Day: September 12, 2018

On 12^th September, President Trump signed anew Executive Order requiring that, not later than 45 days after the conclusion of a US election, the Director of National Intelligence, in consultation with the heads of any other appropriate executive departments and agencies (agencies), shall conduct an assessment of any information indicating that a foreign government, or any person acting as an agent of or on behalf of a foreign government, has acted with the intent or purpose of interfering in that election.  If any such interference is found, the EO allows for sanctions to be imposed on the assets of anyone found to have to have directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in foreign interference, aided or assisted them, or property etc owned or controlled by them.  It also allows for other sanctions, such as blocking and prohibiting all transactions in a person’s property and interests in property subject to US jurisdiction, export licence restrictions and prohibitions on US financial institutions making loans or providing credit.  Anyone designated under the EO would also be barred from entering the US.

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/election_eo.pdf

12^th September 2018

RICE REMAINS TOP ITEM SMUGGLED INTO NIGERIA

The Vanguard in Nigeria on 12^th September reported that sea ports of West African countries are still receiving large quantities of the commodity, apparently for onward shipment to Nigeria through land borders.  Consequently, the commodity still tops the smuggling chart and seized items by the recent records of the Nigeria Customs Service, NCS, with a total of 124,407 bags of rice seized in the first half of 2018.
https://www.vanguardngr.com/2018/09/rice-remains-atop-list-of-items-smuggled-into-nigeria/

CRYPTO INDUSTRY LEADERS ESTABLISH WASHINGTON-BASED LOBBY GROUP

Coin Telegraph on 12^th September reported that a group of US-based blockchain and cryptocurrency companies have announced they will form the Blockchain Association, the “first” lobbying group representing the blockchain industry in Washington DC.  It will represent mainstream companies that look to operate within the political system, primarily addressing policy issues and the treatment of cryptocurrency by US tax law., and at the same time, the group will work closely with lawmakers on AML and KYC policy development within the industry.

https://cointelegraph.com/news/crypto-industry-leaders-establish-washington-based-lobby-group

IMF URGES MARSHALL ISLANDS TO RECONSIDER ADOPTING DIGITAL CURRENCY AS SECOND LEGAL TENDER

Coin Telegraph and others on 11^th September reported that in a report the IMF stating that the introduction of digital currency as an official form of legal tender – a cryptocurrency named the Sovereign (SOV) – will pose risks to the country’s financial integrity, as well as relationships with foreign banks.  The IMF is quoted as saying that the potential benefits from revenue gains appear considerably smaller than the potential costs arising from economic, reputational, AML/CFT, and governance risks. In the absence of adequate measures to mitigate them, the authorities should seriously reconsider the issuance of the digital currency as legal tender.

https://cointelegraph.com/news/imf-urges-marshall-islands-to-reconsider-adopting-digital-currency-as-second-legal-tender

ENFORCEMENT OF FOREIGN JUDGMENTS IN THE BVI

On 10^th September, Harneys published a guide which starts by saying that foreign money judgments can be enforced in the BVI pursuant to the Reciprocal Enforcement of Judgments Act 1922 (if the judgment was obtained from certain countries) or under common law by way of a simple debt claim.  Non-money judgments are not directly enforceable in the BVI – but if the claimant has a foreign judgment based on a cause of action recognised under BVI law the judgment may be enforced by issuing a fresh claim in the BVI and then relying on the principle of issue estoppel.  Foreign arbitration awards (made in a New York Convention state or otherwise) can be registered and enforced in the BVI in accordance with the provisions of the Arbitration Act 2013.  The article goes on to explain the detail.  In the “public policy” section, one notes that BVI courts will not enforce the revenue law of another state or enforcement which would involve the indirect enforcement of another state’s revenue laws.

