Another Public Holiday today – in lieu of 28 November (independence from Spain) being a Sunday. Not a good day for Miss Panama, who reportedly tested positive for Covid-19 upon arrival in Israel for the Miss World contest.
Panama Covid-19 update – “only” 94 new cases reported today and no new fatalities, with the number of active cases falling by 225 to 2,468; with 22 in ICU and 90 in other wards,
29 NOVEMBER 2021
COMPANIES WHICH ENGAGE IN CROSS-BORDER CORRUPTION FROM SWITZERLAND CAN BE PROSECUTED DESPITE DIFFERENT SETTLEMENTS REACHED ABROAD ON VIRTUALLY THE SAME FACTS
On 25 November, LALIVE reported on a recent public statement from the Office of the Swiss Federal Attorney General re a case where a Swiss company failed to take all adequate and necessary internal organisational measures to prevent the bribery of public officials in Angola, Equatorial Guinea and Nigeria.
PROPOSALS FOR SANCTIONS AGAINST TRANSPORT OPERATORS THAT FACILITATE OR ENGAGE IN TRAFFICKING IN PERSONS OR SMUGGLING OF MIGRANTS IN RELATION TO ILLEGAL ENTRY INTO EU
On 23 November, the EU published a proposed EU Regulation that would allow the imposition of measures such as airport and port bans, bans on refuelling, withdrawal of licence etc.
INDUSTRY MISMANAGEMENT SWEETENING THE ILLICIT DEALS FOR SUGAR SMUGGLERS IN KENYA
On 29 November, Daily Maverick reported that the collapse of the country’s once-booming sector has created a thriving illegal cross-border trade. It says that high production costs and the mismanagement of factories have led to a drop in sugar production in Kenya over the past 2 decades, opening the door for smuggling from Uganda. In 2020, sugar made up 48% of the goods smuggled into the country, according to the National Crime Research Centre.
AUSTRALIA: LIVE EXPORT COMPANY EMANUEL EXPORTS’ LICENCE RENEWED AFTER 3-YEAR BAN
On 29 November, MSN and others reported that Australia’s largest live sheep exporter has had its licence reinstated after a 3-year suspension, when the company’s licence was cancelled after an investigation into the death of 2,400 sheep on a sailing to the Middle East.
RUSSIAN MERCENARIES USING EU-TRAINED SOLDIERS IN AFRICA
On 29 November, EU Observer reported that Russian mercenaries have taken command of at least one EU-trained battalion in the Central African Republic (CAR). This comes after MEP having urged the EU to blacklist members of Russia’s mercenary Wagner Group, while listing its crimes in multiple conflict zones.
THE DARK WORLD OF SELLING FUNERAL POLICIES IN SOUTH AFRICA
On 28 December, Daily Maverick reported that a financial services provider offering funeral insurance cover and legal assistance to low-income earners, has accused its underwriter of attempted bribery, delaying payments to claimants and of flouting the sectors codes of practice.
LIQUIDATORS OF WIRECARD’S IRISH ARM FOCUS FRAUD INVESTIGATION ON 4 KEY AREAS
On 29 November, the Irish Times reported that liquidators are focusing their investigation into an almost €400 million fraud on 4 key areas. It is also said that they continue to pursue a possible €43 million corporation tax refund from the Revenue Commissioners, as its reported income in the past had been allegedly overstated, and €70 million owed by debtors.
KYRGYZSTAN: STATE COMMITTEE FOR NATIONAL SECURITY OF KYRGYZSTAN (SCNS) ALLEGES BANK ILLEGALLY ISSUED LOANS TO COMPANIES
On 29 November, 24KG reported that SCNS is said to have checked corruption manifestations in various spheres of activity of Aiyl Bank OJSC. The loans were intended for socially vulnerable groups of the population, as well as for the development of agriculture and animal husbandry.
NETHERLANDS: UP TO 250,000 NAMES WERE ON TAX OFFICE’S FRAUD ‘BLACK LIST’
On 29 November, Dutch News reported that up to 250,000 people may have had their names added to the Dutch tax office’s secret ‘black list’ of suspected fraudsters that left thousands in financial difficulty. Many people had their benefits suspended even though there was no evidence they were committing fraud, and the fraud detection system quickly became so large and unwieldy that suspected cases were treated as proven cases, often with drastic consequences.
COUNTERFEIT MEDICAL DEVICES: ON THE RISE DURING COVID-19?
On 29 November, the Medical Device Network reported that, while counterfeiting has long been an issue in the pharma supply chain, the impact of fake medical devices is less well known. It refers to seizes of counterfeit medical devices, saying such counterfeits covers everything from tweezers to ventilators.
CONVICTED HUMAN TRAFFICKER TO BE REMOVED FROM UK FOR THIRD TIME
A news release from the NCA on 28 November advised that NCA officers located Albanian Hazir Lala, 39, in North London. In April 2016, he was convicted in the UK of drunk driving, driving without insurance and possession and control of false ID documents. In September 2019, he was again arrested for organised immigration crime offences which had been committed in Belgium later in 2016, and he was convicted in his absence in February 2018. He was arrested again under the Immigration Act 1971 in 2020for overstaying and he was deported to Albania on 19 August 2020.
NEW REPORT ESTIMATES THERE ARE 35 MILLION “MISSING ENTREPRENEURS” ACROSS THE OECD AREA
A news release from the OECD on 29 November says a new report demonstrates that young people, women and seniors have fewer opportunities to transform their business ideas into reality. The OECD/EU report shows there could be an additional 9 million people starting and managing new business in the EU – and 35 million across OECD countries – if everyone was as active in business creation as 30-49 year-old men.
12 ONLINE FRAUDSTERS ARRESTED IN GLOBAL OPERATION AGAINST COUNTERFEITERS
A news release from Europol on 29 November advised that, from 1 May until 14 November, Operation In Our Sites took place involving 30 countries and leading to the arrest of 12 suspects, the seizure of €2.6 million worth of counterfeit goods and cash to the value of €460,468. It also reported that another operation, Carding Action 2021, an operation led by law enforcement agencies from Italy and supported by the UK and Europol, targeted fraudsters selling and purchasing compromised card details on websites selling stolen credit card data, known as card shops, and dark web marketplaces. 12 vendors selling compromised credit card details were identified.
On 29 November, Times Now News reported that with the import of phones attracts custom duty of 44%, smuggling for high-end phones is on rise. The Directorate of Revenue Intelligence (DRI) said that in the largest seizure of iPhones in recent times, it had uncovered 2,245 iPhone 13 Pro and 1,401 iPhone 13 Pro Max.
NURDLES: THE WORST TOXIC WASTE YOU’VE PROBABLY NEVER HEARD OF
On 29 November, the Guardian reported on the problem of the tiny plastic pellets floating in the ocean, causing as much damage as oil spills, they are still not classified as hazardous.
UK: 2 DIRECTORS BANNED FOR A TOTAL OF 22 YEARS OVER ‘ETHICAL WATER’ INVESTMENT SCAM
A news release from the Insolvency Service on 26 November advised that the 2 men were directors of Global Water Group Ltd which claimed to sell ethically-based investment bonds to support water projects around the world. It secured at least £800,000 from investors between 2017 and 2020, but when it was put into liquidation in May 2020, the liquidator was unable to identify a single genuine investment.
KUWAIT ISSUES FINAL VERDICT IN CASE OF FORMER BANGLADESHI MP
On 29 November, Asharq Al-Aswat reported that the Kuwaiti Court of Cassation has sentenced a former Bangladeshi lawmaker, arrested in June 2020, to 7 years in prison for human trafficking and money laundering. It also handed down similar jail terms to 2 Kuwaiti Interior Ministry officials and ordered their sacking from their government posts on charges of bribery in the same case. It sentenced ex-Kuwaiti parliamentarian Salah Khurshed to 7 years in prison and ordered him to pay a fine, but also upheld the acquittal of Kuwaiti MP, Saadoun Hammad.
INTRA-EU REQUESTS FOR BENEFICIAL OWNERSHIP INFORMATION MUST SHOW ‘CLEAR AND SUFFICIENT EXPLANATION’
On 29 November, STEP reported that a preliminary judgment by the Court of Justice of the European Union (CJEU) has set out some conditions that must be satisfied when a EU Member State requests cross-border tax cooperation from another when the targeted persons are not identified individually by name. The case concerned a request for information sent by the French tax authority to Luxembourg in April 2017. The conditions included that the requesting authority must provide a clear and sufficient explanation that it is conducting a targeted investigation into a limited group of persons, justified by reasonable suspicions of non-compliance with a specific legal obligation.
THE FAR-RIGHT FRENCH NGO ALLEGEDLY SUPPORTING WAR CRIMES IN SYRIA
On 29 November, the Newslines Institute published a report claiming that SOS Chrétiens d’Orient (SOSCO, or SOS) allegedly provided moral and material support to pro-Assad militias accused of committing war crimes.
WCO PUBLISHES 2022 EDITION OF HARMONIZED SYSTEM NOMENCLATURE
On 29 November, KPMG reported that the World Customs Organisation (WCO) had published the new Harmonized System Nomenclature for 2022, to be followed by the approximately 200 customs authorities worldwide with effect from 1 February. KPMG observes that the changes affect over 1,500 HS codes, most of them in Chapters 84 and 85, relating to different types of machinery and their parts. Moreover, new technologies such as smartphones, vapes, and drones received specific subheadings in the updated list.
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On 29 November, iGB reported that the trade body was backing a new EU Anti-Money Laundering Authority (AMLA) established as a centralised body coordinating AML and FIU across all Member States.
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Panama Covid-19 update – Independence Day (from Spain in 1821), with tomorrow also a Public Holiday…
Menawhile, as one waits with bated breath to see what effects the new Omnicron variant will have and when (or if) it is discovered here, the number of active cases has risen again, by 33 to 2,693 (possible the after-effects of the holiday week at the start of the month?), with 208 new cases and 1 new fatality reported today. There are 21 patients in ICU and 97 in other wards.
28 NOVEMBER 2021
MACAU ARRESTS 11 PEOPLE FOR ALLEGED ILLEGAL GAMBLING AND MONEY LAUNDERING
On 28 November, Saltwire in Canada reported that Macau police have arrested 11 people in an investigation into an illegal gambling and money laundering syndicate. Other sources allege that one of the arrested is Macau’s best-known junket mogul, Alvin Chau Cheok Wa – the founder and CEO of Suncity, one of Macao’s major casino junket operators.
CROATIA’S SOCCER SUPERSTAR, THE FORMER BOSS … AND A SPORT DOGGED BY SCANDAL
On 28 November, The Observer carried an article featuring corruption allegations and Zdravko Mamić, once the most powerful figure in Croatian football, who fled to Bosnia-Herzogovina on the eve of his conviction for fraud 3 years ago.
On 27 November, Politico reported that the premier of the BVI is pushing back against allegations of deep-seated corruption in the Caribbean territory even before an official inquiry has finished its work – with a report expected in January. It began after ex-BVI Governor Augustus Jaspert went public with accusations ranging from mismanagement and graft to organized crime and cocaine trafficking with the participation of senior officials.
INTERPOL HAS ELECTED A TOP CHINESE PUBLIC SECURITY OFFICIAL TO ITS EXECUTIVE COMMITTEE IN THE FACE OF WIDESPREAD CRITICISM
On 26 November, RFA reported that Interpol had elected ministry of public security official Hu Binchen serve for a 4-year term on the committee, although the Chinese Communist Party (CCP) has been known to abuse the Interpol “red notice” arrest warrant system to track down peaceful critics of the regime.
8 PEOPLE CHARGED AFTER PROBE INTO CORRUPTION AROUND SCOTTISH NHS CONTRACTS WORTH MILLIONS
On 27 November, the Daily Record reported that a major investigation into corruption around multimillion-pound NHS contracts in Scotland has resulted in 8 people – including senior health board figures – being charged. Former IT and communications chiefs and Irvine-based telecoms company Oricom are said to be involved.
AUSTRALIA: COMPANY WORTH JUST $8 WHEN AWARDED $385 MILLION NAURU OFFSHORE PROCESSING CONTRACT
On 25 November, the Guardian reported that a Brisbane construction company had only $8 in assets and had not started trading when it was awarded a government contract – ultimately worth $1.6 billion – to run Australia’s offshore migrant processing on Nauru. It has been revealed that while KPMG undertook a pre-contract assessment of Canstruct International Pty Ltd, the government has since confirmed the assessment was actually undertaken on another company, Canstruct Pty Ltd.
AUSTRALIA: $1 BILLION AND COUNTING – POKER MACHINE CRIME
On 28 November, an article from The Age said that state and federal authorities have evidence New South Wales’ 95,000 poker machines are being used as laundering machines for illicit cash that is “easily in the hundreds of millions” of dollars, with allegations that, nationwide, more than $1 billion from the proceeds of crime is likely being cleansed through pubs and clubs with gaming machines. It reports on a syndicate effectively commandeering the pokies venue to launder tens of thousands of dollars, with a large number of people apparently involved in the co-ordinated scheme. It also says that, since January 2018, only 5.5% of NSW venues with electronic gaming machines have submitted a STR to money laundering agency Austrac, despite evidence and intelligence suggesting the problem involves many more venues.
1 IN 6 VLCC HAS CARRIED IRANIAN OR VENEZUELAN OIL OVER THE PAST 2 YEARS
On 26 November, Insurance Marine News reported that, of the 853 very large crude carriers (VLCC) currently afloat, 141 have been involved in Iranian and/or Venezuelan oil trades during the past 2 years. It also said that many ageing tankers had moved into sanctioned Iranian and/or Venezuelan trade during the pandemic.
HONDURANS VOTES FOR NEW PRESIDENT, AS CURRENT ONE FACES EXTRADITION
On 28 November, The Week reported that the election could remove the governing National Party from office for the first time since it took power in a 2009 military coup. The leader in the polls is the wife of the man ousted in 2009, the National party candidate has been hit by allegations of embezzlement whilst a major, and the third candidate only returned to the country in 2020 after serving a jail sentence in the US for money laundering. Current President Juan Orlando Hernández has been accused by US prosecutors of funding his campaigns with drug money and could be extradited to the US if his party loses power.
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Panama Covid-19 update – as Europe (and the US) worries over the new Covid variant; the number of active cases here has fallen by 4 to 2,660, with 210 new cases and 1 new fatality reported today. 23 patients are in ICU and 93 in other wards.
27 NOVEMBER 2021
ROTTERDAM AND THE COCAINE CONNECTION
A BBC Radio documentary about drugs smuggling through the port of Rotterdam, saying that European North Sea coast has overtaken Spain as the primary entry point for South American cocaine, bringing with it violence and corruption. With gangs of “collectors” (some of whom “living” in empty containers, sent to break into containers and recover the drugs. One such gang got stuck in their container and had to phone the police to be rescued!
