OTHER THINGS YOU MAY HAVE MISSED – AUGUST 1

Panama Covid-19 update – too early for the daily news conference, so at least no depressing listing of the latest infections and fatalities.  Meanwhile, the press reports that more than 1.5 million Panamanians (out of a population of around 4.3 million) have received a “solidarity bag” or bags containing food and basic necessities, cleaning and sanitiser materials, a digital and physical voucher.  There have been protests about slow deliveries of the food and necessities, which have cost the government some $60 million.

1 August 2020

ZIMBABWE: TRUCK DRIVER ARRESTED FOR SMUGGLING 12,500 BOTTLES OF BRONCO COUGH SYRUP

On 1 August, Pindula News in Zimbabwe reported that a truck driver has been arrested on charges of smuggling 12,500 100 ml bottles of cough syrup Broncleer (bronco) which has a street value of $2.5 Million from South Africa. Bronco is used as a recreational drug by some people in Zimbabwe.

https://news.pindula.co.zw/2020/08/01/truck-driver-arrested-for-smuggling-12-500-bottles-of-bronco/

INTERNATIONAL DATA TRANSFERS FROM THE EEA AND UK: TAKE CARE

On 31 July, HFW published a briefing saying that the Schrems II judgment, handed down by the Court of Justice of the European Union (CJEU) on 16 July, is significant for any organisation which currently transfers personal data outside of the EEA or the UK. It is especially significant for organisations which currently transfer personal data from the EEA or the UK to the US.

https://www.hfw.com/International-data-transfers-from-the-EEA-and-UK-Take-care-July-2020

BREXIT: NORTHERN IRELAND EU VAT IDENTIFICATION NUMBER

On 1 August, VAT Live reported that the EU will grant Northern Ireland businesses an EU VAT identification number to enable them to report goods transactions after 31 December 2020, the end of the Brexit transition period, when Northern Ireland adopts a dual participation role in the UK VAT and customs system, and the EU VAT, customs and Single Market – for goods only.  For services, it will be treated as remaining solely within the UK VAT regime. Northern Ireland remaining inside the EU systems (for goods only) prevents the need for physical border checks at the Irish border. Movements of goods between Northern Ireland and Ireland will remain as before Brexit.

https://www.avalara.com/vatlive/en/vat-news/uk-brexit-northern-ireland-eu-vat-identification-number.html

see also the following on the post-Brexit Northern Ireland VAT position –

https://www.avalara.com/vatlive/en/vat-news/uk-northern-ireland-vat-post-brexit.html

SERBIAN DRUG LORD GETS 9 YEARS JAIL FOR MONEY LAUNDERING

On 31 July, OCCRP reported that Belgrade High Court has sentenced 13 Serbian members of a criminal group led by drug lord Darko Šarić, with Šarić receiving a 9-year sentence for laundering millions of dirty drug money.  The group was involved in the production and trade of drugs and invested the proceeds into “legal money streams to hide its illegal origin”.

https://www.occrp.org/en/daily/12894-serbian-drug-lord-gets-nine-years-jail-for-money-laundering

TURKEY SUSPENDS SEA SURVEY OFF CYPRUS AFTER EU SANCTIONS THREAT

On 31 July, World ECR reported that Turkey had announced that it was planning to carry out a seismic survey south of 3 Greek islands, which would last until 2 August. Turkish media reported that President Recep Tayyip Erdogan had instructed his aides to ‘be constructive and put this on hold for some time,’ due to increased tensions with neighbouring Greece and prompted criticism by the US, Germany and other European countries.  Turkey has insisted that its drilling activity is part of an agreement with the Turkish Cypriot government in Northern Cyprus.

https://www.worldecr.com/news/turkey-suspends-sea-survey-after-eu-sanctions-threat/

SWISS SAY HUMANITARIAN TRADE CHANNEL TO IRAN IS UP AND RUNNING

On 31 July, World ECR has reported that Switzerland has announced that a humanitarian aid channel (the Swiss Humanitarian Trade Arrangement or SHTA), set up with US approval to allow Swiss-based companies to send medicines and other vital goods to Iran, has become operational, after a delay of several months following a pilot deal in January.

https://www.worldecr.com/news/swiss-say-humanitarian-trade-channel-to-iran-is-up-and-running/

IRELAND: PREPAREDNESS FOR DAC 6 MANDATORY TAX CROSS-BORDER DISCLOSURE REGIME

Irish law firm Matheson has published the results of a poll it undertook during a webinar involving Irish businesses. The firm asked its audience, made up of a mix of intermediaries and taxpayers what their state of readiness was on 8 July. The results, it says, were somewhat surprising.  It says that the most surprising results were that 16% of all respondents felt that their organisation was unprepared for DAC6 and only 3% of organisations polled felt that they were ready to file reports.