https://www.lexology.com/navigator#!results/498/view

FROM ANTIGUA HIDEOUT, INDIAN BANK FRAUD FUGITIVE FRETS ABOUT EMPLOYEES, SHAREHOLDERS

On 12^th September, NDTV in India reported that one of India’s most wanted men, Mehul Choksi, who fled the country in January, and speaking from his current home in Antigua, has blamed the Indian government for the uncertain future he says his 6,000 employees and shareholders are facing.  The government has been trying to extradite him and his nephew, celebrity diamond jeweller Nirav Modi, and went to live in Antigua and Barbuda in the wake of the PNB Bank scandal breaking, and which granted him citizenship of last year.  It says that Mehul Choksi has alleged that the cases against him are a result of political conspiracy, after which India’s extradition request was put on hold by the Interpol.

https://www.ndtv.com/india-news/from-antigua-hideout-mehul-choksi-frets-about-employees-shareholders-1915149

US: FINANCIAL ADVISER PLEADS GUILTY TO MONEY LAUNDERING CHARGE IN CONNECTION WITH BRIBERY INVOLVING ECUADORIAN OFFICIALS

On 11^th September, the US DoJ published a news release relating to a scheme to pay bribes to officials of Ecuador’s state-owned and state-controlled energy company, Empresa Pública de Hidrocarburos del Ecuador (PetroEcuador).  Jose Larrea, 40, a US citizen from Miami, is the 4^th individual to plead guilty in this case.  In addition to Larrea, 2 former officials of PetroEcuador who received bribe payments and a contractor have previously pleaded guilty to date in connection with the government’s ongoing investigations into the PetroEcuador bribery and money laundering schemes.

https://www.justice.gov/opa/pr/financial-advisor-pleads-guilty-money-laundering-charge-connection-bribery-scheme-involving

IMF – CARBON TAXATION FOR INTERNATIONAL MARITIME FUELS: ASSESSING THE OPTIONS

On 11^th September, the IMF issued a Working Paper 18/203 which says that the IMO announced in April 2018 a target of cutting greenhouse gas (GHG) emissions from the sector by 50% below 2008 levels by 2050 and subsequent meetings of the IMO will develop a strategy for making headway on this commitment.  This Working Paper seeks to inform dialogue about the possibility of a carbon tax as a key element of GHG mitigation policy for international maritime transport.  The paper discusses the case for the tax over alternative mitigation instruments, options for the practical design issues, and then presents estimates of the impacts of carbon taxation and other instruments from an analytical model of the maritime sector.

http://www.imf.org/en/Publications/WP/Issues/2018/09/11/Carbon-Taxation-for-International-Maritime-Fuels-Assessing-the-Options-46193

CRIME GANG SNAPPING UP FAKE EURO NOTES ONLINE TO FLOOD IRISH MARKET WITH COUNTERFEIT CASH

Dublin Live on 12^th September reported that organised criminals buy the dodgy cash from a popular website and a network of handlers buy items across the country.  The website, which is not not identified, has dozens of images of fake euro notes of all denominations.

https://www.dublinlive.ie/news/dublin-news/crime-gang-snapping-up-fake-15140590

CHANGES TO UK AVIATION SECURITY RESTRICTIONS

On 11^th September, the DfT issued a news release saying that large phones, laptops and tablets are now allowed in the cabin on the majority of flights to the UK.  Restrictions on carrying large phones, laptops, tablets and accessories into the cabin of UK-bound flights from Turkey, Egypt, Saudi Arabia, Jordan, Lebanon and Tunisia were introduced in March 2018.  The news release details which airports or countries affected – Saudi Arabia, Jordan and Lebanon.  It says that restrictions are no longer applied on any airports in Egypt, Turkey and Tunisia.

