction-and-death-in-its-wake.

[15] “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero,’” InSight Crime. 12 July 2024, https://insightcrime.org/venezuela-organized-crime-news/hector-rusthenford-guerrero-flores-alias-nino-guerrero/.

[16] Op. cit., Trotta and Del Pino at Note 7.

[17] Ibid.

[18] “World Report 2023: Venezuela.” Human Rights Watch. 2023, https://www.hrw.org/world-report/2023/country-chapters/venezuela.

[19] Op. cit., “The Rapid Rise of Venezuela’s ‘Tren de Aragua’ Gang Leaves Destruction and Death in Its Wake” at Note 14.

[20] “Tren de Aragua,” InSight Crime. 12 July 2024, https://insightcrime.org/venezuela-organized-crime-news/tren-de-aragua/.

[21] Ibid.

[22] Ibid.

[23] Op. cit. “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[24] Ronna Rísquez, “7 Key Facts About Venezuela’s ‘Tren De Aragua.’” InVisibles. Accessed 9 June 2024, https://invisibles.info/en/train-aragua-venezuela-explainer/.

[25] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[26] Joseph Humire, “Derailing the Tren de Aragua,” Heritage Foundation. 5 December 2024, https://www.heritage.org/border-security/report/derailing-the-tren-de-aragua.

[27] Emilia Díaz-Struck and Juan Forero, “Venezuelan president Nicolás Maduro given power to rule by decree.” Washington Post. 19 November 2023, https://www.washingtonpost.com/world/the_americas/venezuelan-president-maduro-given-power-to-rule-by-decree/2013/11/19/af304c3c-516b-11e3-9ee6-2580086d8254_story.html.

[28] “Venezuela: A Democratic Crisis,” US Department of State. 11 February 2025, https://2017-2021.state.gov/a-democratic-crisis-in-venezuela/.

[29] Arch Puddington, “Freedom in the World 2013: Democratic Breakthroughs in the Balance.” Freedom House. 2013, p. 18, https://www.freedomhouse.org/sites/default/files/FIW%202013%20Booklet.pdf.

[30] Yana Gorokhovskaia, Adrian Shahbaz, and Amy Slipowitz, “Freedom in the World 2023: Marking 50 Years in the Struggle for Democracy,” Elisha Aaron, David Meijer, Shannon O’Toole, Tyler Roylance, and Lora Uhlig, Eds. Freedom House, March 2023, https://freedomhouse.org/sites/default/files/2023-03/FIW_World_2023_DigtalPDF.pdf.

[31] Op. cit., World Report 2023: Venezuela at Note 18.

[32] Patrick Radden Keefe, “The Geography of Badness: Mapping the Hubs of the Illicit Global Economy,” in Convergence: Illicit Networks in the Age of Globalization, Michael Miklaucic and Jacqueline Brewer, Eds. Washington, DC: NDU Center for Complex Operations, 2013, pp.104–105.

[33] Jeremy McDermott, “Venezuelan Military ‘Invades’ Notorious Prison.” InSight Crime. September 20, 2023, https://insightcrime.org/news/venezuelan-military-invades-notorious-prison/.

[34] Op. cit., “Tren de Aragua” at Note 20.

[35] Ibid.

[36] Op. cit., Radford and Buschschlüter at Note 9.

[37] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[38] Op cit., Ferré-Sadurní and Marcius at Note 4.

[39] Sevil Omer, “Venezuela crisis: Facts, FAQs, and how to help.” World Vision. 27 December 2024, https://www.worldvision.org/disaster-relief-news-stories/venezuela-crisis-facts.

[40] Jeremy McDermott, “Venezuelan Military ‘Invades’ Notorious Prison.” InSight Crime. 20 September   2023, https://insightcrime.org/news/venezuelan-military-invades-notorious-prison/.

[41] Op cit., Keefe, 100 at Note 32.

[42] Op. cit., Rísquez at Note 24.

[43] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[44] Op. cit.. “Tren de Aragua” at Note 20.

