On 28 March, HETQ in Armenia claimed that, since 2017, nearly 100 Armenians have helped a network of companies used by East European oligarchs to move millions of dollars, move assets from closed banks abroad, and pay for lobby services in the US.
UK: ECONOMIC CRIME PLAN 2023 TO 2026
On 30 March, the Home Office announced that the Government, law enforcement and private sector had agreed on a new plan to crack down on money laundering, kleptocracy and sanctions evasion. The Economic Crime Plan 2 is said to build on the foundations of its predecessor with new actions to improve the system-wide response to economic crime through enhanced cooperation between government, law enforcement, supervisory agencies and the private sector. The Plan provides for 475 new highly-trained financial crime investigators, spread across intelligence, enforcement and asset recovery at key agencies. This increased capacity will be targeted toward the detection and disruption of money laundering, and the recovery of an additional £1 billion in criminal assets over the next 10 years. The 3-year plan focuses on achieving tangible outcomes, and commits to –
- reducing money laundering and recovering more criminal assets;
- combatting kleptocracy and driving down sanctions evasion; and
- cutting fraud.
https://www.gov.uk/government/news/new-plan-puts-uk-at-the-forefront-of-fight-against-economic-crime
https://www.gov.uk/government/collections/economic-crime
https://www.gov.uk/government/publications/economic-crime-plan-2023-to-2026
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 29
A new company has been selected to run (initially for a 3-month probationary period) the troubled landfill site. In the light of recent events, one of the commitments included in this new concession is that the company has a plan for the mitigation and prevention of fires.
A report today says that 92.1% of cigarettes smoked in Panama come from illicit trade. this is according to the results of the latest Illegal Cigarette Market Study conducted in Panama in 2022 by Nielsen. This is said to represent a potential $300 million loss to the Government, more than 15 40-feet containers of illegal cigarettes being consumed in Panama each month. in some regions, the proportion of illicit cigarettes was over 96%. That all said, in my personal experience, the percentage of smokers in Panama apears less than in Britain and the rest of Europe.
While I have not got all the latest Covid-19 statistics to hand, we are told that, in the week ending 19 March, there were no deaths due to Covid, but that the number of new cases and active cases have shown another increase (new cases at 842, up from 702 the week before; and active cases up by around 200). Hopefully, the effect of the Carnivale holiday period will now start to decline.
29 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
INSIDE NORTH KOREA’S OIL SMUGGLING
On 29 March, the Financial Times published this report, subtitled “Triads, Ghost Ships and Underground Banks”. It follows the voyage of a tanker to North Korea. Making one of at least 23 trips there, or to its EEZ, since 2019. This report follows a joint investigation with RUSI, and shows how business leaders in Asia linked to organised crime have helped facilitate the delivery of oil to North Korea; naming the former business partner of one of Asia’s gambling tycoons, and a Macao-based businessman.
UK: IS YOUR LAW FIRM AT RISK OF PROLIFERATION FINANCING?
On 28 March, the Law Society issued updated guidance, saying that new legislation is bringing into force changes to solicitors’ AML obligations on assessing proliferation financing risk and reporting register discrepancies.
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 28
Looks like I was lucky with my US visa – not only did I get my appointment and visa in only a few weeks, having applied in February (and not the average 270 weeks that has been quoted!), but the fee for a visa is to go up in May, from $160 to $185. Collected the passport with the new visa in today and, if I was still doing immigration work then the photo on the visa would be enough to have me banned from entry (why are passport and visa photos so awful?).
A new survey says that men here say they want to earn at least $1,058 a month, while women’s say that they require $1,019 on average. It also says that technology and systems positions are those with the highest salary expectation, with mechanical engineering having the average salary required by applicants being $1,146.