https://www.gov.uk/government/news/changes-to-uk-aviation-security

UK IVORY FINGERPRINTING KITS TO HELP IN FIGHT AGAINST ILLEGAL WILDLIFE TRADE

On 11^th September, the FCO issued a news release about the official handover of 100 forensic fingerprinting kits to fight the illegal wildlife trade.  The kits, specially designed to lift fingerprints from ivory, have been donated by IFAW and will be distributed to countries attending the upcoming London Illegal Wildlife Trade Conference in October.  The new fingerprinting technique, developed by the Metropolitan Police and King’s College London, can reveal prints up to 28 days after poachers have touched the ivory, compared to the 2 or 3 days with current conventional powders.  This will significantly increase the chances of identifying the criminals behind the illegal ivory trade.

https://www.gov.uk/government/news/uk-fingerprinting-kits-to-help-in-fight-against-illegal-wildlife-trade

3 MEN JAILED AFTER THEY WERE CAUGHT WITH MORE THAN 1.5 MILLION ILLEGAL CIGARETTES DISGUISED AS ROAD SURFACING MATERIAL AT A SOUTH SHIELDS WAREHOUSE

On 11^th September, Commercial Motor reported that HMRC officers searched the premises in March and discovered 24 pallets loaded with packages containing 1,508,300 non-UK duty-paid cigarettes.  The cigarettes were hidden in wooden containers coated in bitumen, often used for road surfaces, and wrapped in packaging. The 3 men were found hiding at the back of the unit and were arrested.

https://www.commercialmotor.com/news/compliance/cigarette-smugglers-receive-prison-sentences

MAN GOES ON TRIAL ACCUSED OF HOLDING WITCHCRAFT ITEMS IN UAE

Customs Today on 11^th September reported that a 43-year-old Asian man has gone on trial accused of carrying 2 bags containing witchcraft materials and trying to smuggle the illegal items into the UAE.  Officers seized the sorcery items and sent them to officials at the General Authority for Islamic Affairs and Endowments to establish what exactly the products were.  The Islamic scholars also recommended that the sorcery materials be destroyed to protect members of the community.  Prosecutors charged the Asian man with attempting to carry sorcery materials into the UAE to practice witchcraft, which is against UAE laws.

http://www.customstoday.com.pk/man-goes-on-trial-accused-of-holding-witchcraft-items-in-uae/

5,000 AFGHAN BIRDS SMUGGLED IN A YEAR

Customs Today on 10^th September reported that smugglers have stolen nearly 5000 birds out of Afghanistan in the past 12 months, taking them to various countries particularly the Gulf nations, Afghanistan Environment Protection Agency (AEPA) said. Geese and falcons are the most popular birds for smugglers, mostly taken from the northern provinces.

http://www.customstoday.com.pk/5000-afghan-birds-smuggled-in-a-year/

417 KG OF COCAINE FOUND ON CONTAINER IN URUGUAY

Maritime Herald on 11^th September reported that a 40-foot container with 368 packs of cocaine hidden in bales of wool in a container belonging to an Uruguayan company, destined for Antwerp, and the largest seizure ever made in Montevideo.

http://www.maritimeherald.com/2018/seized-417-kilos-of-cocaine-on-a-container-belonging-to-an-uruguayan-company/

US CUSTOMS ENVISIONS STREAMLINING CUSTOMS ENTRY VIA TEXTING

On 11^th September, Travel Weekly reported that US Customs and Border Protection would one day like to speed up the entry process through the use of text messaging.  The vision was laid out at the Future Travel Experience Conference in Las Vegas, but the initiative does not have any sort of implementation timeline.  CBP is presently in the process of implementing biometric entry and exit via facial recognition at airports around the country – it is currently testing facial-recognition entry, eliminating the need for travellers to present their passports, at 15 airports; and facial-recognition exit at 14 airports.

https://www.travelweekly.com/Travel-News/Airline-News/CBP-envisions-streamlining-customs-entry-via-texting

THE RULE OF LAW IS UNDER ATTACK IN MOLDOVA

Chatham House on 12^th September carried a report saying that Moldova has long struggled with corruption in its politics, but a series of events over the course of the summer indicate that democracy and the rule of law are coming under increased threat.  Western partners should take these red flags seriously and re-evaluate how they engage with the Moldovan government.

