It seems that Panama has said that it has completed the process of cancelling and annulling all metal mining concessions. In November , tit enacted Law 407, a mining moratorium in response to protests.
27 APRIL 2024
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On 25 April, the UN advised that SANAULLAH GHAFARI (who has several aliases) had been removed from its sanctions lists.
https://press.un.org/en/2024/sc15682.doc.htm
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On 26 April, OFAC advised that ICE PEARL NAVIGATION CORP and YASA GOLDEN BOSPHORUS had been removed from the SDN List.
https://ofac.treasury.gov/recent-actions/20240426
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Forced into a night out last night, due to a lengthy power cut, affecting just our block, after a day marked by lunch at a cat cafe – funny day…
26 APRIL 2024
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On 26 April, the Home Office reported that that greater powers for the National Crime Agency and police to seize, freeze and destroy cryptoassets used by criminals have come into force.
https://www.gov.uk/government/news/new-powers-to-seize-cryptoassets-used-by-criminals-go-live
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The Terrorgram collective is an entirely online network of Extreme-Right Wing terrorists which produces and disseminates violent propaganda with the aim of radicalising readers and encouraging them to commit acts of terrorism. It is a criminal offence for a person to belong to, or invite support for, a proscribed organisation. It is also a criminal offence to arrange a meeting to support a proscribed organisation; or to wear clothing or carry articles in public which rouse reasonable suspicion that an individual is a member or supporter of a proscribed organisation.
https://www.legislation.gov.uk/uksi/2024/569/contents/made
https://www.gov.uk/government/news/terrorgram-collective-now-proscribed-as-terrorist-organisation
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On 25 April, K2 Integrity published this brief explaining that the US had reversed its 2023 relaxation of certain sanctions against Venezuela in response to failures by representatives of Venezuela President Nicolás Maduro to uphold commitments outlined in a roadmap for democratic elections in the country.
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A Panamanian called Reynaldo Pérez Palacio, who was allegedly the head of a drug trafficking network that sent cocaine to the US and Europe, has been captured in Bogota, in what was said to be a joint operation with Panamanian authorities.
Meanwhile, drama back in my former home, the Isle of Man, with the licence for 2 Asia-facing gambling companies suspended, and a related TCSP involved in virtual currency told to end all its designated business. This amidst a reported criminal investigation, and claims on social media of arrests made by armed police (though, as usual, local media has little detail…). Links to what is available in the newsletter attached below.
25 APRIL 2024
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On 24 April, the FCA consulted on proposed changes in relation to sanctions, proliferation financing and transaction monitoring. It is proposing to add references to cryptoassets and the Consumer Duty, along with consequential changes throughout the Financial Crime Guide. The consultation closes on 27 June.
https://www.fca.org.uk/publications/consultation-papers/cp24-9-financial-crime-guide-updates
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On 25 April, a Notice from HM Treasury advised that the individuals and entries linked to the defence sector had been added to sanctions lists.
https://assets.publishing.service.gov.uk/media/662a48a8690acb1c0ba7e60e/Notice_Iran_250424.pdf
https://www.gov.im/news/2024/apr/25/financial-sanctions-iran
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On 25 April, OFAC advised that it was sanctioning over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale of Iranian unmanned aerial vehicles (UAV) for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which itself is involved in supporting Iran’s Islamic Revolutionary Guard Corps (IRGC) and Russia’s war in Ukraine.
https://home.treasury.gov/news/press-releases/jy2295
https://ofac.treasury.gov/recent-actions/20240425
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The just-issued US State Department report on human rights worldwide includes the following summary for Panama –
Significant human rights issues included credible reports of: serious government corruption; regulations prohibiting consensual same-sex sexual conduct between adults in some security forces; and crimes involving violence targeting lesbian, gay, bisexual, transgender, queer, or intersex persons. The government did not always take credible steps to identify and punish officials who may have committed human rights abuses.
https://www.state.gov/reports/2023-country-reports-on-human-rights-practices/panama
I now have a t-shirt and baseball cap for one Presidential candidate, and a baseball cap for another, as people continue handing out such things. Not sure how they might make you want to vote for the candidate, if that wasn’t already your intention – but the t-shirts are nice and of good quality. At least in Cologne during election time years ago there was beer and sausages on offer…
24 APRIL 2024
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On 24 April, the Home Office published preliminary findings of a review set up to consider the challenges of investigating and prosecuting fraud cases and the operation of the disclosure regime in a digital age. The recommendations and final report are scheduled to be submitted to the Home Secretary in the Summer.