28 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
SEA SHELLS: DEVELOPING BENEFICIAL OWNERSHIP TRANSPARENCY IN THE FISHING INDUSTRY
C4ADS has published this report which says that behind the 4 million commercial fishing vessels in the global fleet lies a complex onshore network of shell companies, frequently concealing the true beneficiaries of this industry. It says that recent policy actions have shifted toward holding accountable ultimate beneficial owners (UBO), instead of, or in addition to, individual vessels for IUU fishing: the individuals who are responsible for and receive the greatest financial benefit from fishing operations. The report explores how ultimate beneficial ownership information in the fishing industry is an important tool to address IUU fishing, improve transparency, and build accountability. It conducted the first full mapping of UBO for vessels flagged to Spain and Ecuador and map the trawler and purse seine fleets of the UK and Indonesia, respectively. This analysis reveals barriers to investigating UBO and identifies opportunities to standardise and improve reporting requirements. As an example, it provides snapshots, including one for the UK.
https://c4ads.org/wp-content/uploads/2023/03/SeaShellsBrief.pdf
UK SETS UP FAKE BOOTER SITES TO MUDDY DDoS MARKET
On 28 March, Krebs on security reported that the NCA has been busy setting up phony DDoS-for-hire websites that seek to collect information on users, remind them that launching DDoS attacks is illegal, and generally increase the level of paranoia for people looking to hire such services. The websites, which have so far been accessed by several thousand people, have been created to look like they offer the tools and services that enable cyber criminals to execute these attacks. Instead, users based in the UK will be contacted by the NCA or police and warned about engaging in cybercrime, and information relating to those based overseas is being passed to international law enforcement.
https://krebsonsecurity.com/2023/03/uk-sets-up-fake-booter-sites-to-muddy-ddos-market/
UK: DRAFT CODES OF PRACTICE ISSUED UNDER POCA 2002 AND THE TERRORISM ACT 2000
On 28 March, the Home Office advised that 3 existing codes of practice need to be updated and one new code of practice made to reflect possible changes made to the Proceeds of Crime Act 2002 (POCA) by the Economic Crime and Corporate Transparency Bill (ECCT Bill). Consultation on the changes lasts until 20 June.
FRENCH AUTHORITIES SEARCH OFFICES OF SEVERAL LARGE BANKS ON SUSPICION OF MONEY LAUNDERING AND FISCAL FRAUD
On 28 March, France 24 reported that authorities had searched offices of several large banks, including Societe Generale, BNP Paribas and HSBC on the suspicion of money laundering and fiscal fraud. A spokesperson said the probe was linked to dividend stripping and that were ongoing linked to so-called “cum-cum” practices, through which wealthy clients sought to evade taxes on dividends through complex legal structures.
ISLE OF MAN AND UK CONFIRM REMOVAL OF INDIVIDUAL FROM IRAQ SANCTIONS LIST
On 28 March, both the Isle of Man and the UK confirmed that AMIR HAMUDI HASSAN AL-SA’DI had been removed from sanctions lists following the decision of the relevant UN Sanctions Committee.
https://www.gov.im/news/2023/mar/28/financial-sanctions-iraq/
UK: LANDMARK SANCTIONS CHALLENGE FAILS
On 24 March, an article from MacFarlanes LLP in Ireland reported that a landmark challenge to a sanctions designation in the English courts has failed, but the case offers an interesting guide to both how sanctions are implemented in the UK and how they can be removed. The judgment offers key insights into the exercise courts will undertake when considering a challenge to designation; and the case stands as a unique reference point for sanctions designation challenges in the UK and will inform sanctioned parties of the approach the judiciary is expected to take going forward.