6 PERSONS ARRESTED INCLUDING A DOCTOR FOR CODEINE SMUGGLING TO BANGLADESH
On 27 November, Devdiscourse reported raids in Barrackpore and arrest of 6 people, who are allegedly part of a syndicate involved in smuggling Codeine syrup, much preferred by drug addicts looking for a quick high, across the Indo-Bangladesh border. It involved Codeine-Based Cough Syrup (CBCS), aka `Lean’ and `Sizzurp’.
BREXIT: CERTAIN PRODUCTS OF ANIMAL ORIGIN CAN CONTINUE TO BE IMPORTED FROM THE EU FROM 1 JANUARY TO 30 JUNE
BIFA reported that the UK Border Operating Model has confirmed that the grace period for Prohibitions and Restrictions (P&Rs) on certain Products of Animal Origin (POAO) imports will continue. Therefore, imports of chilled minced meat (beef, pork, lamb, mutton and goat); chilled and frozen minced poultry meat; mechanical separated meat from porcine, poultry and ratite or game birds; ungraded eggs; and chilled meat preparations can be imported, despite the implementation of much of the deferred customs controls from 1 January.
TURKEY DETAINS 27 TAIWANESE IN RAID ON ALLEGED FRAUDRING
On 27 November, the Taiwan News reported that Turkish police had detained 27 suspects from Taiwan in an operation to crack down on alleged fraud in the resort town of Bodrum. This is said to be in connection with a network involved in people smuggling and online fraud. The Taiwanese had rented a villa in Bodrum.
eATA CARNET: NEW INITIATIVE TO HELP SMALL- AND MEDIUM-SIZED ATA CARNET ISSUING AND GUARANTEEING ASSOCIATIONS GO DIGITAL
The International Chamber of Commerce has announced that the ICC ATA Gateway project aims to develop an ATA Carnet light issuing module for ATA Chain members who do not have their own issuing tools. It is part of a plan to digitise the ATA Carnet (a sort of passport for temporary import of goods) and its procedures. With the support of the World Customs Organisation, ICC has already developed an ATA Carnet System, a centralised digital resource laying the cornerstone for the digitisation of the international customs document.
RUSSIA APPROVES RADICAL NEW ANTI-COUNTERFEITING PLANS
On 25 November, an article from Gowling WLG said that the Russian Federation’s Prime Minister has approved new measures to prevent the illicit trafficking of counterfeit goods, which will be effective until 2025, and which is expected to have a wide-ranging effect beyond Russia’s borders.
IRISH CHAPTER OF THE INTERNATIONAL COMPARATIVE LEGAL GUIDE TO GAMBLING 2022
On 25 November, Irish law firm McCann Fitzgerald published the chapter on the Irish gambling framework, including relevant authorities and legislation, application for a licence and licence restrictions.
US COAST GUARD’S COUNTER-MARITIME DRUG TRAFFICKING MISSION AND THE EXTRATERRITORIAL JURISDICTION
On 8 November, an article from the Center for International Maritime Security provided an overview of the US Coast Guard’s counter-maritime drug trafficking mission and analysed the extraterritorial jurisdiction created by the Maritime Drug Law Enforcement Act. A second part on 22 November discussed the prolonged detention of suspected smugglers aboard Coast Guard cutters and the interaction between intelligence gathering and the trial penalty during prosecution.
YORKSHIRE FRAUDSTER KNOWN AS ‘BRADFORD TONY’ ORDERED TO REPAY MORE THAN £1 MILLION FROM MONEY LAUNDERING SCHEME
On 26 November, the Yorkshire Post reported that Anthony Davey, 50, a resident in Filey, was ordered to repay the money under POCA 2002, which he obtained through various mortgage frauds and money laundering offences committed in West Yorkshire.
INSIDE THE MANHATTAN DA’S ANTIQUITIES TRAFFICKING UNIT
On 23 November, an article in The Atlantic looks at the work of the Unit and Matthew Bogdanos, the 64-year-old prosecutor and chief of the Antiquities Trafficking Unit. The only one of its kind in the world, his squad of prosecutors, criminal investigators, and art specialists polices the loftiest reaches of New York’s art market — a genteel club of museums, collectors, and auction houses that buy and sell the relics of ancient civilizations.
On 26 November, the Guardian reported that 2 ticket touts who made at least £11 million using websites such as StubHub and Viagogo to sell seats at gigs by artists including Ed Sheeran have had their appeals against a conviction for multiple counts of fraud dismissed. It is said to be a landmark verdict that could have significant ramifications for the practice of ticket touting. They had used “dishonest and fraudulent tactics” to purchase multiple tickets from primary ticket sellers such as Ticketmaster, Eventim and AXS, elbowing out genuine fans trying to buy tickets, then listing those tickets for sale to consumers at inflated prices.
MALTA: POLICE BUST LIBYAN TAX EVASION RACKET AT AIRPORT
On 27 November, the Times of Malta reported that a group of Libyan nationals suspected of illegally moving millions of euro through the airport are to be charged with money laundering and tax evasion. It is said to involve around a cluster of some 5 Malta-registered companies which the group controls.
FRAUD PROBE INTO BIRMINGHAM BUSINESSMAN WHO FLED TO PAKISTAN HALTED AFTER 15 YEARS
On 27 November, Birmingham Live reported that Nisar Afzal – accused of being a fraudster implicated in a £49 million mortgage scam – is no longer being pursued over the claims, marking a dramatic end to a 15-year pursuit. Arrest warrants and restraint orders against him have been cancelled at the request of the SFO.
On 25 November, KPMG reported that on 1 November, OFSI published an updated Charity Sector Guidance and a blog post in response to Afghanistan’s Taliban takeover in August.
On 24 November, KPMG reported that Ukraine had advised a new set of sanctions imposing restrictions including, among other things, asset freezes, restriction on the exit of capital from Ukraine, a ban on trade operations and the transit of resources, flights and transportation within the territory of Ukraine, and the suspension of the performance of economic and financial obligations, etc. Those targeted include entities in the shipbuilding sector in Crimea; airlines Camus Air, UM Air and Khors Air; a Russian supermarket chain now operating on (former) Ukraine territory; those involve in cyber attacks and elections to the Russian Duma from the occupied territories; and domain registry re.ru.
On 28 October, Ukraine had also imposed sanctions on a number of persons linked to the Houthi in Yemen.
A ONE-WAY RACHET: FATF REGULATION OF CRYPTOCURRENCY AND DECENTRALISED FINANCE
On 23 November, an article from King & Spalding explains that FATF has updated its 2019 “Guidance for a Risk-based Approach for Virtual Assets and Virtual Asset Service Providers”. The article identifies the key updates.
GLOBAL COMMODITY TRADERS ARE FUELLING LAND CONFLICTS IN BRAZIL’S CERRADO
On 23 November, Global Witness reported that traditional pastoralist communities have been sustainably managing land in Brazil’s Cerrado for centuries, but now powerful agricultural producers seek to forcibly evict them in order to continue growing environmentally damaging cash crops monocultures like soy and cotton. It says that its investigation reveals that global commodity traders ADM, Bunge and Cargill are dealing in conflict-tainted soy sourced from these producers, and in doing so are contributing to this land conflict and alleged human rights abuses, in violation of their responsibilities under UN and OECD human rights standards.
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On 24 November, the US Commerce Department’s Bureau of Industry and Security (BIS) has added 27 entities to the Entity List for illegally selling technology to China, North Korea and other sanctioned countries, for supporting China’s military modernisation efforts or for contributing to Pakistan’s nuclear and missile programmes. Included are 12 Chinese concerns.
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On 25 November, ENACT Africa produced a report which provides insight and analysis to enable law enforcement agencies in North and West Africa to devise appropriate responses to the threat. Trafficking in human beings for organ removal (THBOR) is driven largely by the global shortage in organs for ethical transplant.
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On 25 November, a proposal of the OECD Working Group on Bribery in International Business Transactions had been accepted and a Recommendation dating from 2009 had been amended. The Recommendation on combating bribery of foreign public officials in international business transactions is replaced. The new version seeks to update and expand upon the 2009 Anti-Bribery Recommendation with a view to further supporting the full implementation of the Anti-Bribery Convention by reflecting recent trends and challenges in the foreign bribery field, to ensure that it remains relevant and effective. New sections have been included on key topics that have emerged or significantly evolved in the anti-corruption area since 2009, in particular:
Addressing the Demand Side of Foreign Bribery Cases;
Sanctions and Confiscation;
Non-Trial Resolutions;
International Co-operation;
Protection of Reporting Persons;
Incentives for Compliance; and
Data Protection.
The draft revised Recommendation also updates or broadens the scope of provisions on pre-existing topics, including enforcement as well as awareness raising, training and guidance.
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A report from Conflict Armament Research contains a case study which looks at 6 different Russian-manufactured military unmanned aerial vehicles (UAV – commonly called ‘drones’) that CAR documented in Ukraine. CAR’s investigations found that the Russian military industry has been obtaining key components for these UAV – such as GPS modules, electronic parts, cameras, and engines – from the US, Asia, the Middle East, and EU, both before and after the start of the conflict in Ukraine in 2014, and despite an EU arms embargo on Russia.
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Athina 984 reported on 27 November that former Argentine President and current Vice-President Cristina Fernandes de Kirsner, as well as her 2 children, Florence and Maximo, have been acquitted of charges of corruption and money laundering involving the family real estate business.
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On 26 November, the Washington Post reported that an arbitration panel has ruled in favour of 2 Iranian banks in a financial dispute over the 2015 closing of a Bahraini financial institution accused of helping Iran skirt US and UN economic sanctions. A Hague-based tribunal ordered the government of Bahrain to pay more than $270 million in compensation for losses and legal fees stemming from its decision to close Future Bank. Future Bank was established in Bahrain in 2004 with the backing of Bank Melli and Bank Saderat, 2 of Iran’s largest financial institutions.
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Panama Covid-19 update – so far, Panama has not announced the same travel restrictions that have been introduced by the UK and EU. But then there are no direct, and few (I would have thought) indirect links – though there are South Africans living in the country.
Meanwhile, no new fatalities today and the number of active cases increased by only 1, to 2,664. However, there were 223 new cases reported, with increases in numbers in hospital – 25 in ICU and 105 in other wards.
26 NOVEMBER 2021
REMITTANCES HAVE CUSHIONED THE IMPACT OF COVID-19 IN POOR COUNTRIES
On 25 November, The Economist reported that, even though migration slowed in the past year, payments home surged.
US MANUFACTURERS RACE TO RELIEVE A PANDEMIC-TRIGGERED AMMUNIION SHORTAGE
In its 27 November edition, The Economist is reporting that 2 companies meet the bulk of US demand for ammunition, and chiefly through 2 long-established brands. Remington and Winchester Ammunition, and that soaring demand for guns and ammunition comes from a range of demographic groups.
PERU’S CHIEF OF STAFF STASHED $20,000 IN PALACE BATHROOM
On 26 November, the Panatimes reported that prosecutors in Peru have found $20,000 stashed in a bathroom inside the presidential palace after they raided the palace on Friday as part of an investigation into allegations of influence peddling. Bruno Pacheco, who has resigned, said that the stash was a combination of his savings and salary.
AFTER A YEAR OF SILENCE, ARE EU CYBER SANCTIONS DEAD?
On 26 October, an article on Lawfare posed this question, saying that a year ago the EU imposed its second, and so far last, cyber sanctions package in response to malicious cyber activities that constitute an external threat to the EU or its Member States. To date, only 8 individuals and 4 organisations have been sanctioned for various campaigns; whereas the US has listed including 13 individuals and 19 entities in 2021 alone.
COURT IMPOSES LIMITS ON THE EXTRATERRITORIAL REACH OF THE FCPA AND THE MONEY LAUNDERING CONTROL ACT
On 24 November, an article from Lowenstein & Sandler LLP said that the US District Court for the Southern District of Texas dismissed a 3-count indictment against Daisy Rafoi-Bleuler, a Swiss citizen residing in Zurich. The decision is said to demonstrate limits to the DoJ expansive interpretation of its own jurisdiction over foreign nationals in white collar criminal cases, and it raises the spectre of future due process constitutional challenges to prosecutions of so-called “agents” in corruption and money laundering cases.
WHAT TO DO WHEN THE NCA REFUSES YOUR APPLICATION FOR A DEFENCE AGAINST MONEY LAUNDERING (DAML)
On 25 November, an article from Jonathan Bray Ltd covers the situation when someone has submitted a DAML, answered further questions during the 7-day window, but then no more is heard – and the client is asking questions. What happens if you still hear nothing? It ends by saying that, whatever you do, make sure that you accurately record a detailed audit trail of your decision-making – warning that, if it isn’t recorded, it didn’t happen.
DO THE FCPA, UK BRIBERY ACT, FRENCH OR GERMAN CRIMINAL CODES MAKE A COMPANY LIABLE FOR THE ACTS OF MY SUBSIDIARIES AND EMPLOYEES?
On 23 November, an article from Reed Smith LLP explains the differing ways that the FCPA, UK Bribery Act, French and German criminal codes understand the liability of a company for the actions of its subsidiaries and employees. The article is the third of series of alerts from the firm.
HUMAN TRAFFICKERS GROUNDED IN 29-COUNTRY SWEEP OF EUROPEAN AIRPORTS AND ROADS
On 26 November, a news release from Europol advised that, between 8 and 12 November, Europol supported large-scale international action against trafficking in human beings. 29 countries, led by Austria and Romania, took part in the action days, which were coordinated by Europol and Frontex. The activities saw more than 14,000 law enforcement officers target trafficking routes on roads and at airports. This resulted in 212 arrests and the identification of a further 89 trafficking suspects.
SMALL-SCALE CHEMICAL AND BIOLOGICAL PRODUCTION: CURRENT THREATS AND FUTURE TRAJECTORIES
On 23 November, an Occasional Paper from RUSI says that chemical and biological weapons do not come out of nowhere. They are designed, developed and produced for specific purposes. The Paper analyses 2 central questions and makes policy recommendations to address the overall problem –
it assesses what resources are required for small-scale chemical and biological weapons (CBW) production; and
considers scientific and technical trends, and their impact on potential small-scale CBW production efforts.
GIBRALTAR’S NEW STATUTORY FRAMEWORK FOR LIMITED PARTNERSHIPS AND PROTECTED CELL PARTNERSHIPS IS COMMENCED
A news release from Gibraltar on 26 November advised that the Limited Partnerships Act and the Protected Cell Limited Partnerships Act have now been commenced.