https://www.chathamhouse.org/expert/comment/rule-law-under-attack-moldova

TRUMP’S IRAN SANCTIONS: AN EXPLAINER ON THEIR IMPACT FOR EUROPE

The first part of a mini-series assessing the likely impact of US sanctions on economic ties between Europe and Iran has been published by the European Council on Foreign relations on 12^th September.

https://www.ecfr.eu/article/commentary_trumps_iran_sanctions_an_explainer_on_their_impact_for_europe?utm_content=buffer35056&utm_medium=social&utm_source=twitter.com&utm_campaign=buffer

INDIA AND BANGLADESH OFFICIALS CALL FOR GREATER ACTION ON CROSS-BORDER COUNTERFEIT CURRENCY SMUGGLING

Illicit Trade on 8^th September reported that border officials from India and Bangladesh have met in New Delhi to discuss new ways of working together to prevent human trafficking, drug smuggling and the illegal transfer of counterfeit currency between the 2 countries.  It was said that while the smuggling of fake Indian currency across the countries’ shared border had dropped “considerably” after the Indian government removed high-value banknotes from circulation in 2016, the transfer of counterfeit cash remained a significant issue; and counterfeit Indian banknotes were being produced by a “friendly neighbour” (presumed to mean Pakistan), which was using Bangladesh as a transport hub for the fake currency.

https://www.illicit-trade.com/2018/09/indo-bangla-officials-call-for-greater-action-on-cross-border-counterfeit-currency-smuggling/

PODCAST: VENEZUELA – A RICHES TO RAGS STORY

People in Venezuela are murdering each other at the highest rate in the world.  Workers are fainting on the job because of hunger.  Citizens have lost 20 lb on average since the country’s economic crisis began.  It is a nation in collapse with no clear way out.  How did Venezuela, once one of the world’s richest countries, plummet so far?  Keith Johnson of Foreign Policy helps us understand.

https://www.acast.com/warcollege/venezuela-arichestoragsstory?autoplay=true

YOUR GUIDE TO RUSSIA’S MAFIA, THE VORY

On 18^th July, the War College website in the US published the transcript of its podcast about Mark Galeotti’s book, “The Vory: Russia’s Super Mafia”.  In the podcast, Galeotti takes us through the history of Russia’s mafia and how that history helped to shape Vladimir Putin’s state.

http://warcollegepodcast.com/russian-mafia-the-vory-putin/

CAN LAWSUITS SOLVE THE US OPIOD CRISIS?

On 5^th September, Medium published an article the US is in the grip of an opioid epidemic, affecting millions of Americans and claiming thousands of lives.  Is suing drug companies, retailers and doctors part of the answer?  Many people trace their opioid dependence back to their doctor’s office, the drugs prescribed for pain after an injury, surgery, or dental procedure. Were these painkillers over prescribed? Did drug manufacturers exaggerate opioids’ effectiveness while deliberately underplaying their danger? Did drug distributors and retailers take necessary steps to ensure that pills weren’t falling in to the wrong hands?  In the article, Michelle Mello, an expert in health law, and Nora Freeman Engstrom, an expert in tort law and complex litigation, both professors at Stanford University, explain the scope of the opioid problem and discuss the latest cases and legal challenges.  Some 2.4 million Americans have an opioid use disorder, and the epidemic has already claimed 300,000 American lives, including 42,000 in 2016 alone.  The typical defendants in lawsuits are opioid manufacturers, distributors, and big retail pharmacies.