UK AND OFAC SANCTION SYRIAN REGIME AND LEBANESE ACTORS INVOLVED IN ILLICIT DRUG PRODUCTION AND TRAFFICKING
On 28 March, OFAC announced that it had taken action in coordination with counterparts in the UK to designate key individuals supporting the regime of Syrian President Bashar al-Assad and the production or export of Captagon, a dangerous amphetamine. The trade in Captagon is estimated to have become a billion-dollar illicit enterprise. Those designated include the so-called “King of Captogon”, Hassan Muhammad Daqqou, a Lebanese-Syrian dual national.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230328
https://home.treasury.gov/news/press-releases/jy1369
UK ALSO ADDS 11 INDIVIDUALS TO ITS SYRIAN SANCTIONS LISTS
On 28 March, HM Treasury issued a Notice listing 11 Lebanese and Syrian nationals that were being added to the Syria sanctions lists.
https://www.gov.uk/government/news/tackling-the-illicit-drug-trade-fuelling-assads-war-machine
WILLIAM HILL GROUP TO PAY A RECORD £19.2 MILLION OVER A SERIES OF SOCIAL RESPONSIBILITY AND AML FAILURES
On 28 March, iGB reported that gambling operator WHG International, which runs Williamhill.com, will pay £12.5 million to the UK Gambling Commission, while Mr Green, operator of Mrgreen.com will pay £3.7 million. The William Hill Organization, which runs 1,344 land-based gambling premises across Britain, will also pay £3.0 million. Specific failures noted included insufficient controls in place to protect new customers, and it failed to identify certain customers at risk of experiencing gambling-related harm and failing to carry out checks at an early stage in the customer’s journey. From an AML perspective, among other things, the Commission noted that players were allowed to deposit large amounts without conducting appropriate checks.
https://igamingbusiness.com/legal-compliance/william-hill-group-to-pay-record-19-2m-over-failures
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 26/27
Back home from wanderings once more, and with a (so far) reliable computer, at last.
On the compliance front in Panama, the President of the National Assembly says that Panama will be able to count on a law of extinction of ownership of illicit assets (civil forfeiture) before 30 June, the date on which the period of ordinary sessions ends. Given the opposition to date, which has delayed the proposed law for a number of years, we shall see.
It is reported that the Government has taken control of the 130 hectare (321 acre) landfill site which has seen sites and pollution warnings in recent weeks. This comes amidst allegations against the Colombian-owned private operator about environmental liabilities.
In other news, the mandatory use of face masks on public transport (which has been largely ignored in recent weeks, in my personal experience) officially ends today, 27 March. However, the mandatory use of face coverings is maintained in public and private health facilities, where patient care is provided.
Mentioned in passing, alongside the news about face masks, was reminder that any person who works in the food sector, even as a driver or delivery person in food delivery services, using cars, motorcycles, scooters, mopeds, ATV, motorcycles or other similar means of transport, must have the certificate of good health (white card) and the health training card (green card).
Meanwhile, although membership of political parties might be relatively high here in Panama, there is quite some scepticism and cynicism about politics and politicians, and as elections approach I noticed this notice on a gate in El Valle.
“I don’t want a visit from politicians from any party. They are all corrupt”
26/27 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
UN REMOVES 1 NAME FROM IRAQ SANCTIONS LIST
On 27 March, the UN advised that AMIR HAMUDI HASSAN AL-SA’DI had been removed from UN SCR 1518 sanctions list on the recommendation of the relevant sanctions committee.
WHY MASS LAYOFFS POSE INSIDER RISKS AND HOW COMPANIES CAN PROTECT THEMSELVES
On 27 March, an Analysis from Control Risks says that the last year and a half has brought unusual mass movements of people leaving and entering the workplace.It says thatcompanies are beginning to come to the realisation that insider threats can frequently cause more damage than external cyber threats given employees’ authorised access to critical assets. According to one survey, 87% of employees take data with them when leaving a job. The Analysis lists some indicators and provides some mitigating actions.
https://www.controlrisks.com/our-thinking/insights/why-mass-layoffs-pose-insider-risks
HOW CRIMINALS CAN ABUSE LARGE LANGUAGE MODELS (LLM) SUCH AS ChatGPT
On 27 March, Europol issued a news release saying that its Europol Innovation Lab organised a number of workshops with subject matter experts from across Europol to explore how criminals can abuse large language models (LLM) such as ChatGPT, as well as how it may assist investigators in their daily work. Insights are compiled in Europol’s first Tech Watch Flash report which provides an overview on the potential misuse of ChatGPT, and offers an outlook on what may still be to come. It explains that a large language model (LLM) is a type of AI system that can process, manipulate, and generate text. It highlights 3 crime areas as amongst the many areas of concern identified by Europol’s experts.
