On 30th November, the European Sanctions Blog reported that Canada has imposed targeted sanctions (asset freezes and travel bans) against 17 Saudi nationals under Canada’s Magnitsky law.
Fascinating 20-minute video webcast from Al-Arabiya on 30th November on how Hizbollah (amongst others) uses the former Pablo Escobar-established Colombian drugs money laundering arrangements in Medellin to smuggle cocaine and launder its money. Highlights links into South America (Iran used to use Venezuela). It says the drugs were sent via Panama, Guatemala and Venezuela to the US. How the DEA infiltrated the network, but then the US apparently played down the Iran links. It claims the Hizbollah drugs trade was generating as much, or more, as it received from Iran. It also touches upon Hizbollah and Al-Qaida-linked groups’ involvement in the drugs trade through West Africa, and the link in terms of the cash that was transported between West Africa and Lebanon, and how Hizbollah money was used to fund US used car dealerships to acquire and trade in cars to generate more “clean” money through West Africa.
On 30th November, the House of Commons Library published a briefing paper on the Bill which would create a framework to enable law enforcement agencies and prosecutors to apply to a UK court for an ‘overseas production order’ requiring a person (in practice, generally a communications service provider or ‘CSP’) in a foreign jurisdiction to produce or grant access to electronic data for the purposes of investigating and prosecuting serious crime. An application would only be granted if the judge was satisfied that the data was likely to be of substantial value to the criminal proceedings or investigations for which it was sought, and that it would be in the public interest. The Bill was introduced in the House of Lords on 27th June and had its 3rd reading on 20th November and is due to have 2nd reading in the House of Commons on 3rd December.
10 STEPS TO CONDUCTING EFFICIENT AND EFFECTIVE SUPPLY CHAIN COMPLIANCE RISK ASSESSMENTS
AS part of its follow-up to a recent (free) online webinar, Baker McKenzie produced this one-page list of the 10 steps that a company can take to reduce and mitigate risks in the supply chain.
5 STEPS FOR INTEGRATING DUE DILIGENCE PROCESSES TO COVER GROWING SUPPLY CHAIN LEGAL COMPLIANCE RISKS
It also produced this one-page checklist
Another Occasional Paper from RUSI, on 29th November, discusses the ways that cyber-criminals manage the proceeds of their crimes, from employing money mules to using services such as mixers to obfuscate the proceeds’ origins. It offers recommendations for policymakers, law enforcement professionals and regulated entities to target and reduce these activities. It says that some financial institutions are exploring innovative methods of detecting money-mule accounts, and that potential responses to the threat include either expanding the list of businesses subject to AML obligations on a case-by-case basis, as and when new business models arise, or using a flexible definition – for instance, of a ‘money-service business’ – that is capable of covering novel cryptocurrency businesses. It also recommends that the UK government should provide guidance to regulated virtual currency exchanges on dealing with higher-risk counterparties, such as mixers of unregulated exchanges, and transacting in higher-risk cryptocurrencies, such as privacy coins. Such guidance will help exchanges assess the risks they face and prioritise mitigation measures.