MORE THAN 1,000 ARRESTS AND $27 MILLION INTERCEPTED IN MASSIVE FINANCIAL CRIME CRACKDOWN
A news release from Interpol on 26 November advised that over 4 months from June to September 2021, Operation HAECHI-II brought together specialised police units from 20 countries, as well as from Hong Kong and Macao, to target specific types of online fraud, such as romance scams, investment fraud and money laundering associated with illegal online gambling. In total, the operation resulted in the arrest of 1,003 individuals and allowed investigators to close 1,660 cases. In addition, 2,350 bank accounts linked to the illicit proceeds of online financial crime were blocked. More than 50 INTERPOL notices were published based on information relating to the operation and 10 new criminal modus operandi were identified.
END OF THE ROAD FOR ROMANIAN CRIMINALS TARGETING CARGO TRANSPORTS
On 26 November, a news release from Europol advised that an organised criminal group involving 30 Romanian nationals has been apprehended following an operation conducted by law enforcement authorities in France, Germany and Romania, supported by Europol and Eurojust. The group is suspected of thefts targeting cargo transport rest areas along main road haulage routes between Romania, France and Germany. The group – which was engaged in legitimate road haulage as cover – mainly targeted cargo shipments of alcohol and small electronics, stealing goods worth an estimated €2.5 million.
UK: FIREARMS – IMPORTATION SENTENCING GUIDELINES PUBLISHED
On 24 November, the Sentencing Council reported that it has published a new guideline for sentencing offenders convicted of firearms importation offences in England and Wales, following consultation. The guideline covers importation of firearms and ammunition under 2 Customs and Excise Management Act 1979 (CEMA) offences – improper importation of goods and fraudulent evasion of prohibition/restriction. It applies to adult offenders sentenced in magistrates’ court or the Crown Court on or after 1 January.
THE INTERNATIONAL COMPARATIVE LEGAL GUIDE TO GAMBLING 2022 – ISLE OF MAN CHAPTER
On 25 November, Appleby published the chapter of the 2022 guide which covers the situation in the Isle of Man – including relevant authorities and legislation, application for a licence, licence restrictions, digital media, enforcement, liability and anticipated reforms.
On 26 November, Hellenic Shipping News reported that a Danish naval patrol has killed 4 pirates in an exchange of fire in the Gulf of Guinea off the coast of Nigeria. A frigate had been patrolling the area since early November, and had attempted to board the pirate boat.
INDIA: OFFICIALS RAID PREMISES OF 3 SUCCESSFUL MOLLYWOOD PRODUCERS WITH HINTS AT INDUSTRY’S LINKS TO MONEY LAUNDERING
On 26 November, the New Indian Express reported that the Income Tax Department had carried out inspections at the office to 3 mainstream producers of the Malayalam film industry. A spokesman is quoted as saying that, as the film industry often attracts investments especially from abroad, we carry out such inspections on a regular basis… often film industry is used for laundering of money.
FCA TO PAY EXPERTS OVER $600,000 TO COMBAT CRYPTO CRIME
On 23 November, BTC Manager reported that the FCA in the UK is looking to hire Experts that would help monitor cryptocurrency transactions for money laundering, and other illicit activities.
CHINA: FORMER EDITOR AT STATE-RUN NEWSPAPER GETS 13 YEARS FOR BRIBERY
On 24 November, Caixin Global reported that Ding Ting, a former editor of the Party’s official newspaper, the People’s Daily, has been sentenced to 13 years in prison for accepting and offering bribes.
SWITZERLAND RETURNS LOOTED RELICS TO SYRIAN AUTHORITIES
On 24 November, Swissinfo reported that 3 rare artefacts that were looted from Syria’s ancient city of Palmyra and stored at the Geneva freeport have been returned to Syrian authorities. The items, together with others from Yemen and Libya, had been confiscated by the Office of the Attorney General of Geneva in 2016, after arriving illegally in Switzerland between 2009-2010 and discovered during a routine inspection by Swiss customs in 2013.
OFFICE OF FOOTBALL AGENT JORGE MENDES SEARCHED AGAIN IN MONEY LAUNDERING INVESTIGATION
On 24 November, the Guardian reported that officers from Portugal’s tax and customs authority conducted more than 20 searches in connection with its investigation into tax evasion and money laundering at top-flight clubs, as well as the super-agent Jorge Mendes.
NORTH KOREA REELS IN CASH FROM FISHING PERMITS THIS YEAR, DESPITE UN BAN
On 26 November, NK Pro reported that ship-tracking data shows scores of Chinese vessels entered North Korea’s exclusive economic zone (EEZ) over the last several months, in what likely amounts to extensive violations of sanctions.
EUROPEAN COURT OF JUSTICE DISMISSED AN APPEAL AGAINST A GENERAL COURT’S DECISION OVER DAMAGES OVER IRAN SANCTIONS
On 26 November, the EU Sanctions blog reported that on 18 November, the ECJ dismissed and appeal against a decision to award an appellant €71,000 in non-pecuniary damages and €500 for each month in which his assets were frozen (€21,000 in total) – he had asked for over £1.4 million. The appeal had been brought by Fereydoun Mahmoudian, the majority shareholder and chairman of Fulmen, an Iranian company active in particular in the electrical equipment sector.
UK: HIGH COURT REJECTS HUMAN RIGHTS ACT CHALLENGE TO SANCTIONS LEGISLATION
On 26 November, the EU Sanctions blog reported that the High Court has dismissed an application by Hany Youssef challenging the compatibility of one part of the Sanctions Act with Article 6 of the European Convention on Human Rights which guarantees the right of access to a Court, and Article 8 which protects the right to private and family life.
On 26 November, 5 St Andrews Hill chambers published a video recording of a webinar on 17 November. It looks back on what might be considered the ‘first wave’ of carbon credit fraud, between roughly 2010-2015, and examines whether there is the potential for a new ‘second wave’ of more sophisticated, larger-scale fraud. It looks at the challenges for investigators in terms of embarking on investigations of such conduct and also those seeking to represent individuals accused of wrongdoing in the carbon markets?
UK: WARNING FOR TAXPAYERS NOT TO SHARE THEIR GOVERNMENT GATEWAY DETAILS– INCLUDING COMPANIES THAT OFFER TO MAKE TAX RELIEF CLAIMS ON THEIR BEHALF – DUE TO COMPANY REFUND FRAUD RISK
On 26 November, Accounting Web reported that the Low Incomes Tax Reform Group (LITRG) is warning taxpayers not to share their Government Gateway username and password details with anyone – including companies that offer to make tax relief claims on their behalf. LITRG has issued a list of fraud warning signs.
PODCAST: HOW THE CHARITY SECTOR CAN BE TARGETED BY FRAUDSTERS
On 26 November, Third Sector released a podcast about a broad range of fraudulent activity affecting the charity sector. These include where people falsely claim to be raising money on behalf of charities, where charity staff have been conned into handing over charity money, as well as cases of insider fraud, where charity staff, trustees or volunteers have directly stolen from the charity.
FORMER HEAD OF CZECH SOCCER ASSOCIATION GETS 6-YEAR PRISON TERM FOR FRAUD
On 26 November, the Daily Mail reported that Miroslav Pelta, the former head of the Czech soccer association, had been convicted of fraud and sentenced him to 6 years in prison. He was also fined $220,000 and banned him from an executive position in corporations for 5 years. In the same case dating from 2017 and involving misuse of state subsidies, the court sentenced Simona Kratochvilova, a former deputy education minister, to 6½ years in prison and banned her from working in state offices for 6 years and fined her $88,000.
UK: 3 CIGARETTE SMUGGLERS FRAUDSTERS JAILED FOR A TOTAL OF 8½ YEARS
On 26 November, Forecourt Trader reported that they were part of organised crime networks that operated in London and the Midlands, and were caught with more than 5 million cigarettes in November 2016.
LITHUANIA: CORRUPTION PROBE TARGETS PROPERTY DEVELOPMENT IN VILNIUS
On 26 November, LRT reported that the Special Investigation Service (STT) has announced an investigation into a possible inter-institutional criminal scheme involving employees of Vilnius city municipality.
UK: TREASURY COMMITTEE TO QUESTION MINISTERS ON FRAUD, SCAMS AND ECONOMIC CRIME
On 26 November, the Parliament website reported that Government ministers will be questioned by Parliament’s Treasury Committee on fraud, scams and economic crime at on 29 November. Following news that fraud increased by 30% in the first half of 2021, the Committee is likely to use the session to discuss the action required to tackle fraud and scams. It is said that the Committee may also use the session to explore what the Government is doing to stop the rise in authorised push payment (APP) fraud and to ensure that victims are reimbursed. Other topics of discussion could include effectiveness on the AML regime, and the need for more transparent ownership of companies and property to prevent criminals hiding money in the UK.
HONDURANS WEARY OF CORRUPTION LOOK FOR CHANGE IN ELECTION
On 26 November, ABC News reported that the upcoming election will be about removing a party whose successive administrations are widely seen as deepening the country’s corruption over the past 12 years, driving tens of thousands to flee the country.
FATF WEBINAR ON PROLIFERATION FINANCING RISK ASSESSMENT AND MITIGATION
On 16 December, FATF will host a live webinar featuring a panel of experts from public and private sectors with a global and domestic focus on tackling the financing of the proliferation of WMD.
HONG KONG: SFC ACTION OVER A SUSPECTED SOCIAL MEDIA RAMP-AND-DUMP SCAM INVOLVING MANIPULATION OF THE MARKET IN LATE OCTOBER 2021
A release on Mondo Visione on 26 November advised that the Securities and Futures Commission (SFC) has issued restriction notices to Emperor Securities Limited and Get Nice Securities Limited, prohibiting them from dealing with or processing certain assets held in 17 trading accounts.
Brazil: FORMER OLYMPICS BOSS SENTENCED TO JAIL FOR CORRUPTION
On 26 November, the New Indian Express reported that Carlos Arthur Nuzman, the head of the Brazilian Olympic Committee for more than 2 decades, has been sentenced to 30 years and 11 months in jail for allegedly buying votes for Rio de Janeiro to host the 2016 Olympics.
TRUSTS: UK PROPERTY OWNERSHIP STRUCTURE – REMEMBER TO REGISTER WITH THE UK TRUST REGISTRATION SERVICE
On 26 November, Herbert Smith Freehills issued a reminder that HMRC has expanded the scope of what trusts are required to register with the TRS such that all express trusts (save for a few limited exceptions), which are required to register irrespective of whether they have a liability for UK tax. It explains that whilst the legislation provides that affected trusts must register by 10 March 2022, HMRC has announced that, due to technical upgrades required, this deadline has been extended to 1 September 2022 (for trusts in existence on or after 6 October 2020).
UK: CASH AND CARRY BOSS JAILED FOR 5 YEARS FOR MONEY LAUNDERING
On 26 November, the Ilford Recorder reported that a Barking cash and carry boss, Avtar Singh Mann, 50, has been sentenced to more than 5 years in jail for his part in a £25 million money laundering scheme. He helped move millions of pounds through the bank accounts of shell companies set up to launder cash believed to derive from the sale of non-duty paid alcohol.
CAN THE BIOLOGICAL WEAPONS CONVENTION ADDRESS NEW BIOTHREATS?
On 25 November, an article from Chatham House says that the dual-use nature of many new biological techniques pose significant challenges for governance, particularly as new and complex synergies emerge between biology and other disciplines, such as chemistry, artificial intelligence (AI) and cyber technologies. Developments have diversified biothreats beyond what was originally conceived by the Biological Weapons Convention (BWC), introducing new and more interconnected pathways for the hostile use of biological agents. Parties to the BWC are meeting, and the article says that there is an urgent need to update the treaty regime by reframing discussions to properly address the complexity of modern-day biothreats.
OPERATION CLAMPS DOWN ON ILLEGAL TRANSBOUNDARY SHIPMENTS OF WASTE AND OZONE DEPLETING SUBSTANCES
A news release from the World Customs Organisation on 26 November advised that, from 1 to 31 October, Operation DEMETER VII demonstrated Customs’ commitment to helping to protect the health of both people and the planet, by enforcing Multilateral Environmental Agreements (MEA) which regulate cross-border movements of environmentally sensitive commodities. It tackled the illicit trafficking of waste, ozone depleting substances (ODS) and hydrofluorocarbons (HFC), which are very potent greenhouse gases that contribute to global warming and climate change. These commodities are regulated under, respectively, the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (Basel Convention), and the Montreal Protocol on Substances that Deplete the Ozone Layer (Montreal Protocol). Using risk indicators and focusing on pre-identified routings and hotspots, Customs officers controlled suspicious shipments and seized illegal waste and ODS. It resulted in a total of 107 seizures, including 3,851 tons of waste and additional 6,108 pieces, and 101 kg and additional 493 pieces of substances controlled under the Montreal Protocol.
BANNING BINANCE AND THE CHALLENGES OF REGULATING CRYPTO
On 24 November, an article from Corker Bining examines the facts behind sensational headlines, which it says are emblematic of the tussle between investors, financial institutions, cryptoasset service providers, and regulators that has existed ever since cryptocurrencies came to mainstream attention. At the heart of this tussle are said to be questions about the cross-border regulation of cryptoasset companies, and the financial crime implications for investors and institutions who do business with Binance, and other cryptocurrency exchanges.
FINLAND: BLOCKFEST FOUNDER ACCUSED OF MONEY LAUNDERING
On 26 November, IQ Magazine reported that Kalle Kallonen, thefounder and CEO of Finland’s Blockfest festival has gone on trial accused of money laundering. He denies the charge of allegedly received cash earned from drug offences for €10,000 which he transported to Spain in May 2021. His is part of larger case in which aA total of 10 people have been charged, including 3 men who are alleged to have formed an organised criminal group to commit drug offences from 2020 to June 2021. Founded in 2008, Blockfest has grown to become one of the biggest hip-hop festivals in the Nordic countries.
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On 25 November, a report from the Environmental Investigation Agency said that, despite trade sanctions imposed in June to ban imports of Myanmar teak into Europe, more than 300 tonnes of teak, worth well over €2 million, has since entered into Italy. It says that, in the first half of the year, more than €1 million worth of timber was entering into Italy every month, but in July this decreased to about €500,000 worth. However, with the sanctions in place there should be no timber entering at all and, subsequently, timber imports have increased.
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On 25 November, Comicbook.com reported that Chinese media reports that 20 boxes of counterfeit Pokemon trading cards were seized at Shanghai’s Pudong Airport. They weighed over 7.6 tons and were bound for the Netherlands, where they would presumably be distributed around Europe.