JOINT HM TREASURY AND FCA STATEMENT ON THE CRIMINAL MARKET ABUSE REGIME
On 24 March, HM Treasury published a review of the criminal market abuse regime, fulfilling the commitment made in the Economic Crime Plan 2019-22. The criminal market abuse regime sets out the UK’s criminal sanctions for insider dealing and market manipulation. It is important in helping the FCA fulfil its statutory objectives of protecting consumers, enhancing market integrity, and promoting competition.
UK: 2 INDIVIDUALS AND AN ENTITY ADDED TO MYANMAR SANCTIONS LIST
On 27 March, a Notice from HM Treasury advised that KHIN PHYU WIN, TUN MIN LATT and SHOON ENERGY PTE LIMITED to its Consolidated List.
THE RUSSO-UKRAINIAN WAR AND THE ILLEGAL ARMS TRADE
On 22 March, the Global Initiative Against Transnational Organised Crime published this report, which says that, sespite some over-heated claims, there is currently no substantial outflow of weapons from the Ukrainian conflict zone. However, every precedent suggests that, especially if the threat is not addressed proactively and imaginatively, when the current war ends, Ukraine’s battlefields could and will become the new arsenal of anarchy, arming everyone from insurgents in Africa to gangsters in the streets of Europe. The report explores the current situation in Ukraine in terms of the spread of weapons into non-state hands and clandestine supply chains. It considers the prospects for more serious levels of proliferation after the end of hostilities, and makes practical recommendations for Ukraine and its foreign partners.
https://globalinitiative.net/analysis/russia-ukraine-war-illegal-arms-trade/
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 24/25
As you may have guessed, I am away from home again, and suffering from computer snags (again). Hence the limited output, and 2 days’ worth of survey combined on one page…
Meanwhile, I have been enjoying the cool,clean air of the mountains and cuddling a python called Lola!
25 MARCH 2023
OFAC: BURMA-RELATED DESIGNATIONS AND ALERT RE JET FUEL
On 24 March, OFAC advised that it had added 2 individuals and 6 entities to its Myanmar sanctions list. It also published a Burma Jet Fuel Sanctions Alert, to inform individuals, businesses, and other persons of the sanctions risks associated with providing jet fuel to the military regime.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230324
https://home.treasury.gov/news/press-releases/jy1364
https://home.treasury.gov/system/files/126/20230324_ofac_alert_jet_fuel.pdf
https://www.europeansanctions.com/2023/03/us-adds-to-belarus-myanmar-sanctions-lists/
OFAC: 7 INDIVIDUALS, 1 AIRCRAFT AND 2 ENTITIES ADDED TO BELARUS SANCTIONS LIST
On 24 March, OFAC advised that several people and 2 entities had been added to its sanctions lists, and had released for publication in the Federal Register a final rule amending and reissuing the Belarus Sanctions Regulations.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230324
https://home.treasury.gov/news/press-releases/jy1365
https://kpmg.com/us/en/home/insights/2023/03/tnf-us-rule-amending-belarus-sanctions-regulations.html
https://www.europeansanctions.com/2023/03/us-adds-to-belarus-myanmar-sanctions-lists/
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 23
It is reported today that, apparently, Panama is experiencing an unusual number of cases of malaria. Scientists from the Gorgas Memorial Institute for Health Studies (ICGES) in Panama City made the announcement. It seems that in the province of Darién (the wild area on the Colombian border) the highest incidence of cases is because of 2 native strains which, although less aggressive, are causing asymptomatic or subclinical symptoms that contribute to the increase in contagion. It was also suggested that the increase in cases of the disease could also be associated with other factors, including the large increase in migration at the Colombian/Panamanian border. Only the anopheles genus of the mosquito transmits malaria. As I think I have mentioned before, the advent of the rainy season is when we, in the city, tend to see (or feel!) more mosquitos, and that means around this time of year.