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On 23 April, La Prensa in Panama reported that the EU Parliament rejected by 490 votes in favour, 64 against and 56 abstentions the update of the list proposed by the EU Commission, which also asked to include Namibia and Kenya in this register, so that it cannot enter into force and the Commission will have to make a new proposal.
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On 23 April, OFAC advised that it had sanctioned 2 leaders of al-Qaida-aligned terrorist group Jama’at Nusrat al-Islam wal-Muslimin (JNIM) for hostage-taking of US persons in West Africa.
https://ofac.treasury.gov/recent-actions/20240423
https://home.treasury.gov/news/press-releases/jy2293
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On 23 April, OFAC advised that it had sanctioned 2 companies and 4 individuals involved in malicious cyber activity on behalf of the Iranian Islamic Revolutionary Guard Corps Cyber Electronic Command (IRGC-CEC). These actors targeted more than a dozen US companies and government entities through cyber operations, including spear phishing and malware attacks.
In conjunction with today’s action, the DoJ and FBI are unsealing an indictment against the 4 individuals for their roles in cyber activity targeting US entities.
https://ofac.treasury.gov/recent-actions/20240423
https://home.treasury.gov/news/press-releases/jy2292
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On 9 April, the Governmental Accountability Office reported that, to register civil aircraft with the FAA, applicants can provide opaque information on beneficial owners resulting in criminal and national security risks through aircraft registry fraud and abuse. Additionally, FAA generally relies on self-certification of registrants’ eligibility and does not verify key information. In March 2020, GAO made 15 recommendations to FAA. As of April 2024, FAA addressed 3 recommendations but needs to take additional actions to implement the remaining 12.
https://www.gao.gov/products/gao-24-107495
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EU Regulation 2024/1205/EU amended existing Regulations to remove certain provisions relating to UN measures, and amends the existing exemption to asset freeze measures for certain humanitarian actors, expanding the scope of the exemption to cover additional actors and replacing the related derogation.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401205
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401204
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It appears that, in 3years, the Ministry of Security Task Force against Money Laundering and Corruption has seized over $14 million from organised crime. In 26 operations, 192 people were detained. The pecial unit is made up of the Money Laundering Division of the Judicial Investigation Directorate, the General Directorate of Revenue, the Financial Analysis Unit, the Public Ministry and the Superintendency of Banks of Panama (SBP), with the support of the FBI Federal Investigation Agency; and the headquarters is in Amador.
Panama Customs is trialling digital cash declarations for travellers entering the country. Currently, each traveller must complete a paper form, and declare any cash of over $10,000.
22 APRIL 2024
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On 22 April, the Global Sanctions blog reported that the EU had amended its FAQ concerned with –
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La Estrella de Panama sums up the election (and perhaps all elections) with the following cartoon. The clown is saying, in effect, “once upon a time“…
21 APRIL 2024
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The Spring 2024 edition of the Bulletin of The International Academy of Financial Crime Litigators included this article.
https://edit.financialcrimelitigators.org/api/assets/ecf0bb58-2c32-4239-a6c8-83417ad9278d.pdf
We are told today that, so far this year, the authorities at Tocumen International airport have seized various types of illegal goods, including gold bars, drugs on dolls and macaw eggs. Detentions included 240 macaw eggs and 4 persons on INTERPOL or other warrants.
Attended a model show at Panama City’s only (and, so far as I know, Panama’s only model shop) with an array of excellent and interesting exhibits, including a model of the huge I-400 aircraft-carrying submarine that the Japanese intended using to attack the Panama Canal.
20 APRIL 2024
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Well, I think the rainy season is here, after being caught inan absolute deluge today, ending up with hands looking like I’d been wallowing in a bath for hours…
19 APRIL 2024
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On 19 April, OFAC advised that TIANJIN CREATIVE SOURCE INTERNATIONAL TRADE CO LTD and XI’AN LONGDE TECHNOLOGY DEVELOPMENT COMPANY LIMITED had been added to sanctions lists, and the entry for the MINSK WHEEL TRACTOR PLANT in Belarus had its entry amended.
https://ofac.treasury.gov/recent-actions/20240419
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On 19 April, OFAC announced that it had imposed sanctions on 2 entities – Mount Hebron Fund and Shlom Asiraich – for their roles in establishing fundraising campaigns on behalf of Yinon Levi and David Chai Chasdai, 2 violent extremists who were themselves sanctioned on 1 February in connection with violence in the West Bank. Ben-Zion GOPSTEIN was also added to sanctions lists.
