An e-book from Sanctions Scanners is a collection of views of people described as AML experts from all over the world about the expected changes in AML after COVID-19.
https://sanctionscanner.com/Static/Ebooks/Expected-Changes-in-AML-after-COVID-19.pdf
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The European Studies Unit at Liege University produced in April an article by article guide to the EU control regime for these items.
http://local.droit.ulg.ac.be/jcms/service/49/pdf/eutcr/eutcr_full.pdf
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An article from McCann Fitzgerald on 29 June examines a recent Irish Supreme Court case in which the Court devised a test to identify a “manager” for the purpose of the prosecution of waste offences, in a judgment with implications for offences relating to theft and fraud; investment; health, safety and welfare at work; company law; and tax. It did so because it had been asked to consider the degree of responsibility required for an individual to be considered a “manager” capable of being found guilty of an offence. The relevant provisions are said to cover not just environmental offences, as in the case in question, but also those relating to theft and fraud; investment; health safety and welfare at work; company law; and tax. Essentially, the point was that it was a person’s real-world function and role that was decisive, not their nominal job title.
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On 29 June, the AFA in France published a guide intended to help businesses to prevent, detect and act in the face of the risks of corruption, favouritism, illegal taking of interests or embezzlement of public funds. It provides a toolkit to develop risk mapping and an anti-corruption code of conduct, as well as advice on how to prevent and deal with sensitive situations.
The guide itself (in French, bien sùr) is available at –
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On 3 July, the SEC and US DoJ published a revised guide to the Foreign Corrupt Practices Act described as a detailed compilation of information and analysis on the FCPA and the enforcement of related laws. It is intended to provide useful information to the public, including professionals and businesses of all shapes and sizes, from small businesses doing business abroad for the first time to multinational companies with branches around the world.
https://www.justice.gov/criminal-fraud/fcpa-resource-guide
The Guide is available online at –
https://www.justice.gov/criminal-fraud/file/1292051/download
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Recommended: Kharon has produced a 42-minute webinar and says that on 25 June the US sanctioned companies operating in Iran’s metals sector. Iran has turned to metals as an economic lifeline after US sanctions and other declines decimated its energy sector. To expand production of steel and other metals products, such as aluminium, the Iranian metals sector accesses raw materials and production technology from foreign and domestic suppliers, despite US trade prohibitions against the sector. Kharon says that Iranian metals producers have exported extensively to international markets, creating risk for firms across commercial supply chains. The briefing provides an overview of the industry and associated US sanctions and considers 3 case studies demonstrating international supply chain exposure associated with the Iranian metals sector.
https://info.kharon.com/events/2020/iran-metals-ondemand-viewer
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On 4 July, Sahara Reporters carried an article about the fraudulent activities of Abbas Ramon Olorunwa, 38, widely known as “Hushpuppi”. It is claimed that he conspired with several others across various parts of the world to execute huge financial scams by defrauding individuals and redirecting hefty payments meant for organisations into private bank accounts in countries like Romania, Bulgaria and UAE – and specialised in business email comprise (BEC) fraud. Formerly resident in Dubai, he was arrested under an Interpol notice and extradited to the US to face charges.
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On 1 July, ACAMS reported that the coalition wants amendments that would reform, refine and retool the country’s financial crime compliance defences. They want the changes made to added to the National Defense Authorization Act (NDAA) 2021. The amendments would cover several AML subject areas, including beneficial ownership.
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On 3 July, the Times of Malta reported that the Individual Investor Programme will end in September irrespective of whether or not the 1,800 cap is reached and a new residency programme to take its place. The new programme has no specific name and offers 2 routes to citizenship through residency. Before applying, the applicant will have to pass a due diligence test, which is different from the current programme where the checking process is done after the application is filed.
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raytodd.blog 