23 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
MONEYVAL CHIEF DEPARTS ROLE AFTER REPORT LINKS FAMILY TO RUSSIAN INTELLIGENCE
On 22 March, ACAMS reported that the executive secretary of the FATF affiliate in Europe has left his position following revelations about his family ties to Russia’s Foreign Intelligence Service, or SVR. Russian national Igor Nebyvaev had led the Committee of Experts on the Evaluation of Anti-Money Laundering Measures, or Moneyval, since March 2020. FATF barred Russia from participating in meetings in October and formally suspended the country’s membership in February.
THE GROWING USE OF CRYPTOCURRENCIES BY TRANSNATIONAL ORGANISED CRIME GROUPS IN LATIN AMERICA
On 20 March, a report from the Georgetown University School of Foreign Science says that, across Latin America, transnational criminal organisations, transnational gangs, and extra-regional actors supporting authoritarian regimes are exploiting growing cracks in the region’s weak financial regulations by transferring parts of their financial holdings to cryptocurrency, thereby avoiding detection and asset seizures. Opportunities for criminal use of crypto have significantly increased in the past few years; a growing number of high corruption governments, which also act as money laundering havens, are actively courting unvetted crypto investors with purposeful deregulation and opacity.
THE “GOLD MAFIA” IN SOUTHERN AFRICA
On 23 March, Al Jazeera published its report saying that there are rival gangs — with many different characters. From new-age pastors to old-school smugglers, and from diplomats to the Zimbabwean president’s niece. Al Jazeera’s investigation has uncovered a band of criminals driving gold smuggling and money laundering worth billions of dollars in southern Africa. It some of the key individuals running the mafia. These include a gold smuggler from Kenya who has now moved his operations to Dubai and is smuggling gold from all over Africa, mostly from Zimbabwe, under cover of running a church. Another is one of Zimbabwe’s most influential diplomats, a special envoy and ambassador-at-large to Europe and the Americas since 2021. Another is a pastor in Angel’s Good News Church and a musician. Another is a woman who is the president of Zimbabwe’s mining association and a niece of President Mnangagwa.
https://www.aljazeera.com/news/2023/3/23/gold-mafia-godmen-conmen-president-niece
https://www.aljazeera.com/news/2023/3/23/gold-smuggler-pattni-kenya-zimbabwe
https://www.aljazeera.com/news/2023/3/23/top-zimbabwe-ambassador-gold-smuggling
https://www.aljazeera.com/news/2023/3/23/gold-mafia-looting-southern-africa
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 22
“Herman the German” (real name “Titan”) is a giant floating crane used on the Panama Canal and is approaching retirement.
It was one of 3 heavy lift cranes built in 1941 by Demag Cranes AG as Schwimmkran No. 1 for the Kreigsmarine for use in the Baltic Sea tending to U-Boats. After the war it was removed to the US but, following the closure in 1995 of the US shipyard in Long Beach where it had been employed, it was sold to the Panama Canal Commission and it was transported on a semi-submersible ship in 1996 to the Canal Zone, where it remained into the 21st century, serving as the floating crane Titan. It is described as a large, self-propelled crane vessel with the tip of its main boom standing at 374 feet above the typical water line.
The photo is one I took myself, showing the crane at Gamboa. What will become of this bit of history? There is a great video on the history and use of the crane on You Tube.
https://www.youtube.com/watch?v=b_gBoPhb1fg&t=4s
22 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
UK: GLOBAL HUMAN RIGHTS SANCTIONS – 1 ENTRY AMENDED
On 22 March, a Notice from HM Treasury advised that the entry for Ashraf Said Ahmed Hussein ALI has been amended.