https://home.treasury.gov/news/press-releases/jy2281
https://ofac.treasury.gov/recent-actions/20240419
https://www.state.gov/designations-related-to-destabilizing-activities-affecting-the-west-bank
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On 10 April, the University of Oxford announced the first-ever ‘World Cybercrime Index’, which identifies the globe’s key cybercrime hotspots by ranking the most significant sources of cybercrime at a national level. The World Cybercrime Index has been developed as a partnership between the University of Oxford and UNSW and has also been funded by CRIMGOV, an EU-supported project based at the University of Oxford and Sciences Po.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0297312
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On 11 April, a report from Transparency International contains warnings about the use of offsets – financial sweeteners added to overseas arms sales in addition to the military hardware the country receives.
https://ti-defence.org/blissfully-blind-security-risks-defence-contract-offset
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Bubbling along in the background, Covid-19 is still present. Up until 13 April, another 28 new cases, no new fatalities, and currently 53 active cases (up from 30 the week before), with 1 person in ICU and 21 in other wards.
18 APRIL 2024
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On 18 April, the EU announced that the FAQ had been updated, and a new consolidated version issued.
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On 18 April, Silko Compliance Systems published a recording, and the Powerpoint slides, from a recent webinar which provided an update on the changes in the FATF’s Fifth Round Mutual Evaluation Reviews methodology and what private industry can expect because of these changes. The webinar involved Elisabeth Lees from Claritas Legal in the Cayman Islands.
https://silocompliance.com/aml-grey-matters-fatf-5th-round-what-has-changed-with-elisabeth-lees
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On 18 April, the Isle of Man advised that 7 individuals and 6 entities had been added to the sanctions lists, as HM Treasury issued a Notice contained the same names.
https://www.gov.im/media/1383458/annex-to-iran-sanctions-news-release-18-april-2024.pdf
https://globalsanctions.co.uk/2024/04/uk-and-us-iran-related-designations-following-israel-attack/ https://assets.publishing.service.gov.uk/media/6620f46b651136bd0b757d96/Notice_Iran_180424.pdf
On 17 April, the Wall Street Journal reported that the Biden administration says licences will be evaluated on a case-by-case basis, as it said it would allow some US and European oil companies to carry on in Venezuela after US efforts to coax President Nicolás Maduro into democratic overhauls by lifting economic sanctions ended.
https://globalsanctions.co.uk/2024/04/us-reimposes-sanctions-on-venezuelan-oil
On 18 April, OFAC advised of amendments to 2 existing entries, involving GTS GRUPP and Georgii Semenovich POGIBLOV.
https://ofac.treasury.gov/recent-actions/20240418
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On 18 April, OFAC advised that it was targeting 16 individuals and 2 entities enabling Iran’s UAV production, including engine types that power Iran’s Shahed variant UAV. These actors work on behalf of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), its UAV production arm, Kimia Part Sivan Company (KIPAS), and other Iranian manufacturers of UAVs and UAV engines. OFAC is also designating 5 companies in multiple jurisdictions providing component materials for steel production to Iran’s Khuzestan Steel Company (KSC), one of Iran’s largest steel producers, or purchasing KSC’s finished steel products. OFAC is also sanctioning 3 subsidiaries of Iranian automaker Bahman Group, which have continued to materially support the IRGC and other entities designated pursuant to counterterrorism authorities, including Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Bahman Group itself is being concurrently designated for owning these entities.
It notes that the UK was also imposing sanctions targeting several Iranian military organizations, individuals and entities involved in Iran’s UAV and ballistic missile industries.
https://home.treasury.gov/news/press-releases/jy2270
https://ofac.treasury.gov/recent-actions/20240418
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On 18 April, FinCEN advised that it has updated its Beneficial Ownership Information FAQ to include new questions and updated information about reporting companies, beneficial ownership through trusts, and access to beneficial ownership information, among other topics.
On 18 April, FinCEN issued a Financial Trend Analysis focusing on patterns and trends identified in Bank Secrecy Act (BSA) data linked to Elder Financial Exploitation (EFE), or the illegal or improper use of an older adult’s funds, property, or assets. It found 155,415 filings over the period between 15 June 2022 and 15 June 2023 indicating roughly $27 billion in EFE-related suspicious activity.
https://www.fincen.gov/news/news-releases/fincen-issues-analysis-elder-financial-exploitation
https://www.fincen.gov/sites/default/files/shared/FTA_Elder_Financial_Exploitation_508Final.pdf
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On 17 April, the Global Sanctions blog reported that a (non-binding) Opinion from the Attorney General has said that in his view the authentication and execution of a contract of sale by a notary and the translation of communications between the notary and the seller and purchaser are not prohibited by the prohibition on legal advisory services – notwithstanding what EU FAQ say. It remains to be seen if the court follows the advice.