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On 25 November, an article from OCCRP reported that a former prison warden from Lithuania may have helped the regime of Belarusian dictator Alexander Lukashenko dodge sanctions by benefitting from a $1.1 million deal to export Belarusian trucks, made by sanctioned Belrussian state company BelAZ, through Lithuania’s biggest seaport.
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On 26 November, FATF published this report prepared by FATF-style regional body GIABA following an on-side visit on 13 to 29 January 2020. It finds that, overall, the understanding of risks in Niger is considered as satisfactory, although not at the same level for all sectors.
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On 25 November, an EU news release advised that the EU Council had agreed its position on the proposal for a Digital Services Act (DSA). The main aim of the proposed DSA is to keep users safe from illegal goods, content or services, and to protect their fundamental rights online. It also modernises part of the 2000 e-commerce Directive.
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The Terrorism Act 2000 (Proscribed Organisations) (Amendment) (No 3) Order 2021 adds Harakat al Muqawama al-Islamiyya (Hamas) to the list of proscribed organisations under the Act. 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.
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On 26 November, the Institute of Export & International Trade released a webinar presentation about the changing regulations from 1 January when importing from the EU to GB.
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On 24 November, Taylor Wessing published this article saying that the EU Regulation on European Crowdfunding Service Providers (ECSPR) came into operation on 10 November after more than 2 years of long and intense discussions between EU lawmakers. In this first part of a publication the firm analyses the scope of application of the ECSPR and the authorisation requirement that prospective CSP will need to fulfil under the new regime. The second part will analyse the investor protection requirements that the prospective CSP will need to comply with as well as the impact of the ECSPR on national regulatory framework in Germany.
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Panama Covid-19 update – on 24 November, it was announced that Panama had (so far) spent $92 million on Covid vaccines, mostly (over $84 million) to Pfizer/BioNTech. This news comes as the Government boasts, with street signs etc, of reaching the 80% double-vaccinated level, and as the booster programme continues. In view of the news of the new variant coming out of southern Africa (so that the UK has had to resurrect its Red List, to put South Africa and others to it), perhaps this is just as well!
The number of active cases show a rise of 122 today to 2,663. There were 262 new cases and 2 new fatalities; with 22 in ICU and 94 in other wards.
25 NOVEMBER 2021
OFAC ISSUES FIRST ROUND OF SANCTIONS UNDER ETHIOPIA SANCTIONS PROGRAM AND NEW GENERAL LICENSE
On 23 November, a blog post from Baker McKenzie reported that on 12 November, OFAC sanctioned 4 entities and 2 individuals. This is the first round of sanctions imposed under Executive Order 14046.
On 24 November, BLM released this 10-minute video which discusses deliberate and potentially fraudulent fires, addressing the key issues and things to look out for.
On 23 November, Hassan Elhais published a short note saying that the UAE does not have a particular anti-bribery law, and instead, the applicable provisions are part of Federal Law which provides for the main provisions governing the anti-corruption and anti-bribery practices in the region.
ISIS IS STEALING THOUSANDS OF SHEEP IN SYRIA TO FINANCE TERROR CELLS
On 21 November, Metro reported that cells in Hama and areas bordering Raqqa and Aleppo are said to be carrying out widespread black market operations with sheep stolen from locals are being sold at live cattle markets by fighters posing as shepherds. Hundreds of animals were reportedly stolen every week at the beginning of 2021, with farmers being murdered in raids or killed by mines laid on roads and in grazing areas. Some of the cattle is being used to sustain the fighters.
MALTA STILL SLOWEST IN EUROPE TO CONCLUDE MONEY LAUNDERING CASES
On 25 November, The Shift reported that the latest data published in July by the European Commission shows that Malta continues to have overall some of the longest estimated times needed in order to resolve litigious, civil, and commercial cases at all court instances, with only Italy having a worse performance.
DEADLINE FOR REGISTRATION OF UBO IN CZECH REPUBLIC APPROACHING
On 24 November, an article from Bird & Bird says that all registrations must comply with a new Act on Beneficial Owners Register and explains what do you need for the registration.
EUCOMMISSION PROPOSALS FOR RATIFICATION OF NEW INTERNATIONAL INSTRUMENT TO IMPROVE COOPERATION ON ACCESS TO ELECTRONIC EVIDENCE
On 25 November, the EU said that the Commission had adopted 2 proposals to authorise EU Member States to sign and ratify the Second Additional Protocol to the Council of Europe Budapest Convention on Cybercrime. It is said that the Budapest Convention lies at the heart of a global alliance against cybercrime and has been signed by all EU Member States. It is the foundation for of anti-cybercrime legislation in 80% of countries worldwide.
On 23 November, the Home Office produced an updated version of the list of groups and organisations affected. It contains updated details for 2 such groups and notes the increased maximum jail sentence available from 10 to 14 years.
On 24 November, the House of Commons Library published a briefing which discusses the incidence of tax avoidance and evasion, before looking in detail at the development of follower notices and accelerated payment notices, and further initiatives to reduce the tax gap. Other available briefings look at the introduction of the 2019 Loan Charge, legislation to tackle mass marketed ‘loan schemes’ announced in the 2016 Budget (which has proved highly controversial); the Labour Government consideration of a general anti‑avoidance rule (GAAR) and the establishment of DOTAS; and at the Coalition Government’s decision to introduce a GAAR.
On 24 November, the Department for Digital, Culture, Media and Sport published 2 factsheets which give an overview of the Dormant Assets Bill, which will allow the inclusion of additional assets across from the insurance and pensions, investment and wealth management, and securities sectors in the Dormant Assets Scheme. It is said that the scheme expansion has the potential to unlock an estimated £880 million for social and environmental purposes.
SECOND OF FORMER PANAMA PRESIDENT MARTINELLI’S SONS TO BE EXTRADITED TO US
On 24 November, Kenneth Rijock in his blog said that Guatemalan media has reported that Luis’ brother, Ricardo Martinelli Linares, has now followed Luis and waived his right to further contest extradition from Guatemala to the US and he was expected to be flown to New York in the next couple of days.
GERMANY’S NEXT GOVERNMENT AIMS TO LEGALISE RECREATIONAL CANNABIS
On 25 November, TJI reported that the Social Democratic Party, the Greens and the Free Democratic Party have agreed to introduce legislation during their 4-year term to allow the controlled distribution of weed in licensed shops.
DUTIES OF CARE ON FINANCIAL INSTITUTIONS AROUND THE WORLD
On 24 November, an article from Eversheds Sutherland takes a high-level look at some of the key trends in the development of duties of care imposed on financial institutions outside express contractual terms in some key jurisdictions around the world and whether the scope of such duties are expanding.
CRIME GANGS MAKE VIETNAM THE TOP DESTINATION FOR SMUGGLED AFRICAN WILDLIFE
On 24 November, RFA reported that wildlife being trafficked from Africa by Vietnamese organised crime networks include pangolin meat, elephant ivory, and rhino horns, says the report by the London-based NGO Environmental Investigation Agency (EIA). It says that networks are accelerating the decline of Africa’s biodiversity and are exacerbating corruption and weak rule of law in many source and transit countries in the continent.
PrivatBank LATVIA HIT WITH YET ANOTHER FINE FOR AML FAILURES
On 23 November, LSM reported that Latvia’s banking regulator, the Financial and Capital Market Commission (FKTK), has said that it was hitting AS PrivatBank with a fine of more than €750,000 “for breaches of regulatory requirements in the field of anti-money laundering and combating terrorism and proliferation financing (AML/CTPF)”, plus various other measures.
FRAUD SUIT VERDICT UNDERMINES SEC CONTROL OF CRYPTOCURRENCIES
On 23 November, PYMNTS.com reported that a lawsuit over an alleged crypto Ponzi scheme dating back to 2014 may have thrown a big wrench into the SEC argument that nearly all cryptocurrencies are securities over which it has authority.
On 24 November, Kharon reported that QuantumCTek, which has provided services to Chinese military entities, received items from US and Western companies through intermediaries in recent years. It has now been added to the Commerce Department Entity List, which imposes export controls.
INTERNATIONAL STUDENTS AND OFFSHORE BANKING FLAGGED IN CANADIAN REAL ESTATE MONEY LAUNDERING
On 25 November, Global News reported on files from the Canada Border Services Agency provide a rare glimpse into an opaque business model increasingly cited in examinations of Canadian real estate, in which relatives use foreign students as fronts to funnel wealth into condos and mansions. It also says that Transparency International Canada, the anti-corruption watchdog, has studied luxury real estate trends in Vancouver, and finds that “student” buyers were a significant concern.
CANADA SPOTS 24 SUSPECTED SHIP-TO-SHIP TRANSFERS IN DPRK SANCTIONS OPERATIONS IN OCTOBER
On 25 November, NK News reported that Canada has spotted at least 24 ship-to-ship transfers and over a hundred “vessels of interest” potentially violating sanctions against North Korea since mid-October. Canadian naval and air assets are currently in the Indo-Pacific as part of the UN Enforcement Coordination Cell. In September, HMS Richmond also spotted “multiple ships of various nationalities” conducting similar activities in the East China Sea, potentially in contravention of UN sanctions.
PERU OPENS CRIMINAL PROBE INTO JOURNALIST WHO EXPOSED ILLEGAL COLLUSION WITH WITNESS in car wash case
On 24 November, The Intercept reported that the federal public prosecutor’s office in Peru had opened an investigation into Ernesto Cabral, a journalist for the award-winning investigative outlet OjoPúblico. It stems from 2019, when Cabral, working in partnership with Intercept Brasil journalists, wrote a story shedding light on illegal malpractice on the part of 2 Peruvian anti-corruption prosecutors, who were alleged to have coached a cooperating witness to ensure that his testimony lined up with their case.
2 TUNISIAN REGIONAL GOVERNORS HAVE BEEN DETAINED ON SUSPICION OF CORRUPTION
On 25 November, FX Empire reported a Reuters story that the public prosecutor’s office had ordered the arrest of the governors of Sidi Bouzid and Kebili regions on suspicion of “financial corruption and abuse of official authority by public officials”.
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On 25 November, ENACT Africa announced the release of this Index. It says that organised crime increased across Africa during the COVID-19 pandemic and shows no signs of slowing. It says that organised crime is one of Africa’s biggest security challenges, with more than two-thirds of Africans living in countries with high criminality, and nearly 80% in states with acute vulnerability and low resilience. The Democratic Republic of the Congo has the highest criminality, followed by Nigeria, with Kenya, South Africa, Libya and Mozambique also in the top 10. State-embedded actors are said to have grown more powerful during the pandemic as they monetised their control over government resources and institutions. Human trafficking remained the most pervasive criminal market in Africa, while the cocaine trade saw the biggest increase. The Index is based on analysis and inputs from 120 experts across the continent and an extensive literature review. It reports on mafia-style groups, criminal networks, state-embedded actors and foreign criminals. It assesses resilience to organised crime, including political leadership and governance, criminal justice, economic and financial environments, and civil society. Its aim is to stimulate informed dialogue on the impact of criminality and response measures, and promote policies to build resilience to organised crime.
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On 24 November, the Basel Institute on Governance published an article which is a quick guide which looks at how criminals obtain a veneer of respectability and exploit secrecy by manipulating and misusing corporate vehicles in offshore structures and beneficial ownership. It focuses on the meaning of “corporate vehicle” and “offshore” and other related concepts such as beneficial ownership. It also gives an example of how a trust, which is one common type of corporate vehicle in the vast “offshore ecosystem”, can be used for illicit purposes.
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On 24 November, a news release from the UN advised that the relevant Sanctions Committee has added Emraan Ali to its sanctions list. He is said to be a senior member of Islamic State in Iraq and the Levant (ISIL), listed as Al-Qaida in Iraq.
A Notice from HM Treasury added Emraan Ali to the UK Consolidated List.
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On 25 November, Legal Futures reported that the Law Commission, which advises on changes to law in England and Wales, says that there is no need for new legislation on smart contracts because the existing laws can accommodate them. A new paper gives advice to government on smart contracts.
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On 21 November, The National reported that Lebanon’s Amal party is set to run a US-designated terrorism financier, Kassem Hejeij, as a candidate in the country’s coming parliamentary elections. This is said to be in exchange for him significantly funding the party’s election campaign.
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Panama Covid-19 update – the number of active cases has risen by a further 73 to 2,541; there were 2 new fatalities and 268 new cases; with 21 in ICU and 96 in other wards.
24 NOVEMBER 2021
AUTONOMOUS WEAPONS – WHAT THE LAWS SAYS, AND DOES NOT SAY, ABOUT THE HUMAN ROLE IN THE USE OF FORCE
On 11 November, an article from the International Committee of the Red Cross says that intergovernmental discussions on the regulation of emerging technologies in the area of (lethal) autonomous weapon systems (AWS) are back on track in Geneva after more than a year of COVID-19 related disruptions.The article reflects on whether international humanitarian law provides sufficiently clear guidance as to how humans and machines may interact in use of force decisions. Building on the findings of a recent SIPRI study, it argues that clarification may be warranted and provides concrete suggestions on how states may further identify what IHL compliance requires in the development and use of AWS. The article argues that it is time for the international community to consider, not only what the law already says, or does not say, about the human role in the use of force, but what it should say—regardless of the technology being used.
A SIGNIFICANT SHIFT IN THE EU’S FOREIGN AND SECURITY POLICY – THE TRANSFER OF WEAPONS TO FRAGILE STATES
On 10 November, an article from the Stockholm International Peace Research Institute about a new approach — part of the EU’s increasing reliance on military-oriented tools to fulfil its goals to contribute to peace, security and development around the world — is in some measure embodied by the new European Peace Facility (EPF). The EPF is part of an ambitious plan, launched by the 2016 EU Global Strategy to strengthen EU security and defence and to develop an integrated approach to conflict and crises. It warns that the use of the EPF will probably involve transfers of arms to countries or regions that are by definition fragile and affected by political instability and armed conflicts, often involving transnational terrorist groups or armed rebel groups contending the control of national territories. It identifies the key risks, including diversion of the equipment and the risk of misuse of weapons.
AN INTRODUCTION TO THE ISO 37001- AN INTERNATIONAL STANDARD RE ANTI-BRIBERY MANAGEMENT SYSTEM FOR INTERNAL AND EXTERNAL WORKFORCES
On 22 November, an article from the CRI Group says that ISO 37001 was launched in 2016 and postulates a sequence of measures that an organisation can implement to aid in preventing, detecting and tackling bribery and is calculated to be unified with your organisation’s prevailing management processes and controls; and the ISO 37001 also shadows the shared ISO structure for management system standards, such as the ISO 9001.