UK: RUSSIA SANCTIONS – 1 DUPLICATE ENTRY REMOVED AND 1 AMENDED
On 22 March, a Notice from HM Treasury advised that a duplicate entry relating to Sergey Borisovich KOROLEV has been removed – the original entry still being on the Consolidated List of those subject to sanctions. The entry relating to Alexey Viktorovich KUZMICHEV has been amended.
PANAMA IN WORLD WAR 2 – WHAT HAPPENED WHEN – 1945
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 21
I did spot a woman, who passed me and seemed to be wearing two different coloured stockings…now I find that that this was to mark World Down Syndrome Day. I didn’t notice anything in the English language newspapers, even the Guardian, before I went out. It was only in La Prensa, when I got home, that I found out.
The weather is supposed to be changing here, as the dry season “Summer” ends. However, though we have had a little rain, it seems sunnier and hotter than ever – 33 degrees today. It’s perhaps a good job that we off to the mountains at the weekend. This time of year, with slightly wetter weather, is also the worst for mosquitos, at least in my experience – but fewer of those up in the mountains too.
Meanwhile, the latest Covid statistics continue to show a presumed post-Carnivale surge. 702 new cases in the week to 18 March (compared to around 500 for each of the 2 previous weeks). There are now 2 people in ICU (there were none the week before), with 36 in other wards (down 6). Just 1 new fatality is reported. the test results figure also continues to rise – now at 4.4%, up from3.4% the week before.
21 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
EXTRATERRITORIAL APPLICATION OF AMERICAN CRIMINAL LAW
On 21 March, the US Congressional Research Service published an updated briefing, saying that a number of US criminal laws apply extraterritorially outside of the US. Application is generally a question of legislative intent, express or implied. There are 2 exceptions. First, the statute must come within Congress’s constitutional authority to enact. Second, neither the statute nor its application may violate due process or any other constitutional prohibition. The CRS also issued an “Abbreviated Sketch” – an 8-page summary version.
https://crsreports.congress.gov/product/pdf/RL/94-166
UK: RUSSIA SANCTIONS – PROHIBITION ON PROVIDING TRUST SERVICES TO OR FOR THE BENEFIT OF CERTAIN PEOPLE OR ENTITIES.
On 21 March, HM Treasury advised that the UK government has acted alongside its international allies to introduce new measures that will prevent Russia from accessing UK trust services. OFSI says that there is there is evidence of UK-based trust and company service providers (TCSP) offering their services to persons to enable them to reduce the impact of sanctions in the event they become subject to them. Changes mean now that the 1,730 persons that are currently designated under regulations imposing an asset freeze are now also designated under regulation 18C (trust services). This means that it is now prohibited to provide trust services to or for the benefit of these persons, unless permitted by a licence or there is an applicable exception. The EU Sanctions blog noted that, in addition, 6 entries on the Russia sanctions list, and the entry for PJSC Sberbank. A new General Licence from HM Treasury provides for a 90-day wind-down period to undertake any activity necessary to terminate an existing arrangement.
https://ofsi.blog.gov.uk/2023/03/21/trust-services-sanctions-update/
The Isle of Man followed suit on 21 March –
https://www.gov.im/news/2023/mar/21/financial-sanctions-russia/
https://www.gov.im/news/2023/mar/21/financial-sanctions-russia-general-licence/
OFAC: FURTHER SANCTIONS ON PROCUREMENT NETWORKS FOR IRAN UAV AND WEAPONS PROGRAMS
On 21 March, OFAC advised that it had designated 4 entities and 3 individuals in Iran and Turkey for their involvement in the procurement of equipment, including European-origin engines of unmanned aerial vehicles (UAV) in support of Iran’s UAV and weapons programs. This procurement network operates on behalf of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which oversees several companies involved in UAV and ballistic missile development.