https://www.futurity.org/opioid-crisis-lawsuits-litigation-1857002/

AN ANALYSIS OF SOCIAL MEDIA INFLUENCE OPERATIONS AGAINST US COUNTER-PROLIFERATION EFFORTS IN SYRIA

On 12^th September, the James Martin Center for Nonproliferation Studies published an Occasional Paper which seeks to analyse the tradecraft, trends, themes, and possible effects of disinformation produced by suspected synthetic actors (i.e. bots, trolls, and cyborgs) on Twitter concerning chemical weapons use in Syria.  Although it is highly likely these synthetic actors exist on other social media platforms as well, this analysis focuses exclusively on Twitter, since the open nature of the platform allows for study without special access.   It identifies a well-coordinated network of synthetic actors deployed for the primary purpose of discrediting the reports of the Assad regime’s CW use in order to influence the US counter-proliferation response.   The report concludes with recommendations for both policy makers and social network companies.

https://www.nonproliferation.org/op37-all-the-world-is-staged-an-analysis-of-social-media-influence-operations-against-us-counterproliferation-efforts-in-syria/

ISLE OF MAN UPDATES ITS SUDAN/SOUTH SUDAN SANCTIONS LEGISLATION

On 12^th September, the Isle of Man advised that the European Union (South Sudan Sanctions) (Amendment) Order 2018 and South Sudan Sanctions (Amendment) Regulations 2018 came into operation on 11^th September.  The Order applies the provisions of Council Regulation (EU) 2018/116, as amended, as part of Island law.  That Regulation gives effect to the measures imposed by UN SCR 2428 (2018), the UN Security Council having decided that until 31^st May 2019, all Member States will prevent the supply, sale or transfer to South Sudan from or through their territories of arms and related material, and withhold training, technical and financial assistance related to military activities or materials.  In addition, it lays out several exemptions to the country’s arms embargo including for material and activities related to humanitarian activities and measures to be taken in relation to the inspection of shipments and cargo bound for South Sudan.

https://www.gov.im/news/2018/sep/12/european-union-south-sudan-sanctions-amendment-order-2018-and-south-sudan-amendment-regulations-2018/

SWISS PARLIAMENT APPROVES CORPORATE TAX OVERHAUL

Reuters on 12^th September reported that the Swiss parliament has approved a corporate tax overhaul that it hopes will stave off the danger of it landing on a EU blacklist of unco-operative tax havens.

https://uk.reuters.com/article/us-swiss-tax/swiss-parliament-approves-corporate-tax-overhaul-idUKKCN1LS2U8

IRELAND: FACIAL IMAGING SOFTWARE HAS BEEN USED TO DETECT €4 MILLION WORTH OF IDENTITY FRAUD
The Journal in Ireland on 12^th September reported that software deployed by the Department of Employment Affairs and Social Protection has recorded 28 cases of identity fraud to date in 2018.  According to the department, the cost of operating the facial imaging software system “is self-financing” as the value of fraudulent activity detected since its application is in excess of €4 million.

http://www.thejournal.ie/facial-imaging-software-4232030-Sep2018/?src=ilaw

ISLAMIC DEVELOPMENT BANK FREEZES SOMALIA PROJECT OVER CORRUPTION ALLEGATIONS

VoA on 12^th September reported that the Islamic Development Bank has suspended a multi-million dollar project in Somalia due to accusations of corruption and mismanagement.  It started in October 2016, and the Dryland Development Project was being conducted in 3 rural villages to help pastoralists build resilience to drought, give them access to health and education services, and develop livestock and crops.  The project was set to cost $5 million overall.

https://www.voanews.com/a/islamic-development-bank-freezes-somalia-project-mismanagement/4568564.html?src=ilaw

CYPRUS: POLICE OFFICERS REMANDED IN TRAFFICKING AND CORRUPTION CASE

The Cyprus Mail on 12^th September reported that 3 police officers and 2 others were remanded in custody in Nicosia in connection with people trafficking and corruption.  The officers are accused of receiving bribes to turn a blind eye while serving at passport control at the airport and let through women from third countries who were later employed at a bar in Nicosia.

https://cyprus-mail.com/2018/09/12/police-officers-remanded-in-trafficking-case/?src=ilaw