On 23 November, Newsroom Panama reported that the preliminary hearing of the investigation into the Panama Papers by the Third Court of Criminal Proceedings of Panama to determine if the merits exist for a money laundering trial have begun at the Balboa Theatre (converted into a courtroom) and will run from 22 November to 17 December with a cast of hundreds including 50 high-profile defendants and their legal teams.
HONG KONG CUSTOMS AGENTS SEIZE 200 TONNES OF CONTRABAND MEAT
On 24 November, OCCRP reported the seizure of a smuggling vessel carrying approximately 200 tonnes of frozen meat and arrest of 3 men between the ages of 38 and 47. The meat was destined for Mainland China. It also notes that Indian beef is banned due to a Chinese import prohibition in response to a skin disease that was spreading amongst India’s cows.
BELGIAN GHOST COMPANY RECEIVED MORE THAN €6 MILLION FROM CONGO
On 24 November, the Brussels Times reported that a seemingly non-existent company based in Brussels received more than €6 million from a Belgian-Congolese entrepreneurial duo linked to Congo’s former president, raising questions about possible money laundering. It is reported that no such business exists on the Belgian companies register. It is said that between 2012 and 2018, at least €6.35 million was transferred to Belgium from an account via the Congolese branch of Banque Gabonaise et Française Internationale (BGFIBank).
INDIA IS PLANNING TO INTRODUCE A BAN ON ALMOST ALL PRIVATE CRYPTOCURRENCIES IN A NEW CLAMPDOWN
On 24 November, Euronews reported that India is on track to ban all but a few private cryptocurrencies after the government announced that it was introducing a new financial regulation Bill.
SMALL-SCALE CHEMICAL AND BIOLOGICAL PRODUCTION: CURRENT THREATS AND FUTURE TRAJECTORIES
On 23 November, an Occasional paper from RUSI explores scientific and technical trends in small-scale chemical and biological weapons production, and provides key recommendations for policymakers and diplomats to address the problem. It analyses 2 central questions and makes policy recommendations to address the overall problem. First, it assesses what resources are required for small-scale chemical and biological weapons (CBW) production. The necessary inputs in terms of budget, facilities, labour, materials and other factors are small, meaning efforts can be easy to conceal. Then, second, the paper considers scientific and technical trends, and their impact on potential small-scale CBW production efforts.
ACTIVISTS SAY ILLEGAL FISHING IN WEST AFRICA IS HURTING OCEANS AND SOCIETIES
On 24 November, OCCRP reported that illegal, unreported and unregulated (IUU) fishing is a scourge to maritime ecosystems and economies around the planet, accounting for 20% of the world’s catch and is particularly pervasive in West Africa. It also says that while illegal fishing takes different forms, but large-scale industrial operators do the most damage to ecosystems and the environment.
ENERGY EFFICIENCY FUNDS FRAUDSTERS DEACTIVATED IN ITALY
A news release from Europol on 24 November advised that Italian and German police, supported by Europol and Eurojust, dismantled a criminal network involved in fraud with public funds. The fraud was perpetrated through the use of so-called ‘white’ energy efficiency certificates, with criminals then laundering the illicit proceeds. Between 2016 and 2020, the criminal network illegally obtained certifications for energy efficiency (“white” certificates), while receiving subsidies through fictitious projects. In total, the criminal network illegally obtained about €27 million in subsidies from nationally distributed funds. Then, they transferred the illicit proceeds to bank accounts in Germany, Switzerland and other European countries.
CHINESE AND UAE OFFICIALS RUN FOR TOP INTERPOL POSITIONS
On 23 November, Rferl reported on concerns as Interpol’s general assembly meets in Istanbul where it is expected to elect its new leadership. Representatives from China and the UAE are bidding for top posts in the policing body.
CANADA INTERCEPTS ALLEGED FORCED LABOUR CLOTHING SHIPMENT FROM CHINA
On 22 November, Just Style reported that the Canada Border Services Agency (CBSA) has intercepted a shipment of women’s and children’s clothing from China that it has classified as being ‘goods mined, manufactured or produced wholly or in part by forced labour’. The shipment of clothing was intercepted in the Quebec region due to forced labour concerns.
On 24 November, the FATF-style regional body announced that on 15-19 November, GAFILAT, through its president and the Executive Secretariat of the organisation, made a High-Level visit in preparation for the mutual evaluation process for Ecuador. Experts made various presentations on core issues for the preparation of Ecuador in its evaluation process.
ITALIAN AUTHORITIES IDENTIFY 12 MAFIA ASSOCIATES IN MALTA-ITALY CRACKDOWN
On 24 November, the Times of Malta reported that the Malta Gaming Authority has asked the Italian authorities for information on an anti-mafia money laundering probe with ties to Malta. The so-called Game Over II law enforcement operation ended in Italy earlier this month and included Maltese companies and online gambling sites that were once licensed in Malta.
US TO DROP COLOMBIAN REBEL GROUP FARC FROM TERRORIST LIST
On 23 November, the Wall Street Journal reported US plans which follows the 2016 peace deal between FARC and the Colombian government which ended 52-year conflict.
PODCAST: “PROMOTING INTEGRITY IN THE WORK OF INTERNATIONAL ORGANISATIONS”
The latest TRACE podcast features Duncan Smith of the European Investment Bank who discusses his book, Promoting Integrity in the Work of International Organisations: Minimising Fraud and Corruption in Projects. He talks about the unique role of multinational development banks, the progress that remains and the cost of getting it wrong.
POTENTIAL ALLIANCE BETWEEN FINCEN AND THE DoJ ENVIRONMENTAL CRIMES UNIT PRESENTS A POTENT LAW ENFORCEMENT COMBINATION FOR COMPANIES TO MONITOR
On 24 November, an article from Eversheds Sutherland says that, as companies continue to focus on improving their ESG credentials, they are constantly assessing their environmental management systems and compliance programs for potential areas of ESG-related risk. It says that a FinCEN/DoJ alliance on environmental crimes would be a remarkably potent law enforcement combination. It says that prudence dictates that organisations assess their environmental compliance systems in light of these developments.
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n 24 November, OFAC issued new General License 8I “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities”.
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On 24 November, OFAC announced that it had amended the Syrian Sanctions Regulations to expand the authorisations for NGO to engage in certain transactions and activities. This action builds upon the US Government’s longstanding humanitarian exemptions, exceptions, and authorisations in the Syria sanctions programme — and helps ensure the continued provision of humanitarian assistance, including certain early-recovery activities, that benefit the Syrian people. The US Treasury’s recent sanctions review highlighted the need for continued review of existing authorities to facilitate legitimate humanitarian activity while continuing to deny support to malicious actors.
On 24 November, a statement from the Financial Services Authority advised that a TCSP had received a civil penalty of £321,550 (discounted by 30% to £225,085) for contraventions of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019. It was also established that a number of entities administered by the TCSP were not complying with their own respective obligations under the Code.
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On 24 November, Legal Futures reported that the Solicitors Regulation Authority (SRA) identified authority, independence and resources as the key pillars of the roles of money laundering compliance officer (MLCO) and reporting officer (MLRO) – while most it talked to were generally fulfilling the first 2, the third was the biggest challenge. It is proposed that MLRO and MLCO workloads be reduced and that firms should consider appointing deputies.
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On 24 November, a news release from Europol advised that Europol, Eurojust and the European Judicial Network have published the third annual edition of the SIRIUS European Union Digital Evidence Situation Report. This year, the report goes beyond a comprehensive status update by including an assessment of the impact of the COVID-19 pandemic on the access of EU authorities to electronic evidence held by foreign-based online service providers (OSPs) in 2020. It says that the volume of cross-border requests submitted by EU authorities to 8 large online service providers (OSP) increased 27% in 2020 in comparison with the previous year, with a large majority of them issued by Germany and France, and mainly to Facebook and Google. There was a very significant increase of 112% in emergency disclosure request in 2020 compared to 2019, with Facebook receiving most of them, among the OSP analysed. The report says that cross-border access to digital evidence is crucial to most investigations, and it became even more relevant during the pandemic.
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Panama Covid-19 update – no new fatalities today, although there were 214 new cases, with the total of active cases rising by only 13 to 2,468. 23 patients are in ICU and 91 in other wards.
23 NOVEMBER 2021
2-YEAR INVESTIGATION UNCOVERS ILLEGAL GAMBLING AT WASHINGTON HORSE RACING SITE
On 22 November, iGB reported that a ranch was being used for a horse racing operation that was accepting illegal wagers, along with other suspected illegal gambling on site, with monthly horse racing meets held and advertised on social media.
CALL FOR GAO TO EXAMINE FBI WHISTLEBLOWER PROTECTIONS
On 22 November, Government Executive in the US reported that 5 years after Congress passed a law reforming the FBI whistleblower programme, the DoJ still has not issued regulations to implement those changes. A bipartisan group of lawmakers has asked the Government Accountability Office to conduct a new review of the programme after years of inaction despite calls for reform. It was in 2015 that the GAO highlighted a number of weaknesses in the rules, including a lack of clarity in terms of where whistleblowers can make protected disclosures and an inability of employees who believe they were retaliated against to challenge adverse personnel actions.
AN OFFSHORE PERSPECTIVE: THE ENGLISH COMMERCIAL COURT’S DECISION IN THE SKAT “CUM-EX” CASE AND DICEY RULE 3
On 22 November, Harneys published an article about the case in which the English High Court dismissed proceedings brought by the Danish national tax authority against over 100 defendants in connection with tax refunds that it alleged it had been induced to repay by misrepresentations. The judge had invoked “Dicey Rule 3”, a rule which disallows claims for the enforcement, directly or indirectly, of the penal, revenue and public laws of foreign states. The article considers the position from a Cayman and BVI perspective. It points out that the rule may apply even where fraudulent or dishonest or wrongful conduct may be shown (obviously, between EU Member States, EU law has evolved to counter such rules). The article does say that the rule is in effect in Cayman and the BVI just as it is in England and Wales.
MUST A FACTUAL WITNESS KEEP THEIR OPINIONS TO THEMSELVES?
On 18 November, Watson, Farley & Williams published an article about a recent High Court case in which the defendant sought to strike out parts of the claimant’s witness statements on the basis that they contained impermissible opinion evidence. The application was dismissed, but it provides useful clarification on the application of new rules, and their interaction with the law on admissibility of evidence – under new rules applied to the business and property courts. It is said that the new rules do not affect the precedent law on admissibility of opinion evidence from witnesses of fact in relevant cases. It also serves as a useful reminder that, in appropriate cases, witnesses can give evidence by reference to their own personal knowledge and involvement as to what would or could have happened in counterfactual or hypothetical circumstances.
THE RISING STANDARDS OF AML/CFT COMPLIANCE IN HONG KONG
On 22 November, Regulation Asia reported that discusses key developments in 2021 and which are said to demonstrate a trend in increased standards expected of Hong Kong financial institutions.
HOW DIGITAL ESPIONAGE TOOLS EXACERBATE AUTHORITARIANISM ACROSS AFRICA
On 19 November, an article from the Brookings Institute on use of the Pegasus spyware system says that, of the 14 phone numbers said to be on the system, belonging to world leaders on the list of numbers and suspected of being targeted, half were African. They included 2 sitting heads of state — South Africa’s Cyril Ramaphosa and Morocco’s King Mohammed VI — along with the current or former prime ministers of Egypt, Burundi, Uganda, Morocco, and Algeria. However, it also says that African leaders are both victims and users of malware systems such as Pegasus. It says that it is clear that governments across Africa are also using spyware for purposes of international espionage – and these tools are being used in ways that risk worsening authoritarian tendencies and raise questions about whether security services are being properly held to account for their use. It warns that Pegasus is far from the only cyber espionage software ostensibly meant to aid law enforcement fight criminals that is being used for more nefarious purposes; and that digital surveillance is a booming industry in Africa.
EU COURT OF JUSTICE UPHOLDS THE ACTS OF THE COUNCIL MAINTAINING HAMAS ON THE EUROPEAN LIST OF TERRORIST ORGANISATIONS
A news release from the Court of Justice of the European Union on 23 November advised that the General Court should not have cancelled in 2019 Hamas’ listing on the ground that the EU Council had failed to authenticate by means of a signature the statements of individual reasons for those acts.
A NATIONAL COURT MUST DISREGARD ANY NATIONAL JUDICIAL PRACTICE WHICH IS PREJUDICIAL TO ITS RIGHT TO MAKE A REFERENCE TO THE EU COURT OF JUSTICE
A news release from the Court of Justice of the European Union on 23 November advised about a case from Hungary and involving a Swedish national and interpretation. It said that a supreme court of a Member State may not declare a request for a preliminary ruling submitted by a lower court unlawful on the ground that the questions referred are not relevant and necessary for the resolution of the dispute in the main proceeding.
EXTRADITION AND PROSECUTION OF ISRAELIS BY FOREIGN COURTS
On 22 November, an article from Barnea Jaffa Lande & Co starts by saying that numerous news articles have reported on the arrests of Israeli citizens resulting from foreign investigations conducted abroad. For example, more than 20 employees of a Tel Aviv based company engaging in forex investment marketing were arrested following an FBI investigation and reports indicate that European countries have arrested many other suspects as part of the same investigation, led apparently, by the US. It refers to Israel’s lax law enforcement policy regarding international white-collar crimes.
CHINESE CUSTOMS SEIZES METEORITES PASSED OFF AS PYRITE
On 23 November, The Indian Express reported that almost half a tonne of meteorites declared as pyrite ore on import have been seized by authorities. Pyrite, also known as “fool’s gold”, is an iron sulphide mineral used in the paper and jewellery industries. It was not immediately clear how the owner had come into possession of the meteorites.
On 22 November, an article from Insight Crime is about a vast cryptocurrency pyramid scheme, have emerged, including links to drug money, charitable donations to a church, and a murder-for-hire plot. The article examines the case in which, in 2015, Glaidson Acácio dos Santos, a former waiter and pastor, founded a company, GAS Consultoria Bitcoin, that traded in cryptocurrency; and he soon had a vast portfolio that moved hundreds of millions in dollars. However, he was arrested in August 2021 and accused of building a complicated pyramid scheme. Since his arrest, the case has taken a number of turns, including Acácio dos Santos being named a defendant in 288 separate civil cases.
On 23 November, the Financial Services Authority published this Plan which, it says, set out its blueprint to maintain the Island’s reputation as a well-regulated international finance centre. It highlights the goals and priorities that will lead initiatives to protect consumers, reduce financial crime and uphold confidence in the financial services sector. On AML/CFT, with an updated approach to AML/CFT, the Plan says its strategic priorities are – defining (and implementing) the role and responsibilities of its new AML/CFT Division; maintenance and review of guidance; and continued engagement with Government AML/CFT Policy.
