UK: CONSULTATION ON AMENDMENTS TO DISCLOSURE RULES

On 26 February, HM Attorney General’s Office launched a consultation on revisions to the Attorney General’s Guidelines on Disclosure and the CPIA Code of Practice and called for evidence.  This is said to be part of an ongoing project to identify and incorporate improvements to sources of guidance on disclosure – the process whereby relevant unused material, gathered during the course of an investigation, is provided to the defence.  The consultation closes on 22 April.  The 2 sets of guidance were revised to reflect the challenges of modern disclosure practice, including the increase of digital material and the delays this increase causes.

https://www.gov.uk/government/publications/consultation-on-revisions-to-the-attorney-generals-guidelines-on-disclosure-and-the-cpia-code-of-practice

https://www.gov.uk/government/news/attorney-general-seeking-feedback-on-new-disclosure-guidelines

 

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OFAC ADDS AN IRAQI TO TERRORISM SANCTIONS LIST

A news release from OFAC on 26 February advised that Ahmad AL-HAMIDAWI (who has several aliases) had been added to the terrorism sanctions list.

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200226_44.aspx

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OFAC DESIGNATES COMPANIES AND OFFICIALS LINKED TO THE MARTYRS FOUNDATION FOR HIZBOLLAH LINKS

A news release from US Treasury on 26 February advised that OFAC has designated 3 Lebanon-based officials and 12 Lebanon-based entities linked to the Martyrs Foundation, part of Hizballah’s support network.  Specifically, OFAC has designated Atlas Holding for being owned or controlled by the Martyrs Foundation, as well as senior Atlas official Kassem Mohamad Ali Bazzi, and 10 Atlas-affiliated companies.  Individuals Jawad Nur-al-Din and Sheikh Yusuf Aasi were also designated for being leaders or officials of the Martyrs Foundation, which was itself designated in July 2007. Mirath S.A.L., which is owned or controlled by Jawad Nur-al-Din, was also designated.

https://home.treasury.gov/news/press-releases/sm917

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200226.aspx

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OFAC REMOVES 13 ENTRIES FROM SOUTH SUDAN SANCTIONS LISTS

On 26 February, OFAC announced the removal of 13 entries from the list of those subject to sanctions in respect of South Sudan, including Israel Ziv (there are various aliases) and entities linked to Ziv.

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200226.aspx

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OFAC SETTLEMENT WITH SWISS-BASED SOCIÉTÉ INTERNATIONALE DE TÉLÉCOMMUNICATIONS AÉRONAUTIQUES SCRL (SITA) FOR IRAN SANCTIONS VIOLATIONS

On 26 September, OFAC announced that it had reached a settlement with SITA, which has agreed to pay $7,829,640 to settle its potential civil liability for 9,256 apparent violations of the terrorism sanctions regulations and totalling approximately $2,428,200 in 2013/2018.  The case involved SITA providing commercial services and software that were subject to US jurisdiction and benefitted certain airline customers after OFAC designated those airlines as specially designated global terrorists (SDGT).  SITA provides commercial telecommunications network and information technology services to the civilian air transportation industry, including Mahan Air, Syrian Arab Airlines, Caspian Air Meraj Air and Al-Naser Airlines.

https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20200226_sita.pdf

https://www.freightwaves.com/news/airline-systems-firm-pays-7-8-million-for-us-sanction-violations

 

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HUGE US MONEY LAUNDERING PROBE TARGETS WIDENING CIRCLE OF VENEZUELAN ELITES

The Miami Herald on 26 February reported that, after 2 years, necessary bank records have arrived, due to a major decision to release them by Switzerland’s highest court.  It is alleged that business elites are suspected of paying hefty bribes to government officials in exchange for making loans in bolivars to the national oil company, Petróleos de Venezuela SA, and then receiving repayments in US dollars — with the proceeds washed through the government’s favourable currency-exchange system to magnify profits – and then diverted to secret Swiss bank accounts between 2012 and 2014, according to US authorities.

https://www.miamiherald.com/news/local/article240482546.html

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ILLICIT TRADE NETWORKS – CONNECTING THE DOTS

The Institute for Science and International Security has published a free pdf e-book, containing a number of illustrative case studies, which explains strategic commodity trafficking, or illicit procurement, to assist in understanding what this activity is, who is involved, and how it occurs.  It explains the most basic activities of illicit trade and general structures of illicit networks.  It also discusses the international framework of and recent developments in proliferation financing.  It then goes on to explain how goods are shipped, having been illicitly acquired.  One section concentrates on the findings from a once-prominent transnational illicit network centred in China, the Cheng/Jamili network, which outfitted Iran’s nuclear, missile, military, and other sensitive programmes.  It is said that the case studies used are focused on the ordering, financing, and shipping processes, and showcase key illicit procurement methods in action.  Many of the case studies identify ways in which states and their associates seek and successfully obtain sensitive commodities. Other ones show when counter-proliferation methods have worked to thwart those efforts. These cases highlight ways in which countries can improve their detection and prevention of illicit procurement.  To conclude, the report draws together illicit procurement methods and tactics and their warning signs as potential “red flags” indicating the existence of illicit trading.  The report also recommends a range of policy steps that the US and other countries can take to more effectively detect and prevent illicit procurement today and in the future.

https://isis-online.org/uploads/isis-reports/documents/Illicit_Trade_Networks_Vol1_Connecting_the_Dots_February_2020_FINAL.pdf

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