SECURING UK INFRASTRUCTURE: 10 THINGS TO KNOW ABOUT NATIONAL SECURITY & INVESTMENT REFORM PROPOSALS

On 12^th September, Bryan Cave Leighton Paisner published a briefing saying that the UK Government published in July a White paper on proposed national security and investment reforms which would significantly enhance its ability to review transactions, such as company takeovers, which might raise national security concerns.  It outlines 10 key features of the UK proposals which infrastructure operators and investors need to know.  The new regime is not expected to be introduced until 2020.

http://www.blplaw.com/expert-legal-insights/articles/securing-uk-infrastructure-10-things-to-know-about-national-security-investment-reform-proposals

6 ARRESTED FOR ILLEGAL TV STREAMING IN UK AND IRELAND

A news release from Europol on 12^th September said that after a year-long complex investigation coordinated by Europol, authorities in Hampshire, south-east England, Scotland and Ireland have arrested 6 people, suspected of illicitly distributing premium TV channels by using Internet Protocol television (IPTV) technology.  The arrests are the result of a complex investigation, involving a number of law enforcement agencies (Garda National Bureau of Criminal Investigation, Police Scotland, Trading Standards and UK IPO) and private sector partners, such as the Audiovisual Anti-Piracy Alliance (AAPA), Federation Against Copyright Theft (FACT).

https://www.europol.europa.eu/newsroom/news/six-arrested-in-hit-against-illegal-television-streaming-in-uk-and-ireland

MASSIVE SHARK FIN SEIZURES TOTALLING 12 TONS RING ALARM BELLS

The Taiwan News on 12^th September reported that shipments totalling 8 tons of shark fin en route to mainland China and Hong Kong were confiscated in India – worth more than $6.2 million and led to an additional seizure of 4 tons of “dried ray skin” believed to be shark fin in Malaysia, making this one of the largest combined seizures of shark fins in recent history.

https://www.taiwannews.com.tw/en/news/3528342

US TO PUSH NEW RULES FOR DRONE AGREEMENT IN NOVEMBER

Defense News on 11^th September reported that the US is preparing a new push to change how unmanned systems are categorized under an international arms agreement, MTCR, as part of a broader effort to make it easier to sell military drones abroad.  The Missile Technology Control Regime covers large unmanned systems, such as the MQ-9 Reaper, because of a technicality that identified such systems as once-use missiles and not aircraft which will be reused multiple times; advocates argue that designation makes no sense for the way large UAV are used.  The article explains that systems which carry 500 kg payloads for more than 300 km are considered “Category 1” systems, which comes with a “presumption of denial” which means countries tied into the MTCR need to have a very compelling case to sell them.

https://www.defensenews.com/unmanned/2018/09/11/us-to-push-new-rules-for-drone-treaty-in-november/#.W5krrKd9eqQ.twitter

On 12^th September, OFAC added Ibrahim ADHRAN (aka. Ibrahim Saad AL-JADRAN AL-MAGHRIBI; Ibrahim JATHRAN) to the SDN List.  It also amended the entry for the SCOGLITTI RESTAURANT in Malta, which now is a listing for PORTICELLO RESTAURANT (formerly known as SCOGLITTI RESTAURANT).

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20180912.aspx

https://home.treasury.gov/news/press-releases/sm477

 

In the latest episode of Bribe, Swindle and Steal, Simona Weinglass, a reporter with The Times of Israel, describes the $10 billion global binary options scam that she and her colleagues exposed.   Far from being a sophisticated scheme, it was simply unchecked fraud on a massive scale

https://www.traceinternational.org/bribe_swindle_or_steal

On 11^th September, a news release advised that the relevant UN sanctions committee had recommended the adding of Ibrahim Saeed Salim Jadhran to the sanctions lists and subject to the assets freeze and travel ban, under UN SCR 1970 (2011) and UN SCR 1973 (2011).  Libya’s Attorney General’s Office has issued an arrest warrant against him accusing him of perpetrating a number of crimes, as he allegedly carried out armed actions and attacks against oil installations located in the oil crescent region that caused its destruction, the latest of which was on 14^th June, and has attempted to illegally export oil from Libya.