AUSTRALIA: MAN CHARGED AFTER 1,000 LITRES OF PSEUDOEPHEDRINE SEIZED
A news release from Australian Federal Police on 22 November advised that a joint-agency police investigation has resulted in the seizure of more than 1,100 litres of pseudoephedrine.
OLAF TO PLAY AN EVEN BIGGER ROLE IN STOPPING WASTE TRAFFICKING AND FIGHTING CLIMATE CHANGE
On 17 November, a news release from the EU anti-fraud office advised that up to 30% of all waste shipments may be illicit, estimates suggest, making up to €9.5 billion for criminals. 70 million tonnes of waste are shipped per year within the EU, in addition to nearly 33 million tonnes of waste that the EU exports to non-EU countries. Now the European Commission has adopted a proposal to revise the EU’s rules on waste shipments. The proposed changes include enhancing the role of the European Anti-Fraud Office (OLAF) to counter cross-border waste trafficking involving suspicious movements inside the EU.
PAKISTAN: NAB CHAIRMAN CLAIMS SOLID EVIDENCE OF MONEY LAUNDERING AGAINST “BIG FISH”
On 22 November, The Nation reported that the National Accountability Bureau (NAB) Chairman has claimed that the bureau had solid evidence of money laundering of billions of rupees by the big fish, with money laundered through fake accounts.
EX-CREDIT SUISSE BANKERS SAY IT STILL AIDS HIDDEN ACCOUNTS
On 22 November, Swissinfo reported that former Credit Suisse Group AG bankers have told criminal investigators that the bank is still helping US clients hide accounts from the IRS, even after the firm paid $2.6 billion in penalties in 2014 and promised to stop the practice.
AFRICAN CONTINENTAL FREE TRADE AREA (AFCFTA) COULD BOOST MARITIME TRADE IN AFRICA
On 23 November, Hellenic Shipping News reported that the AfCFTA free trade agreement, under which trading started in January 2021, aims to increase intra-African trade by eliminating import duties – and to double this trade if non-tariff barriers are reduced. UNCTAD estimates that the agreement could boost intra-African trade by about 33% and cut Africa’s trade deficit by 51%. It is said that a study by the UN Economic Commission for Africa with a time horizon of 2030 indicates that cargo transported by vessels would increase from 58 million to 132 million tons with the implementation of AfCFTA. The study says Comoros, Gabon, Gambia, Ghana, Madagascar, Mauritius, Mozambique, Namibia and Somalia will experience a surge in traffic through their ports by 2030 as a result of AfCFTA. Africa’s contribution to global containerized trade remained relatively low in 2020, with container ports on the continent holding a 3.9% share of global container port traffic, compared to Asia with nearly two-thirds and Europe with 14.9%.
MALTA: OLAF REPORT PRESENTED WITH MISSING DOCUMENTS IN DALLI SISTERS’ MONEY LAUNDERING CASE
On 23 November, Malta Today reported that daughters of former EU Commissioner the John Dalli are accused of running a $600,000 Ponzi scheme which defrauded several American pensioners of their life savings. The case has been ongoing since 2018, originally against the Dalli siblings along with 4 others, who were all charged with fraud, misappropriation, forgery and making false declarations to a public authority. The case continues in February.
GERMAN POLICE RAID MONEY LAUNDERING GANGS AND BIKERS
On 23 November, Deutsche Welle reported that police in the western German state of North Rhine-Wesphalia have carried out 2 large anti-crime operations. One targeted money laundering gangs, the other, local biker gangs in a case of attempted murder. The raids took place as part of an international operation. The EU police agency, Europol, was also involved; several arrest warrants had been executed in NRW. Raids were also carried out in Italy, Switzerland and the southern German states of Bavaria and Baden-Württemberg, with Italian financial police saying they had arrested 22 people and confiscated some €41 million in real estate, cryptocurrencies and in bank accounts.
SPACE LAW HASN’T BEEN CHANGED SINCE 1967 – BUT THE UN AIMS TO UPDATE LAWS AND KEEP SPACE PEACEFUL
On 23 November, an article in The Conversation said that the UN General Assembly First Committee which deals with disarmament, global challenges and threats to peace that affect the international community. 1 November, it approved a resolution that creates an open-ended working group. It explains that activities in space are governed by the 1967 Space Treaty which is currently ratified by 111 countries. The treaty was negotiated in the shadow of the Cold War when the Soviet Union and the US had spacefaring capabilities. It offers broad principles to guide the activities of nations, and it does not offer detailed “rules of the road”. The article says that, essentially, the Treaty assures freedom of exploration and use of space to all humankind. There are just 2 caveats to this, and multiple gaps immediately present themselves. The Treaty does specifically prohibit placing nuclear weapons or WMD anywhere in space, it does not prohibit the use of conventional weapons in space or the use of ground-based weapons against assets in space. Finally, it is also unclear if some weapons – like China’s new nuclear-capable partial-orbit hypersonic missile would be caught by the Treaty.
On 23 November, an article from Field Fisher follows new guidance from the EU authorities, saying that, in a post-Schrems era, understanding what constitutes a transfer of personal data is not a trivial question. Data flows which do not amount to a data transfer under the meaning of Chapter V of the GDPR will not be subject to restrictions, including those deriving from Schrems.
US TERMINATES ACTIONS ON DIGITAL SERVICES TAXES (DST) INVOLVING AUSTRIA, FRANCE, ITALY, SPAIN AND UK AND ANNOUNCES DST AGREEMENT WITH TURKEY
A Client Alert from Wilmer Hale on 23 November explained that, in essence, the US has lifted the threat of retaliatory tariffs — citing a political agreement reached between the US Treasury and the 5 countries that is expected to lead to the withdrawal of each country’s DST. It also announced that it will monitor implementation of the political agreement in coordination with Treasury. It further explains that the agreement with Turkey that provides that the same terms that apply under the political agreement with the other countries will also apply with respect to Turkey’s DST.
FAMED RUSSIAN CHILDREN’S CAMP COMPLEX PLAGUED BY CORRUPTION
On 23 November, Rferl reported on an investigation into a famed Russian camp complex near the Black Sea shore were suffering from bad food, squalid bathrooms, shoddy accommodations, bedbug-infested mattresses, among other things. The state-subsidised Orlyonok complex is where as many as 20,000 school-age children and teenagers attend programmes annually. The investigation claims that there was a scheme of inflated contracts with contractors and suppliers, exorbitant compensation for its general director, and posh, free-of-charge accommodations for VIP guests.
SPAIN ENACTS FIRST LEGISLATION TO REGULATE CRYPTOCURRENCIES
On 23 November, an article from White & Case said that the Bank of Spain created the registry where service providers for both the exchange of virtual currency for fiat currency and the custody of electronic wallets must register under a law enacted in April.
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A report from The Wild Parrot Trust says that the trade in wild parrots increasingly relies on social media platforms, and it analyses the online trade in wild parrots over a 4-year period provides new insights into the scope and scale of the trade, trade routes, modes of transport and compliance with national and international laws and agreements.
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On 22 November, FATF-style regional body CFATF released the 3rd enhanced follow-up report for Antigua & Barbuda. The country saw its mutual evaluation report released in 2018. CFATF the CFATF has re-rated the country in relation to FATF Recommendation 7 from Non-Compliant to Partially Compliant; Recommendations 22 and 40 from Partially Compliant to Largely Compliant; Recommendations 28 and 37 from Partially Compliant to Compliant; and Recommendation 2 from Largely Compliant to Compliant. Therefore, Antigua and Barbuda is now Compliant with 11 Recommendations and Largely Compliant on 25 on FATF Recommendations. As usual, the report does not address effectiveness ratings. Antigua and Barbuda will remain in enhanced follow-up on the basis that it had a low or moderate level of effectiveness for 7 or more of the 11 effectiveness outcomes (aka “Immediate Outcomes” or IO) and will continue to inform the CFATF of progress achieved on improving the implementation of its AML/CFT measures.
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On 22 November, the House of Commons Library published a briefing about a new levy that will first be charged in the financial year running from 1 April 2022 to 31 March 2023 on any medium, large and very large entities regulated for AML purposes at any point during that year.
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Panama Covid-19 update – well, I had my booster shot today, and it occurred to me that if we continue to need such boosters the authorities are going to produce bigger vaccination record cards…
The number of active cases has risen again, though the increase has slowed, with only 27 additional cases added today, taking the total to 2,455. There were 132 new cases reported and 1 new fatality. However, the numbers of those in hospital (and hospital-hotel quarantine) have fallen – with 20 in ICU, 90 in other wards and 74 in the hotels.
22 NOVEMBER 2021
THE CUM-EX TAX SCANDAL – A STATE PROSECUTOR HUNTS THE “TAX MAFIA”
On 27 October, Deutsche Welle released a 42-minute documentary saying that the scandal is like something out of a thriller movie. The players in the tax scandal are powerful bankers, executives, top-tier lawyers, and even, perhaps, German politicians…along with the state prosecutor who’s on their trail. The documentary shows the people behind the investigation of the biggest tax scandal in German history, and asks how states can protect public money from unscrupulous financial predators.
On 8 October, the UN released this Report draws the attention of the international community to urgent human rights concerns and urges all relevant parties to take concrete steps towards finding a peaceful resolution to the long-standing conflict on the Korean Peninsula. It recommended that the UN Security Council consider lifting sanctions that negatively affect humanitarian assistance and human rights in North Korea and conduct a study of the detrimental impact of sanctions on human rights and the on the humanitarian situation, particularly in the context of the COVID-19 pandemic.
WHAT DO THE FCPA, UK BRIBERY ACT, FRENCH OR GERMAN CRIMINAL CODES MEAN FOR DEALINGS WITH THIRD PARTIES?
On 16 November, an article from Reed Smith explains how the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and the French and German criminal codes apply to a company’s or individual’s dealings with third parties. A previous article covered who is subject to the FCPA, UK Bribery Act, French, German and Greek criminal codes.
UK: HM TREASURY HIGHLIGHTS ‘WEAKNESSES’ IN AML EFFORT
On 22 November, the Law Society Gazette reported that about 12% of the professionals supervised by AML authorities are ‘at risk’, according to the latest annual report of supervisory activity published by HM Treasury. The report covers the activities of the Solicitors Regulation Authority as well as bodies such as the FCA and Gambling Commission. The SRA is by far the largest of the 9 legal sector supervisory bodies – the Bar Standards Board has an AML population of 582.
ARMENIAN ANTI-GRAFT BODY INDICTS EX-PRESIDENT SARKISIAN
On 22 November, Azatutyun reported that Armenia’s new anti-corruption body has decided to bring charges against Serzh Sarkisian, subpoenaing the former president for interrogation as part of a yet undisclosed criminal case. A spokesperson for the Anti-Corruption Committee did not provide details as to the criminal case or what particular crime or crimes the third Armenian president is accused of.
NEW REPORT SAYS MILLIONS DUE TO CORRUPTION IN SOMALIA
On 22 November, Garowe Online reported that the country’s Auditor General has said that millions are missing from key departments of the federal government.
NETHERLANDS: NEW LEGAL INSTRUMENTS FOR THE CONFISCATION OF CRIMINAL ASSETS
On 17 November, a news release from the Dutch Government advised that the government will introduce legislation to provide additional legal means to confiscate criminal assets. It will make it possible to confiscate money and property originating from criminal activity without first having to obtain a criminal conviction; and also introduces the instrument of an emergency asset freeze on financial transactions to prevent criminal money being siphoned off.
A SUSPECT ARRESTED IN VANCOUVER IN THE ASSASSINATION OF A MAN ALLEGED TO HAVE BEEN CANADA’S MOST PROLIFIC MONEY LAUNDERER
In his blog on 21 November, Kenneth Rijock reported that a suspect has been arrested in Vancouver in the assassination of Jian Jun Zhu, alleged to have been Canada’s most prolific money launderer. The suspect is accused of killing Jian back in September, whilst he was dining at a Japanese restaurant in Richmond, British Columbia.
CHINA STOPS CONSTRUCTION OF SECRET UAE PORT PROJECT AFTER US RAISES CONCERNS
On 22 November, Eurasia Review reported that China stopped construction of a secret port project in the UAE after US intelligence agencies suspected it was a military facility
FURLOUGH FRAUD FEARS HIGHLIGHT NEED FOR ROBUST WHISTLEBLOWING POLICIES
An article from Out-Law on 19 November said that the case of a recruitment agency alleged to have falsely claimed furlough money from the government shows the importance of robust internal whistleblowing policies and procedures.
THE ‘ZELLE FRAUD’ SCAM: HOW IT WORKS, HOW TO FIGHT BACK
On 19 November, the Krebs on Security blog carried a post explaining that one of the more common ways cybercriminals cash out access to bank accounts involves draining the victim’s funds via Zelle, a P2P payment service used by many financial institutions that allows customers to quickly send cash to friends and family.
APG VIRTUAL PLENARY ADOPTS MUTUAL EVALUATION REPORT ON VIETNAM
On 22 November, FATF-style regional body APG said that it had concluded its 2021 special plenary hosted in virtual format by the Government of Australia. The principal outcome of this special plenary meeting was the adoption of the Vietnam Mutual Evaluation Report. The onsite visit to Vietnam took place in November 2019 and the finalisation of the report was delayed due to travel restrictions related to the COVID-19 pandemic.
COUNCIL OF EUROPE ADOPTS ADDITIONAL PROTOCOL TO TACKLE CYBERCRIME
On 17 November, EurActiv reported that ministers at the Council of Europe, the international human rights body, had adopted the second Additional Protocol to the Budapest Convention to tackle the current surge in cybercrime. The Convention is described as one of the most important international treaties on cybercrime and is ensuring a common criminal policy approach and fostering international cooperation. The Second Additional Protocol is said to modernise the Convention to make it ready for the challenges of the 21st Century. The article points out that the EU has a number of different sector-specific Regulations and Directives in development to tackle cybercrime, and that they are all built on the provisions set out in the Budapest Convention.
FORMER LONDON AND MIAMI ART DEALER PLEADS GUILTY TO DEFRAUDING ART BUYERS AND FINANCERS OF MORE THAN $86 MILLION
A news release from US DoJ on 18 November advised that Inigo Philbrick, 34, a US citizen previously residing in London, and an art dealer specialising in postwar and contemporary fine art with galleries in London and Miami has pleaded guilty to one count of wire fraud for perpetrating a multi-year scheme to defraud various individuals and entities in order to finance his art business.