https://home.treasury.gov/news/press-releases/jy1355
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230321
UK UPDATES EXPORT CONTROL LISTS IN LINE WITH WASSENAAR ARRANGEMENT ETC
On 21 March, the EU Sanctions blog reported on new amending regulations laid before Parliament on 10 March. These make the necessary amendments to UK legislation to reflect agreed changes to changes to the Wassenaar Arrangement munitions list and dual-use list, as well as changes to other multilateral export control regime lists, including those of the Australia Group and the Missile Technology Control Regime (MTCR). The changes enter into force on 31 March.
THE FOREIGN SUPPLY OF REPRESSIVE EQUIPMENT TO HONG KONG
On 16 March, a report from C4ADS says that Western companies have continued to provide the Hong Kong Police Force and the Government Flying Service with equipment, technology, and training that may aid in the repression of Hong Kong residents. It says that, between 2017 and 2022, companies in 9 foreign countries – Australia, Canada, Finland, France, Germany, the Netherlands, Singapore, UK, and US – received security-related contracts totalling more than US$171 million. These 29 foreign contracts are a subset of over 575 security-related contracts, with the rest going to Hong Kong-based companies. However, they are often the sole source of equipment such as bullets, boats, and aircraft that may support human rights abuse in Hong Kong. Australian, Canadian, Finnish, French, and Singaporean companies have remained active suppliers to the HKPF and Government Flying Service.
GOLD SHIPMENT FORFEITED AFTER NCA LINKS IT TO DRUG CARTELS
On 21 March, a news release from the NCA advised that the NCA had obtained a civil recovery order for gold worth an estimated £4 million that was being laundered by South American drug cartels. The shipment of gold weighing 104 kg was seized at Heathrow in June 2019. It was being transported from the Cayman Islands to Switzerland via Heathrow, having earlier been shipped to the Caymans on a private jet which had arrived from Venezuela.
EU ADDS 8 INDIVIDUALS AND 1 ENTITY TO IRAN SANCTIONS LISTS
EU Regulation 2023/645/EU added 8 persons and 1 entity should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures, following human rights abuses in Iran.
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 20
While the actual number of those using them on buses and the Metro had already drastically declined, the health minister has announced that face masks will no longer be mandatory on public transport. Those involved in handling food will also not be compelled to use masks. However, they remain mandatory in health facilities – as well as being recommended for those with chronic illnesses and more at risk.
Meanwhile, I spent the afternoon at Corozal, part of the old Canal Zone, taking a look at the impressive American Cemetary, which reminded me of the Commonwealth War Graves and those in Normandy. It reminded of a surprise I got one Christmas while wandering around a churchyard in Bregenz in Austria. Firstly, there was a large memorial to the fallen of World War 1, but then the surprise was that tucked behind it were a line of World War 2 graves, with dates (as I remember) from near the end of the war, and being of SS soldiers. Obviously, they must be buried somewhere, but somehow one does not think of it.
20 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
NEW IRAN SANCTIONS FROM UK, AUSTRALIA AND EU
NEW IRAN SANCTIONS FROM UK, AUSTRALIA AND EU
On 20 March, the EU Sanctions blog reported that the UK has added 7 people to its Iran (human rights) sanctions list. The EU has listed the Supreme Council of Cultural Revolution alongside 8 people who are alleged to be responsible for serious human rights violations in Iran. Australia has designated Safiran Airport Services and 13 people, over their alleged involvement in the production and supply of drones to Russia. Australia has also listed 14 people and 14 entities alleged to be responsible for egregious human rights abuses and violations in Iran.