[45] Op. cit., Rísquez at Note 24.

[46] Unidad Investigativa De Venezuela, “Tren de Aragua’s Criminal Portfolio: Adapt or Die,” InSight Crime, 4 October 2023, https://insightcrime.org/investigations/tren-de-aragua-criminal-portfolio-adapt-die/.

[47] Ibid.

[48] Ibid.

[49] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[50] Op. cit., Trotta and Del Pino at Note 7.

[51] Ibid.

[52] Op. cit., Rísquez at Note 24.

[53] Op. cit., “Tren de Aragua” at Note 20.

[54] Ibid.

[55] Op. cit., Rísquez at Note 24.

[56] Op. cit., Venezuela Investigative Unit at Note 1.

[57] Op. cit., Humire at Note 26.

[58] Joshua Goodman, “What is Tren de Aragua? The gang’s history, from Venezuela’s prisons to US soil.” Denver 7. 24 September 2024, https://www.denver7.com/news/front-range/aurora/what-is-tren-de-aragua-the-gangs-history-from-venezuelas-prisons-to-us-soil.

[59] Ibid.

[60] Op. cit., Humire at Note 26.

[61] Antonio Maria Delgado, “Venezuela wanted a dissident dead and hired Tren de Aragua gang to kill him, Chile says.” Miami Herald. 23 January 2025, https://www.miamiherald.com/news/nation-world/world/americas/venezuela/article299042200.html.

[62] Ibid.

[63] Regina Garcia Cano, “Nicolás Maduro sworn in for third term as Venezuelan president despite evidence of election loss.” PBS. 10 January 2025, https://www.pbs.org/newshour/world/nicolas-maduro-sworn-in-for-third-term-as-venezuelan-president-despite-evidence-of-election-loss.

[64] Op. cit., Delgado at Note 61.

[65] Michael Miklaucic and Moises Naim, “The Criminal State,” in Convergence: Illicit Networks in the Age of Globalization, eds. Michael Miklaucic and Jacqueline Brewer. Washington, DC: National Defense University Press, 2013, p. 162.

[66] Ibid, p. 154.

[67] Venezuela Investigative Unit, “Venezuela’s Cocaine Revolution.” InSight Crime. April 2022, p. 18, https://insightcrime.org/wp-content/uploads/2022/05/Venezuelas-Cocaine-Revolution-InSight-Crime-Apr-2022.pdf.

[68] Ibid.

[69] Walter Kemp, “Chapter Three: Crime and Governance,” in Crooked Kaleidoscope: Organized Crime in the Balkans. Geneva: The Global Initiative against Transnational Organized Crime (GI-TOC), June 2017, p. 16.

[70] Ibid.

[71] Op. cit., Goodman at Note 58.

[72] Robert Mandel, Dark Logic: Transnational Criminal Tactics and Global Security. Stanford: Stanford University Press, 2011, p. 43.

[73] Ray Sanchez and Rafael Romo, “Tren de Aragua, a gang started in a Venezuelan prison, becomes early target of Trump administration immigration raids.” CNN. 29 January 2025, https://www.cnn.com/2025/01/29/us/venezuela-tren-de-aragua-gang/index.html.

[74] Piotr Chlebowicz, “Organised Crime as a Political Influence Tool of the Russian Federation.” Internal Security. Vol. 13, no. 2, July-December 2021: p. 177.

[75] Op. cit., Rísquez at Note 24.

[76] Ibid.

[77] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[78] Ibid.

[79] Ibid.

[80] Op. cit., “Tren de Aragua” at Note 20.

[81] Ibid.

[82] Ibid.

[83] “Treasury Sanctions Tren de Aragua as a Transnational Criminal Organization.” US Department of Treasury. 11 July 2024, https://home.treasury.gov/news/press-releases/jy2459.

[84] Misha Glenny, “How Global Crime Networks Grow.”, TED (video), 10:20 minutes. July 2009: https://www.ted.com/talks/misha_glenny_the_real_story_of_mcmafia_how_global_crime_networks_work/
transcript.