NEW MOBILE REPORTING APP IS HELPING COMBAT CORRUPTION AND WILDLIFE TRAFFICKING IN THE AVIATION INDUSTRY
On 18 November, TRAFFIC reported on Wildlife Sentinel, an app to help staff at airports, airlines, and other aviation companies report suspected wildlife trafficking and corruption. Released by Crime Stoppers International, the app is already being used by aviation personnel with many reports providing indicators of wildlife crime.
UK: REPORT A BUSINESS THAT IS NOT REGISTERED FOR MONEY LAUNDERING SUPERVISION
On 22 November, HMRC issued updated information explaining how to find out if a business has registered with HMRC under the Money Laundering Regulations and how to report them if they have not.
AUSTRALIA: MAN CHARGED WITH MONEY LAUNDERING, AFTER SEIZURE OF $4 MILLION BY POLICE
On 22 November, 9 News reported that a man in his 20s has been charged with money laundering, and of breaching a COVID-19 public health direction after allegedly crossing a state border with $4 million in his boot.
SEC ENFORCEMENT REPORT TOUTS VOLUME OF NEW ACTIONS AND INCREASE IN PENALTIES
On 19 November, an article from Cadwalader Cabinet reported that the SEC said there had been over 450 new enforcement actions in fiscal year 2021, with a wide variety of actions taken. The new actions filed brought the total number of actions to 697, representing an increase of 7% over new actions brought in fiscal year 2020, but a decrease in overall actions compared with the 6 prior years. The report also found a 33% decrease in disgorgements compared with the prior fiscal year, but a 33% increase in fines.
A MULTIDIMENSIONAL STRATEGY FOR STRENGTHENING AMERICA’S CRITICAL MINERALS SUPPLY CHAIN
This report from the Wilson Center is said to show that extraction of critical minerals suffers chronic underinvestment in the US because it’s perceived as ecologically unfriendly, politically fraught, and extremely long term. Obtaining the required permits for a new mine can take up to 10 years because it often involves multiple jurisdictions, and political, and legal challenges. It says that the US is at a distinct disadvantage vis-à-vis China in securing access to the metals and rare earth elements that are vital for the energy transition and for geopolitical ambitions.
On 22 November, a news release from US Immigration and Customs Enforcement advised that, in conjunction with the Department of State, it had repatriated a trove of stolen artifacts to the Republic of Mali. The artifacts were detected in March 2009, when US Customs and Border Protection encountered a suspicious container at the Port of Houston. The container, which originated from Mali, claimed to be carrying replica cultural items.
On 8 October, World Political Review published this report saying that the gold trade boomed, even as the pandemic closed other businesses. However, much of the gold comes from smuggling, from neighbouring states – in 2019, the central bank estimated that only 10% of the country’s gold exports originated in the country.
EL SALVADOR IS PLANNING TO BUILD A TAX-FREE BITCOIN UTOPIA USING VOLCANIC POWER
On 22 November, Oil Price.com reported that the Bitcoin-friendly president of El Salvador has said at a Bitcoin investment summit that his country plans to build the first “Bitcoin City”. He said that Bitcoin City will rely on geothermal energy from nearby volcanoes, and it will be tax-free except for VAT.
On 22 November, Eurasia Review reported that, with about 3,100 African, European and US soldiers deployed to the Cabo Delgado province, the security situation is beginning to stabilise in Mozambique.
MORE TRANSPARENCY NEEDED TO TACKLE TAX EVASION VIA THE NETHERLANDS
On 22 November, Dutch News reported that the Netherlands remains an attractive place for companies and criminals to avoid tax and to hide cash by using shell companies, despite efforts to tackle the problem, according to a government commission. In 2019, the Netherlands was home to some 12,400 “letter box” companies, with a value of €4,500 billion. The commission estimates that shell companies have created just 3,000 to 4,000 jobs and account for less than 1% of the country’s tax income. Instead, multinationals and their tax advisors have been the main beneficiaries.
‘FAT LEONARD’ — CENTRAL FIGURE IN US NAVY CORRUPTION CASE — BREAKS SILENCE ON PODCAST
On 22 November, Stars & Stripes, the US forces newspaper, reported that Leonard Glenn Francis has been under house arrest in San Diego for several years. However, he has now secretly recorded a 9-part podcast with a Singapore-based journalist, offering for the first time publicly his own account of the bribery scandal that has rocked the Navy, led to the prosecution of dozens of military officials and put hundreds more under scrutiny. The term “Fat Leonard” is said to refer to his imposing physique and was a long-time nickname in military circles in ports across SE Asia.
AUSTRALIA: WOMAN STOLE $940,000 FROM EMPLOYER TO SPEND ON GAMBLING APP
On 22 November, ABC News reported that a Tasmanian woman has pleaded guilty to stealing the money to fund her addiction to an online gambling game that does not pay out real money. She was an account manager at the Tasmanian Veterinary Hospital between 2016 and 2019.
US – COUNTERING THE RANSOMWARE THREAT: A WHOLE-OF-GOVERNMENT EFFORT
A post on Lawfare on 22 November says that the US Government has begun to leverage a range of criminal, diplomatic, economic and military capabilities in order to combat the ongoing ransomware threat. The post sets out post to provide an account of how the Biden Administration is going about the business of countering the ransomware threat through a whole-of-government approach. This includes initiatives and actions by the DoJ, the US Treasury Department, the Department of Homeland Security and other agency-specific efforts. In an effort to begin to assess the efficacy of these activities, this post will also describe the impact such efforts appear to be having on at least some ransomware threat actors, most notably the decision by REvil to take itself “offline” and the ripple effects in the ransomware ecosystem stemming from that action.
On 17 November, a report from Insight Crime reports on an investigation which exposes how the Maduro regime’s attempts to control Venezuela’s mining heartland in the state of Bolívar has led to criminal chaos, as guerrilla groups, heavily armed gangs and corrupt state elements battle over the country’s gold. This includes Colombian guerrillas’ involvement in illegal mining in Venezuela, with indigenous communities have reported incursions into illegal gold mines by dissidents from the Revolutionary Armed Forces of Colombia (Fuerzas Armadas Revolucionarias de Colombia or FARC) for at least 5 years, and another Colombian guerrilla group – the National Liberation Army (Ejército de Liberación Nacional or ELN) is also present. But these are only 2 of a number of groups involved.
On 22 November, Front Page Africa reported that the FIU had presented the NRA to the Liberia bankers’ Association. The NRA was released in September and major outcomes of the NRA show Liberia’s money laundering risks as high in the financial sector as well as for DNFBP. However, it also reveals that Liberia’s terrorist financing risk is low.
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On 22 December, OFAC announced that it had designated Ismatullah Khalozai, an individual who has acted as a financial facilitator for the Islamic State’s Khorasan Province (ISIL-Khorasan), active in Afghanistan and commonly referred to as “ISIS-K”. The designation, in coordination with the Department of State, also sees Sanaullah Ghafari, Sultan Aziz Azam, and Maulawi Rajab designated as Specially Designated Global Terrorists (SDGT) for their roles as leaders of ISIS-K.
At the same time, OFAC has made a number of deletions from its SDN List, and amended a number of others. A news release from the US Treasury refers those seeking information on the process for seeking removal from any OFAC list, including the Specially Designated Nationals and Blocked Persons List, to FAQ 897.
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This Index set out to assess the quality of institutional controls to manage the risk of corruption in the defence and security institutions. It rates countries from Band A (New Zealand), with a very low risk, to Band F (featuring 18 countries) with a critical risk. It is said to be the world’s leading assessment of corruption risks in government defence institutions.
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A report from The Sentry says that although President Joseph Kabila’s final term as head of the DRC was set to end in December 2016, he clung to power and delayed elections for another 2 years. Meanwhile, his brother Francis Selemani purchased numerous luxury homes in the US and South Africa, it appears at least in part using funds diverted from the government. Selemani was MD of BGFIBank DRC, the Congolese subsidiary of Gabon-based BGFIBank Group. It is claimed that Selemani and the Kabila family used a network of companies and the bank they controlled to misappropriate public funds, transferring millions abroad and purchasing millions of dollars in foreign real estate.
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Panama Covid-19 update – 1 new fatality and 162 new cases reported today, with the number of active cases up again, though only by 25, to 2,428. There are 21 patients in ICU and 93 in other wards.
21 NOVEMBER 2021
SAUDI ARABIA: ATTEMPTS TO SMUGGLE OVER 3,000 BOTTLES OF WINE INTO JEDDAH
On 20 November, Zawya reported that Saudi customs authorities have foiled an attempt to smuggle 3,612 bottles of wine into Saudi Arabia via Jeddah Islamic Port.
SOUTH AFRICA: ALLEGED RINGLEADER IN GOLD SMUGGLING AND MONEY LAUNDERING RACKET WAS ARRESTED ON SIMILAR CHARGES BEFORE
On 16 November, IOL reported that Gregory Fourie, one of the men accused of running a multi-million-rand gold smuggling syndicate was out on bail when he was arrested by the Hawks. According to reports, Fourie was arrested in November 2019, on similar charges. He and 4 others are facing charges ranging from theft to illegal dealing and possession in unwrought gold.
TORONTO: NEARLY $30 BILLION IN HOUSING LINKED TO MONEY LAUNDERING
On 17 November, an article from Storeys reported that billions of dollars in real estate transactions in the greater Toronto area alone can be tied to money laundering, according to a 2019 study. The study found multiple risk indicators in real estate, including that different corporations acquired nearly $30 billion in local housing between 2008 and 2018, the majority of which was privately owned with no information on beneficial owners provided.
US ANNOUNCES SEX-TRAFFICKING CHARGES AGAINST DUTERTE ALLY
On 19 November, CNN reported that US prosecutors have announced sex-trafficking charges alleging that girls and young women were coerced to have sex with the founder of a Philippines-based church who is a friend and adviser to President Rodrigo Duterte of the Philippines. Charges have been filed against charges Apollo Carreon Quiboloy, founder of a church called Kingdom of Jesus Christ, The Name Above Every Name (KOJC) and other church officials, including 2 US-based church administrators.
AUSTRALIA: CROWN CASINO AND MONEY LAUNDERING MISDEEDS
On 9 November, Transparency International Australia published an article following the recommendation of the Victorian Royal Commission into Crown Casino in Melbourne that it be allowed to keep its licence – albeit under a 2-year grace period during which a special manager should ‘oversee the affairs of the casino operator including the casino operations’.
IRELAND: CENTRAL REGISTER OF BENEFICIAL OWNERSHIP FOR ICAV AND UNIT TRUSTS
On 18 November, an article from LK Shields says that a central Register of beneficial ownership for certain financial vehicles, namely ICAV, unit trusts and credit unions, became a legal requirement under Irish Regulations published in 2020. The register was created for AML purposes and the article outlines the requirements for certain financial vehicles (CFV) under the 2020 Regulations and the penalties for non-compliance.
MIAMI MAN USED HIS DORMANT BUSINESS AND SOLD CONDO FOR A $920,000 COVID-19 RELIEF FRAUD
On 21 November, the Miami Herald reported that Carlos Vazquez’s Big League LLC was a dormant business when the COVID-19 pandemic began in 2020. So, it asks, how did Big League have 64 employees, pay them $4.425 million during the 2019 tax year and become eligible for a Paycheck Protection Program loan of $921,875? Vazquez, 57, has been sentenced to 3½ years in federal prison and $921,875 in restitution.
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On 20 November, RFA reported that the Center for Strategic and International Studies (CSIS) says that for years China has been funding the expansion of the militia to assert its claims in the South China Sea, and that now hundreds of Chinese maritime militia vessels are operating in contested areas of the South China Sea on a consistent basis, posing a significant challenge to “maritime order rooted in international law”. A new report provides a comprehensive profile of a force that it says has been operating alongside Chinese law enforcement and military to achieve Chinese political objectives in disputed waters. It concludes that “the majority of Chinese fishing vessels in disputed areas of the South China Sea do not operate as independent commercial actors but instead as paid agents of the Chinese government obligated to help fulfil its political and national security objectives”.
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On 21 November, Malta Independent carried an article which seeks to explain in more detail the difference between the FATF and Moneyval evaluations, what led to the grey listing, and the focus areas where Malta lacked. It explains that, in view of the results obtained on effectiveness in its 2019 assessment, Malta was placed under the scrutiny of a FATF working group called the International Cooperation Review Group (ICRG), meaning that the country’s progress would be monitored by both MONEYVAL and the FATF. The scope of the follow-up conducted by the 2 bodies is different – while MONEYVAL focuses on the progress made by the country on its technical shortcomings, FATF monitors the country’s ability to improve its effectiveness in implementing the laws and procedures. It is said that the efforts being made to remove Malta from the grey list will be discussed during an in-depth interview with FIAU Deputy Director Alfred Zammit, which will be published on 5 December.
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Panama Covid-19 update – re the recent increase in active cases, the authorities have indicated that this occurs as a result of the movementof people to different parts of the country on the occasion of the national holidays at the beginning of the month. Let’s hope they are right, and it is a temporary blip.
Meanwhile, active case numbers are up again, by 159 to 2,403. there were 258 new cases reported today (the highest daily number since the end of September) and 2 new fatalities. There are 22 patients in the ICU and 94 in other wards.
20 NOVEMBER 2021
PANAMA: FORMER PROVINCIAL GOVERNOR JAILED FOR 10 YEARS FOR FRAUD
On 19 November, Newsroom Panama reported that businessman and former governor of Coclé, Richard Fifer, had been sentenced to 10 years in prison, followed by a further 10 years ban from public office. The fraud involved false representations over mining exploration.
On 19 November, the Washington Examiner reported that authorities in Mogadishu had seized 6 disassembled drones. Subsequent Turkish pressure forced Somali authorities to release the Turkish engineers who accompanied the shipment, who claimed that the drones were for agricultural purposes. The article also claims that Turkey has helped build a drone base manned by both Turkish and Somali intelligence operatives adjacent to Somalia’s National Intelligence and Security Agency.
IRAN’S REVOLUTIONARY GUARDS SEIZE FOREIGN DIESEL-SMUGGLING SHIP IN GULF
On 20 November, the Times of Israel and others reported that the Revolutionary Guards said that they had seized a vessel smuggling diesel in the Gulf and arrested its 11 foreign crew members. They did not specify either the date of the seizure, the nationality of the boat or its crew, or further details about the vessel and its origin.