https://www.europeansanctions.com/2023/03/uk-eu-australia-designate-iranian-nationals-entities/
UK: FINDINGS FROM FCA MULTI-PROFESSIONAL BODY SUPERVISOR (PBS) TRUST AND COMPANY SERVICE PROVIDERS (TCSP) REVIEW WHICH LOOKED AT THE PBS APPROACH TO TCSP RISKS
The FCA has published this report which found that most PBS have assessed the TCSP risk within their own supervised populations as being relatively low. This is contrary to the National Risk Assessment 2020 (NRA) which categorised TCSP as higher risk. It says that PBS view company formation as a higher risk TCSP service, but had different views on the higher-risk and lower-risk indicators of TCSP services. They also did not demonstrate a consistent understanding of TCSP ‘supply chain’ risk.
https://www.fca.org.uk/publication/multi-firm-reviews/opbas-multi-pbs-project-tcsp-risk.pdf
UK: 7 INDIVIDUALS ADDED TO IRAN SANCTIONS LISTS
On 20 March, a Notice from HM Treasury advised that 7 individuals linked to the IRGC have been added to the UK’s Iran human rights sanctions lists.
https://www.gov.uk/government/news/uk-sanctions-top-iranian-revolutionary-guard-corps-financiers
WHEN WILL A FRAUD VICTIM’S SETTLEMENT OF ITS ONWARD LIABILITY AFFECT THE AMOUNT RECOVERABLE FROM THE FRAUDSTER?
On 14 March, an article from Herbert Smith Freehills LLP was concerned with recent Court of Appeal decision which highlights the principles a court will apply when deciding whether a benefit received by a victim of fraud reduces its recoverable loss. The Court decided that the claimant’s damages for an unlawful means conspiracy could be reduced to reflect any benefit it had obtained by negotiating a settlement limiting its onward liability to a third party – although on the facts no such benefit had been obtained.
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 19
Thought we were away this weekend, until checking directions to the accommodation I found that I had rearranged the trip until next weekend…
At least this meant I didn’t miss the interesting Japan exhibition at the Biblioteca Nacional in the lovely Parque Omar Torrijos (only in Panama, maybe, would you have a park named after a popular dictator, who turned a former golf course into the best recreational park in the city). Bonzai, kimonos, kendo and manga…
19 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 18
La Prensa reported that at least 5high-profile officials of the administration of former President Ricardo Martinelli (who was President 2009-2014) have suffered harsh judicial setbacks in recent months. Some have had convictions confirmed for crimes ranging from embezzlement, corruption, and money laundering.
Meanwhile the Ministry of Health (Minsa) reported that so far this year, 958 cases of dengue have been confirmed nationwide. However, to date no deaths have been reported.
18 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 17
Had to go to the US Embassy this morning, and judging from the queue at the gate everyone is planning to leave Panama…odd to find the consular official commenting on my “scouse” accent (it turned out he was from Norwich). It has to be said that the Embassy is in a lovely setting, with nice gardens, and I saw a toucan flying across. This is very unlike the almost anonymous British Embassy, tucked away on a busy street in the city, and occupying just a small part of an equally anonymous office block.
The National Consumer Price Index (CPI) of Panama showed a year-on-year variation of 2.0% in February, and virtually no change compared to January. It was said that the products with the greatest increases year-on-year variation were housing, water, electricity and gas (as electricity is cheap, has been subsidised since the start of the pandemic, and retirees get a discount anyway – gas is also subsidised and water bills seem very modest – so I am not sure how this can be).
17 MARCH 2023
https://www.buymeacoffee.com/KoIvM842y
GUIDANCE: OFSI ENFORCEMENT AND MONETARY PENALTIES FOR BREACHES OF FINANCIAL SANCTIONS
UK: RUSSIA SANCTIONS – 1 ENTRY REMOVED, 1 AMENDED AND ANOTHER DUPLICATE REMOVED
On 17 March, a Notice from HM Treasury advised that Brian McDonald, head of Russia desk for the English language edition of RT (formerly Russia Today), has been deleted; the entry for Igor Makarov have been amended; and a duplicate entry for the Minsk Wheel Tractor Plant has been deleted.
raytodd.blog 