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It seems that the current frontrunner in the Panama Presidential elections, José Raul Mulino (who took the place of convicted ex-President Martinelli, and inherited much of his lead in the polls) has apparently vowed to block US-bound migrants from crossing the lawless Dariénjungle straddling the country’s border with Colombia and to begin deportations..
17 APRIL 2024
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On 17 April, OFAC advised that it had issued General License 44 (Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in Venezuela) as well as an updated version of FAQ related to the suspension of certain US sanctions with respect to Venezuela on 18 October 2023.
https://ofac.treasury.gov/media/932826/download?inline
https://ofac.treasury.gov/media/932821/download?inline
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On 17 April, the Transnational Alliance to Combat Illicit Trade published this report which identifies the scale of trade of illicit pesticides on e-commerce platforms and the vulnerabilities that expose platforms to illicit traders. The primary objective of the report is to examine the structural vulnerabilities in the operations of e-commerce platforms that can be exploited by criminals to sell illicit pesticides online. It goes on to present examples of listings of illicit pesticides found on major ecommerce platforms worldwide. It found that major e-commerce platforms worldwide sell illicit pesticides, in circumvention of national regulatory controls.
https://www.tracit.org/tackling-the-sale-of-illicit-pesticides-on-e-commerce-platforms.html
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On 17 April, ICIJ released information about the tiny southern African kingdom of Eswatini — once known as Swaziland. It says that a leak from inside the Eswatini FIU reveals how the king’s broken promises and his inner circle have enabled suspicious money to flow through the landlocked country and beyond. One thing highlighted is how a “special economic zone” — touted as a way to repair the country’s tattered economy — became a ghost town home to 2 “phantom” gold refineries channelling millions of dollars to Dubai.
https://www.icij.org/investigations/swazi-secrets
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The Panama Canal will increase transits to 32 daily from 1 June , based on rain projections that suggest that the level of Gatun Lake, the largest of the two reservoirs managed by the Panama Canal, will recover.
One of the things that surprises people like me from bigger, richer and allegedly more advanced countries is some of the things that Panama does for its older people. For example, the jubilado discount scheme for pensioners (and the pension age thresholds are much lower here, and the jubilado thresholds even lower) applies to a whole range of things – including shops, cafes and restaurants, new cars, entry tickets, utility bills, and travel costs. Today, for example, we were able to claim a 25% discount of airline tickets to Mexico later this year.
The past and the future? One of reducing number of diablos rojos (colourful and noisy former US school buses), already replaced in the city by air-conditioned Volvos. Then one of the new gas-powered “green” buses – very airy and a delight to travel on.
16 APRIL 2024
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On 16 April, a Notice from HM Treasury advised that, following notification from the UN, the existing entry for the NATIONAL AEROSPACE TECHNOLOGY ADMINSTRATION had been amended.
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On 15 April, the UN advised that the existing entry for NATIONAL AEROSPACE TECHNOLOGY ADMINISTRATION had been amended.
https://press.un.org/en/2024/sc15664.doc.htm
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Logisticcs trade publication Freightwaves has reported that the end of Panama’s dry season is in sight, and the Panama Canal Authority (ACP) plans to welcome more vessels in the coming weeks. It also says that the US National Weather Services’ Climate Prediction Center is forecasting a swift end to El Niño conditions in the coming months.
Meanwhile, the election campaign trundles on. As a non-voter, the biggest impact on me personally are the occasional noisy parade-cum-demonstration nearby (leading us to eat out more), and the odd vehicle with loudspeakers broadcasting local candidates’ manifesto pledges… My wife, a Panamanian, is more involved, and has just received her training as an election observer on 5 May – with a long day predicted, having to be on site before 6 am, and not expected to be home until the evening.
One of the nice things about Panama is the precence of wildlife (much more exotic than back in Britain), even in the city (with even large crocodiles venturing into the city centre). The other day I came across this Jesus lizard (photo below), holding up the traffic, as he was determined to cross the road.
15 APRIL 2024
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The Estonian FIU has issued an English version of its report on 2023, a year that included a MONEYVAL report on Estonia. One of the points made is that the greatest threat to Estonia is the layering of foreign proceeds of crime through Estonia; also noting that fraud continues to be the most common predicate offence for money laundering.
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On 15 April, a news release from FinCEN advised that it had issued a Notice to financial institutions on fraud schemes related to the use of counterfeit US passport cards. The Notice provides an overview of typologies associated with U.S. passport card fraud, highlights select red flags to assist financial institutions in identifying and reporting suspicious activity, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.
https://www.fincen.gov/sites/default/files/shared/FinCEN_Notice_Counterfeit_US_Passport_FINAL508.pdf
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