ISLE OF MAN LEGISLATES FOR CHEMICAL WEAPONS SANCTIONS

The Order Paper for the December sitting of the Island’s parliament includes the European Union (Chemical Weapons Sanctions) Order 2018 (SD 2018/ 028) and the Chemical Weapons Sanctions Regulations 2018 (SD 2018/ 0281).  These apply and implement in the Island EU Regulation 2018/1542, which provides for the freezing of funds and economic resources of certain persons, entities or bodies for the manufacture, use etc of chemical weapons.  They came into effect on 22nd October.

http://www.tynwald.org.im/business/opqp/sittings/20182021/2018-SD-0280-0281-MEMO.pdf

OFAC AND 6 GULF STATES SANCTION TALIBAN FACILITATORS AND THEIR IRANIAN SUPPORTERS

On 29th November, the US Treasury announced that the 7 member nations of the Terrorist Financing Targeting Center (TFTC – being Saudi Arabia, Bahrain, Kuwait, Oman, Qatar, and UAE) took significant actions to expose and disrupt Taliban actors and their Iranian sponsors that seek to undermine the security of the Afghan Government.   The TFTC Member States (including OFAC in the US) have designated 9 individuals associated with the Taliban, including those facilitating Iranian support to bolster the terrorist group.

https://home.treasury.gov/news/featured-stories/treasury-and-the-terrorist-financing-targeting-center-partners-sanction

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20181023.aspx

US TREASURY ADDS DIGITAL CURRENCY AS A WAY OF IDENTIFYING SANCTIONS TARGETS

On 29th November, the Wall Street Journal reported that the US Treasury has for the first time added digital currency identifiers to flag targets on its OFAC sanctions blacklist, as part of action against an Iranian hacking cell allegedly running a ransomware scheme.  OFAC put sanctions on 2 men it said had laundered the millions of dollars’ worth of bitcoin gained from the scheme.

https://www.wsj.com/articles/u-s-treasury-adds-digital-currency-to-means-of-identifying-sanctions-targets-1543446964?mod=searchresults&page=1&pos=4

OFAC has also published 2 new FAQ related to digital currencies –

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_compliance.aspx

WEAPON SUPPLIES INTO SOUTH SUDAN’S CIVIL WAR

Conflict Armament Research has published a new report, based on 3 years of fieldwork, which shows how military equipment has reached all sides of South Sudan’s civil war: through the intermediation of neighbouring states, through networks of brokers and intermediaries, and via air and land logistics.  South Sudan’s warring sides signed the peace agreement in September to end a 5-year civil war that has killed nearly 400,000 people.  Amongst the findings of the new report are that a key broker of the latest deal to end South Sudan’s civil war diverted European weapons to South Sudan’s military despite an EU arms embargo, and a US military jet ended up deployed in South Sudan in possible violation of arms export controls.  Uganda bought arms and ammunition from at least 3 EU members — Bulgaria, Romania and Slovakia — that were diverted to South Sudan’s military and armed allies in Sudan.  A network of “jointly owned Ugandan and US companies — controlled by UK, Israeli, Ugandan, and US nationals — procured a military jet from the US and an Austrian-made surveillance aircraft.

http://www.conflictarm.com/reports/weapon-supplies-into-south-sudans-civil-war/

IRELAND’S TAX HIKE FOR BETTING OPERATORS WILL GO AHEAD AS PLANNED ON JANUARY 1st

On 28th November, Calvin Ayre reported that Ireland’s tax hike for betting operators will go ahead as planned on January 1st while the government conducts its review of the hike’s impact.  After reports that it would be delayed, the Finance Ministry has confirmed that the rise – as well as the increase in betting exchange commission tax from 15% to 25% – will go ahead as scheduled.  The Ministry has promised to consider revising the tax in the nation’s 2020 budget depending the results of the review.