IMF ON TRINIDAD & TOBAGO:PROGRESS IN STRENGTHENING THE AML/CFT FRAMEWORK IS WELCOME BUT FURTHER ACTIONS ARE NEEDED
On 19 November, the IMF reported on the outcomes of its Article IV mission, an inspection of Trinidad & Tobago. Amongst its conclusions were that its removal from the FATF monitoring list in February 2020 is commendable. The authorities were encouraged to make further efforts to strengthen the AML/CFT framework, including registering beneficial ownership, finalising amendments to the public procurement Act, and adopting risk-based AML/CFT supervision. It is also said to be essential to make similar progress on resolving issues related to the EU blacklist and the OECD’s Global Forum requirements on tax transparency and exchange of information.
ETHIOPIA NOW CONFIRMED TO FLY CHINESE ARMED DRONES
On 19 November, Pax for Peace in the Netherlands reported that high resolution satellite imagery from November 2021 now confirms the presence of Chinese Wing Loong drones in Ethiopia. Despite claims made last year of Chinese drones flown by the UAE from a base in Eritrea, no proof had been found of these drones were actually deployed over Ethiopia.
PANDORA PAPERS: UAE A GO-TO OFFSHORE HAVEN FOR AFRICA’S POLITICAL AND BUSINESS ELITE
On 16 November, ICIJ reported that the Pandora Papers discovered secretive Emirati financial interests of politicians and powerful business leaders from 17 African countries.
PANDORA PAPERS REVEAL EMIRATI ROYAL FAMILIES’ ROLE IN SECRET MONEY FLOWS
The ICIJ on 16 November reported that that the real owners of the offshore companies sold to clients who prefer to keep their identities under cover include a raft of shady players in the offshore world.
DRONES IN UKRAINE: TRACING KEY COMPONENTS FOR RUSSIAN-MADE MILITARY UAV
This Case Study from Conflict Armament Research looks at 6 different Russian-manufactured military unmanned aerial vehicles (UAV – commonly called ‘drones’) that CAR documented in Ukraine. Its investigations found that the Russian military industry has been obtaining key components for these UAV – such as GPS modules, electronic parts, cameras, and engines – from the US, Asia, the Middle East, and the EU, both before and after the start of the conflict in Ukraine in 2014, and despite an EU arms embargo on Russia.
DR CONGO PRESIDENT DEMANDS AUDIT OF MINING REGISTRY TO FIGHT FRAUD
On 20 November, Reuters and others reported that the Democratic Republic of Congo President has demanded a ban on issuing and trading mining permits until the country’s mining registry has been audited, a measure aimed at combating fraud within the sector. The DRC is the world’s top producer of cobalt and Africa’s biggest copper producer, but more than 70% of its roughly 100 million people live on less than $1.90 per day, according to the World Bank.
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The RAND Corporation has published a report which examines Russian arms exports and the impact of sanctions designed to discourage third country purchases and raise the cost of future Russian malign interference in other nation-states. It contains 65 cases in 33 countries of Russian arms export negotiations and sales, beginning in July 2017 and ending in May 2021; and these cases illustrate that the monetary value of lost Russian arms sales due to US diplomatic efforts buttressed by the prospect of third-party sanctions is difficult to determine with precision. While making further recommendations, the report concludes that there is no question that the “chilling effect” has resulted in Russia losing arms sales; and countries such as Vietnam and India face formidable challenges in quick diversification away from Russian systems.
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On 20 November, the Globe & Mail reported that while dozens died when Champlain Towers South fell apart this Summer, by then its Canadian developers were long dead – but it says that records tell the story of dubious tactics used to create a property empire from Toronto to Florida.
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Panama Covid-19 update – the number of active cases continues a slow rise, with another 97 more taking the current figure to 2,244. 208 new cases have been reported, but no new fatalities. The number of those hospitalised has actually fallen, with 21 in ICU and 102 in other wards.
Slightly more worrying, perhaps, is the first sighting of Santa in the huge Albrook Mall today
19 NOVEMBER 2021
FATF “GREY LISTS” TURKEY, CITING CONCERNS WITH TURKEY’S BANKING AND REAL ESTATE SECTORS AND POTENTIAL TERRORISM FINANCING
On 18 November, a post on the Compliance & Enforcement blog from the Program on Corporate Compliance and Enforcement at the New York University School of Law says that FATF has added Turkey to its list of jurisdictions subject to increased monitoring (also known as the FATF “Grey List”). Turkey is the largest economy to be included on the Grey List. The post provides more detail on FATF’s action and its implications.
On 17 November, A&L Goodbody reported that while this Bulletin is directed at the Funds sector, the CBI advises designated persons operating in other sectors to “take note” of the Bulletin and “consider its relevance” to their sector. All firms, regardless of sector, are expected to “critically assess” their anti-money laundering/countering the financing of terrorism and financial sanctions frameworks (AML/CFT/FS) against the CBI’s expectations. It says that the CBI has identified weaknesses in 4 key areas and firms must introduce “enhancements” in these areas in order to ensure they can “sufficiently demonstrate compliance” with the requirements of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. A number of firms engaged with by the CBI had no Business Risk Assessment in place.
On 17 November, Nikkei Asia carried an article saying that the shackles on movement have accelerated the decline of Hong Kong’s lucrative status as a regional business hub. It is said that it might be tempting to think that the impact of the travel ban will be limited. After all, it will eventually be lifted. Perhaps, but what about the financial institutions and foreign media organizations that have pulled up their stakes and left for such destinations as Singapore and Seoul?
UK: PAYMENTS SYSTEMS REGULATOR PLANS TO HELP VICTIMS OF AUTHORISED PUS PAYMENT (APP) FRAUD
On 17 November, the BBC reported on the plans by the government to help victims of fraud who are tricked into transferring money to con-artists. They will be legally entitled to compensation, under government plans.This type of fraud rose by 71% in the first half of the year. At present, refunds by banks are governed by a voluntary code which consumer groups argue has been a lottery for scam victims. A total of £355 million was lost through so-called authorised push payment (APP) fraud cases in the first half of the year. Victims pay fraudsters who they believe are genuine organisations, such as banks, the police, or solicitors.
REPORT CLAIMS ILLEGAL GAMBLING BOOMED IN ITALY DURING PANDEMIC
On 18 November, iGB reported that an official report estimates the value of Italy’s illegal gambling in 2020 as €18 billion, a significant increase on the 2019 estimate of €12 billion, and the illegal market could top €20 billion by the end of 2021. It also said that enforcement action by Italian authorities was ramped up in recent months.
ARE TRADE FINANCE FIRMS FAILING TO TACKLE CRIME RISKS?
A post from Risk Screen on 18 November said that UK trade finance firms are failing to assess their financial crime risks adequately, according to regulators. Experts say trade finance firms also lack the skills and technology necessary to achieve adequate compliance. The FCA said it found several failures in the anti-financial crime regimes of companies it inspected recently and warned firms to increase their efforts. This follows several high-profile failures of trade finance firms over the last 18 months, with significant financial losses.
PAKISTAN: DRIVE TO CURB TYRE SMUGGLING LEADS TO PRICE RISES
On 19 November, Business Recorder says that that the anti-smuggling drive has affected consumers because of a price hike of tyres. It is said that local manufacturers are unable to meet the demand, and that importers are avoiding imports due to rupee devaluation and increase in duties while the entry of smuggled tyres has become next to impossible due to the actions of the customs authorities.
US: ART DEALER PLEADS GUILTY TO $86 MILLION FRAUD SCHEME
On 18 November, BNN Bloomberg reported that Inigo Philbrick, 34, a once high-flying international art dealer has pleaded guilty to selling the same works to multiple collectors. He agreed to forfeit almost $87 million to the government as part of a plea agreement reached with federal prosecutors in Manhattan.
LIFTING THE VEIL OF SECRECY: PERSPECTIVES ON INTERNATIONAL TAXATION AND CAPITAL FLIGHT FROM AFRICA
This book says that capital flows to tax havens are one factor limiting the benefits of economic growth for ordinary Africans. It is estimated that African countries, relative to the size of their economies, lose more in corporate tax evasion than countries anywhere else in the world. It analyses some of the main issues surrounding illicit financial flows, in particularly concerning tax havens.
THE PERIL OF POORLY DONE ENHANCED DUE DILIGENCE (EDD)
An article from Thomson Reuters was the first of a 2-part article marking UN International Corruption Day on the critical issues around enhanced due diligence (EDD) protocols. It distinguished between CDD or KYC and EDD. It argues that with a shifting workforce, disrupted operations, and supply chain issues, many organisations may be compelled to do business with entities they would not previously have considered.
LIECHTENSTEIN CONFIRMS PROBE INTO LEBANON’S CENTRAL BANK GOVERNOR
On 18 November, OCCRP reported that Liechtenstein’s judicial authorities have a “pending money laundering investigation” in relation to Lebanese central bank governor Riad Salame. Liechtenstein’s chief prosecutor declined to provide further details.
EUROPEAN COMMISSION PROPOSED NEW REGULATION TO CURB THE EXPORT OF WASTE TO THIRD-PARTY COUNTRIES
On 18 November, Jurist reported that the Regulation will cover all waste, not just those forms of waste that are traditionally understood as hazardous. Exporters will be encouraged to export waste only to countries within the OECD. Shipments will be supervised and suspended if they “generate serious environmental problems” in the destination country. Exports to non-OECD countries will be further restricted.
US CUSTOMS SEIZE 1,000 COUNTERFEIT AND POTENTIALLY DANGEROUS SOLAR PANELS FROM CHINA
A news release from US Customs & Border Protection on 18 November advised that officers at Baltimore had inspected and detained the shipment of 365-watt crystalline silicon photovoltaic modules from China on 23 September. CBP import specialists then worked with trademark holders to verify the solar panels’ authenticity. The solar panels displayed a counterfeit safety certification marking presented a very real and a very serious concern to the health and safety of consumers.
WANTED ALBANIAN BUSINESSMAN TELLS MEDIA HE WILL FACE JUSTICE
On 19 November, Exit News reported that Rezart Taci, a businessman and ex-media mogul wanted by Albanian authorities on charges of money laundering, has told the media he is ready to hand himself in and face the courts. Authorities claim he worked with 2 Italian citizens, connected to the mafia, to launder the money into Albanian banks while taking a cut.
NEW AUSTRAC FINANCIAL CRIME GUIDE TARGETS TECHNOLOGY-FACILITATED ABUSE
On 19 November, AUSTRAC released a new financial crime guide designed to help businesses understand, identify and report technology-facilitated abuse through financial transaction payment text fields. AUSTRAC has seen an increase in the use of these fields to stalk, harass or threaten victims, in an attempt to avoid law enforcement scrutiny.
CANADA: YOUTH CHARGED AFTER $46 MILLION IN CRYPTOCURRENCY STOLEN FROM US RESIDENT
On 17 November, CBC reported that a youth has been charged in the theft of $46 million in cryptocurrency after investigators learned some of it was put toward buying a gaming username. Local police worked with the FBI and US Secret Service to investigate millions in missing currency stolen via what’s known as a SIM-swap attack.
Comply Advantage has released this Guide, saying that while traditional financial institutions now recognise the importance of investing in innovative, online solutions, it is digital banks that customers still associate with fast, convenient access to banking services; and that challenger and neobanks banks are projected to reach a market size of $471 billion by 2027 (up from $20.4 billion in 2019).
Comply Advantage has produced this Report, saying that sanctions regimes are becoming increasingly detailed, complex, and fluid. One is seeing more countries and international organisations use them as a tool of policy on a regular basis. It considers the key concepts and the chief sources of the sanctions, including the UN, EU and individual countries, including now China.
UK: PARLIAMENTARY COMMITTEE CONSIDERS IMPACT OF BELARUS SANCTIONS
On 6 August, the Regulatory Policy Committee reported on its scrutiny of an Impact Assessment (IA) submitted by the Foreign, Commonwealth and Development Office on the application of trade, financial and transport sanctions on Belarus, following the recent escalation of serious human rights violations. The IA estimates the resultant loss to UK business is £23.8 million. Belarus is the UK’s 110th largest trading partner in 2020, accounting for less than 0.1% of total UK trade, with the largest of impacts (£15.5 million) on the petrochemical sector, in the form of BNK (UK) – a UK company that is a subsidiary of the Belarusian state-owned enterprise, CJSC Belarusian Oil Company.
NICARAGUA LEAVES THE ORGANIZATION OF AMERICAN STATES (OAS)
On 19 November, TeleSUR reported that Nicaragua’s Foreign Affairs Minister has announced his country’s decision to leave the Organization of American States (OAS).
LOS ANGELES-AREA MAN WHO RAN MULTIMILLION-DOLLAR UNLICENSED BITCOIN EXCHANGE BUSINESS SENTENCED TO 3 YEARS IN FEDERAL PRISON
A news release from US Immigration & Customs Enforcement on 18 November advised that Hugo Sergio Mejia, 50, had an unlicensed business that exchanged at least $13 million in Bitcoin and cash, often for drug traffickers – May 2108 to September 2020.
On 15 November, Homeland Security Today reported that the Nigerian Maritime Administration and Safety Agency (NIMASA) has introduced new measures to check security threats in the Nigerian maritime domain and deter persons who may seek illegal means of entry into the country as stowaways. All ship captains are to submit the Security-Related Pre-Arrival Information forms to the Agency no later than 48 hours before the ship’s arrival at any Nigerian port. Other measures include proper pre-departure search and completion of pre-departure forms before departure from any port; switching on AIS; close monitoring of communication channels; and response to any VHF call from the Nigerian Navy or the Regional Maritime Rescue Coordination Centre.
SEYCHELLES: SUPREME COURT ORDERS COUPLE SUSPECTED OF LAUNDERING $50 MILLION HELD
A news release from the Seychelles News Agency advised that the Court has remanded for 14 days a Seychellois couple arrested on suspicion of money laundering $50 million. The Anti-Corruption Commission said the couple had set up a whole network, which allowed them to hide the money and then bring it back to Seychelles, an archipelago in the western Indian Ocean, to buy hotels.
On 19 November, Mercopress reported that Peru’s Presidential Secretary Bruno Pacheco has turned in his resignation claiming his decision was motivated “to avoid a smear campaign” against the head of state. The Prosecutor’s Office Specialized in Crimes of Corruption submitted a new complaint to the Public Ministry against Pacheco and those allegedly responsible for the crime of influence peddling.
US REBUFFS TALIBAN APPEAL TO CONGRESS TO RELEASE AFGHAN CENTRAL BANK ASSETS
On 19 November, VoA reported that the Taliban had published the so-called open letter calling on US lawmakers to unfreeze about $9.5 billion in Afghan foreign assets and end financial sanctions placed on Kabul after the Taliban takeover of the country in mid-August. The US has frozen the Afghan funds over human rights and terrorism concerns under the Taliban government.
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