https://www.un.org/press/en/2018/sc13497.doc.htm

The UK added the name to its sanctions lists on 12^th September –

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/740155/Notice_Libya_12092018.pdf

CILT on 10^th September reported that Pitney Bowes Parcel Shipping Index reports that parcel shipping generated $279 billion in revenue last year, an increase of 11% over 2016. Parcel volume globally grew 17% last year to 74.4 billion parcels, up from 63.6 billion in 2016.  China once again reported the largest parcel volume growth at 28% year-over-year (YOY).  If you exclude China from the Index, the global growth number drops from 17% to 6%.  The UK shipped a total of 3.2 billion parcels in 2017, growing 8% YOY, which represented 48 parcels shipped per person.

https://ciltuk.org.uk/News/Latest-News/ArtMID/6887/ArticleID/19127/Pitney-Bowes-says-global-shipping-volume-to-surpass-100-billion-parcels-in-2020

On 12^th September, Guernsey Press reported that the Head of Law Enforcement Patrick Rice has insisted there are no trust issues between the Guernsey Border Agency and the Criminal Justice Unit.  A court had been told that the GBA would no longer entrust the CJU with matters of disclosure – the evidence and information to which a defendant is entitled.  He said the issue was not one of trust, but rather of process, and that the case was adjourned because the relevant court documents were not prepared in time for the hearing.

https://guernseypress.com/news/2018/09/12/no-trust-issues-between-border-agency-and-cju/

Channel News Asia on 12^th September carried an article about a Transparency International report which says that countries that strictly enforce a worldwide pact against foreign bribery are far outnumbered and outweighed by those that turn a blind eye.  It alleged that 22 countries accounting for nearly 40% of global exports practice “little or no enforcement” of the OECD 1997 Anti-Bribery Convention, which requires signatories to criminalise bribery of foreign public officials.  The list includes China and India, but also signatories like Mexico, Japan or Finland.  Just 7 countries (accounting for 27% of global exports), the US, Germany, the UK, Italy, Switzerland, Norway and Israel are classed as “active” enforcers of the agreement
https://www.channelnewsasia.com/news/world/most-big-exporters-failing-to-check-foreign-bribery-report-10707288

Politico on 11^th September reported that a UN panel of experts on Libya has said that Belgium is in violation of international sanctions targeting assets once owned by the late Libyan dictator Muammar Gaddafi.  This follows an investigation published by Politico earlier this year that showed that tens of millions of euros in interest payments from Gaddafi’s frozen funds managed by Euroclear — a financial institution headquartered in Brussels — were still being paid out.  The money was channelled to mystery beneficiaries behind accounts managed by the Libyan Investment Authority (LIA), the country’s sovereign fund. The Panel considers the payments of interest and other earnings to be in non-compliance with the asset freeze.  It remains unclear what exactly has happened to the money sent from Belgium, and the UN findings also potentially pit it against the EU, where Member States determined in October 2011 that the sanctions were only applicable to the original frozen assets and not any interest earned after September 2011, when the sanctions first came into force.  LIA funds are locked in at least 4 bank accounts managed by Euroclear in Belgium and frozen funds invested in shares before 2011 have risen in value to €14 billion.

https://www.politico.eu/article/un-panel-finds-belgium-in-violation-of-libya-sanctions/

the Politico investigation referred to dates from February 2018 and is available at –

https://www.politico.eu/article/muammar-gaddafi-frozen-funds-belgium-unknown-beneficiaries/

It discovered big, regular outflows of stock dividends, bond income and interest payments.  Gaddafi’s wealth is meant to be held in trust for the Libyan people until the war-shattered country stabilises, but interest payments flowed from frozen accounts in Brussels to bank accounts in Luxembourg and Bahrain.