https://calvinayre.com/2018/11/28/business/ireland-betting-tax-hike-on-schedule/

2018 GLOBAL WHITE COLLAR CRIME SURVEY

More than a third of people working in legal or compliance departments have felt under pressure to approve the engagement of a third party despite bribery and corruption “red flags”.  The Law Society Gazette on 28th November reported that, according to the 2018 Global White Collar Crime Survey, 40% of employees reported such pressure, 5% said they always felt it, 14% said they often felt it and 21% said sometimes.  On top of this, 48% believe that people who pay bribes on behalf of their company are rewarded internally or personally while 29% are unaware of whether their place of work has any anti-bribery and corruption (ABC) measures in place.  88% said they would be inclined to raise any potential issues internally, rather than externally. However, only 3% said they would make use of a whistleblowing hotline, and only 2% would go to a regulator or authority.

https://www.lawgazette.co.uk/law/lawyers-dont-let-bribery-scupper-a-good-deal-survey/5068482.article

The survey report is available at –

https://www.whitecase.com/sites/whitecase/files/white-collar-survey-37-web.pdf

UK: ONLINE GAMBLING OPERATORS FINED AND BARRED IN CRACKDOWN

The BBC reported on 28th November that the Gambling Commission has fined 3 operators almost £14 million for not having “effective safeguards” to prevent money laundering and harm to customers from gambling – Daub Alderney is to pay £7.1 million, Casumo £5.85 million and Videoslots £1 million.  CZ Holdings, surrendered its licence to operate in the UK.

According to CasinoDB, CZ Holdings Ltd is (was) licensed and regulated by the Gambling Commission allowing them to take bets from players based in the UK.  Parent is CZ Trading Limited, the registered operator of the “Dr Vegas” online casino brand based in Malta and offering online casino gambling services to customers throughout Europe.  CZ Holdings Ltd is another Malta-based company and both companies are based in Malta.

https://www.bbc.co.uk/news/business-46382717

https://www.thecasinodb.com/operators/info/cz-trading-limited/20

EU ADDS BADI SALAH TO LIBYA SANCTIONS LIST

EU Regulation 2018/1863/EU added Badi Salah to its Libya sanctions list with effect from 28th November.  He is senior commander of the armed anti-GNA Al-Somood front, also known as Fakhr or “Pride of Libya”, and the Misratan Al Marsa Central Shield brigade.

See also Council Decision 2018/1863/CFSP.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2018.304.01.0001.01.ENG&toc=OJ:L:2018:304:TOC

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/760465/Notice_Libya_2018_1863.pdf

THE UK JOINT MONEY LAUNDERING INTELLIGENCE TASKFORCE (JMLIT)

NCA provides on its website information about JMLIT, which has been set-up in partnership with the financial sector to combat high-end money laundering.  Established as a “business as usual” function in May 2016, JMLIT has been developed with partners in government, the British Bankers Association, law enforcement and more than 40 major UK and international banks under the leadership of the Financial Sector Forum.  The taskforce has analysed information and expertise in the public and private sectors to better understand the true scale of money laundering and the methods used by criminals to exploit the UK’s financial system and terrorists using the financial systems to finance attacks.  It says that NCA is working with colleagues from overseas law enforcement agencies to help inform the development of similar partnerships in a number of countries around the world including in Australia, Hong Kong, Singapore and the USA.

jmlit

http://www.nationalcrimeagency.gov.uk/about-us/what-we-do/economic-crime/joint-money-laundering-intelligence-taskforce-jmlit

ACCOUNT FREEZING ORDERS & ACCOUNT FORFEITURE ORDERS

On 28th November, Greenberg Traurig published Part III of its series on asset recovery powers available to UK law enforcement authorities focuses on new powers under the Criminal Finances Act 2017 to obtain orders to freeze bank accounts and apply for forfeiture orders, permanently depriving the account holder of the funds contained in the account.

https://www.gtlaw.com/en/insights/2018/11/prove-it-or-lose-it-part-iii-a-step-too-far-account-freezing-orders-and-account-forfeiture-orders