[85] Jan Van Dijk and Toine Spapens, “Transnational Organized Crime Networks Across the World,” in Jay Albanese and Philip Reichel, Eds., Transnational Organized Crime: An Overview of Six Continents. Thousand Oaks: Sage Publications, 2014, p. 214.

[86] Ibid.

[87] Ibid.

[88] Charles Larratt-Smith and John Polga-Hecimovich, “How Much of a Threat is Tren de Aragua in the U.S.?” Americas Quarterly. 9 December 2024, https://americasquarterly.org/article/how-much-of-a-threat-is-tren-de-aragua-in-the-u-s/.

[89] Op. cit., Mandel, pp. 21–22 at Note 72.

[90] Chris Dalby, “Core, Franchises and Copycats – The Triple Threat Posed by Tren de Aragua.” Seasons of Crime. 22 May 2025, https://www.seasonsofcrime.com/p/core-franchises-and-copycats-the.

[91] Ibid.

[92] Ibid.

[93] Ibid.

[94] Op. cit., “Tren de Aragua” at Note 20.

[95] Op. cit., “Treasury Sanctions Tren de Aragua as a Transnational Criminal Organization” at Note 83.

[96] Executive Order No. 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” Federal Register, Vol. 90, no. 14, 20 January   2025: p. 8439, https://www.federalregister.gov/documents/2025/01/29/2025-02004/designating-cartels-and-other-organizations-as-foreign-terrorist-organizations-and-specially.

[97] Ted Hesson, “US declares Tren de Aragua, other cartels are global terrorist organizations.” Reuters. 20 February 2025, https://www.reuters.com/world/us-declares-tren-de-aragua-other-cartels-are-global-terrorist-organizations-2025-02-19/.

[98] Office of the Spokesperson, “Designation of International Cartels.” US Department of State. 20 February 2025, https://www.state.gov/designation-of-international-cartels/.

[99] Transnational Organized Crime Rewards Program, “Reward for Information: Hector Rusthenford Guerrero Flores, a/k/a ‘Niño Guerrero.’” US Department of State. 11 July 2024, https://www.state.gov/reward-for-information-hector-rusthenford-guerrero-flores.

[100] “ICE HSI San Antonio and our law enforcement partners arrest a Tren de Aragua gang member during enforcement action.” US Immigration and Customs Enforcement. 11 February 2025, https://www.ice.gov/news/releases/ice-hsi-san-antonio-and-our-law-enforcement-partners-arrest-tren-de-aragua-gang.

[101] “High-Ranking Tren de Aragua Member in Custody on Terrorism and International Drug Distribution Charges.” US Department of Justice. 23 April 2025, https://www.justice.gov/opa/pr/high-ranking-tren-de-aragua-member-custody-terrorism-and-international-drug-distribution.

[102] Executive Order 13692, “Imposing Tariffs on Countries Importing Venezuelan Oil.” The White House. 24 March 2025, https://www.whitehouse.gov/presidential-actions/2025/03/imposing-tariffs-on-countries-importing-venezuelan-oil/.

[103] Op. cit., Venezuela Investigative Unit at Note 1.

[104] Ibid.

[105] INTERPOL Washington, “INTERPOL Washington and Canada Sign Historic Partnership to Combat Tren de Aragua.” US Department of Justice. 13 February 2025, https://www.justice.gov/interpol-washington/pr/interpol-washington-and-canada-sign-historic-partnership-combat-tren-de.

[106] Op. cit., Mandel, p. 34 at Note 72.

[107] Ibid, p. 35.

[108] Ibid.

[109] Op cit., Van Dijk and Spapens, p. 224 at Note 85.

[110] Op. cit., “Tren de Aragua” at Note 20.

[111] Ibid.

[112] Op. cit., “Héctor Rusthenford Guerrero Flores, alias ‘Niño Guerrero’” at Note 15.

[113] Ibid.