https://www.matheson.com/images/uploads/brexit/business/DAC6_Webinar_Attendees_Poll_2020.pdf

CRYPTOCURRENCY AND ICO IN THE BVI

On 30 July, Ogier published a briefing arguing that a BVI company offers a number of advantages which have made the BVI an attractive Initial Coin Offer (ICO) base. As a result, it says, the jurisdiction has seen a number of highly successful launches during the last 12 months.

https://www.ogier.com/publications/crypto-currency-and-icos-in-the-british-virgin-islands

THE RISE OF RANSOMWARE AND LEGAL COUNTERMEASURES

On 24 July, Field Fisher published an article which starts by saying that ransomware attacks, vicious malware that locks users out of their devices or blocks access to files until a sum or money is paid, are becoming increasingly prevalent across the globe.  For example, smartwatch company Garmin was forced to shut down its call centres, website and other online services after a ransomware attack encrypted its internal network and production systems.  Both the number of ransomware attacks and the percentage of attacks that result in payment have increased every year since 2017.  The article sets out to answer the question: when a company has no choice but to pay a ransom to get their business back online, does it have any means of subsequently recovering that money and tracing the perpetrators?

https://www.fieldfisher.com/en/services/fraud-financial-crime-and-investigations/fraud-corporate-crime-blog/the-rise-of-ransomware-and-legal-countermeasures

NEW EU REPORT SUGGESTS CONSUMER PROTECTION APPROACH TO TACKLE LOOT BOXES

On 27 July, an article from Field Fisher reported that a new report commissioned by the European Parliament’s Committee on Internal Market and Consumer Protection (IMCO) recommends tackling the topic of loot boxes by looking beyond gambling aspects and approaching the issue from a wider consumer protection angle.

https://www.fieldfisher.com/en/services/technology-outsourcing-and-privacy/technology-and-outsourcing-blog/consumer-protection-approach-to-tackle-loot-boxes

The report is at –

https://www.europarl.europa.eu/RegData/etudes/STUD/2020/652727/IPOL_STU(2020)652727_EN.pdf

NETHERLANDS: ULTIMATE BENEFICIAL OWNERS REGISTER UPDATE

On 24 July, an article from Field Fisher says that on 7 July, the Dutch government announced that the long awaited UBO register, of which the implementation is mandatory by EU law, will be implemented as per 27 September. The article explains what an UBO is in Dutch law and about the register and privacy matters.

https://www.fieldfisher.com/en/insights/ultimate-beneficial-owners-register-update

A GUIDE TO OPEN SOURCE NUCLEAR DETECTIVE WORK

On 28 July, the Nuclear Threat Initiative published this interesting article saying that images and videos contain an incredible amount of information that can be used to better understand military capabilities around the world – including nuclear weapons and long-range missiles. As an illustration of what can be done, the article provides an interactive detailing our analysis of a military exercise conducted by the US and UAE outside Dubai in 2018.

https://www.nti.org/analysis/articles/build-your-own-new-tools-toolbox-a-guide-to-open-source-nuclear-detective-work/

CENTRAL AFRICAN REPUBLIC: US ARMS EMBARGO

On 21 July, KPMG reported on a final rule amending the International Traffic in Arms Regulations (ITAR) to reflect an arms embargo concerning the Central African Republic.  No broker may engage in or make a proposal to engage in brokering activities subject to the ITAR involving the Central African Republic without first obtaining the approval of the Directorate of Defense Trade Controls (DDTC).

https://home.kpmg/us/en/home/insights/2020/07/tnf-us-arms-embargo-concerning-central-african-republic.html

https://s3.amazonaws.com/public-inspection.federalregister.gov/2020-13511.pdf

INDIA’S BAN ON CHINESE APPS

On 1 August, an article in Eurasia Review says that India recently banned 59 mobile applications of Chinese origin, including Tik Tok and WeChat.  It says that some analysts have speculated that the ban was driven by recent hostilities across the border but there is more to the move than meets the eye. Recent Sino-Indian skirmishes could have triggered the ban but other reasons exist, including supporting domestic technology firms and aligning with partners like the US on digital issues. However, the rationale for banning these Chinese apps rests on “national security concerns”.

https://www.eurasiareview.com/01082020-tik-toked-indias-ban-on-chinese-apps-analysis/

HOW DID TURKEY GAIN CONTROL OF LIBYA?

An Op-ed in Eurasia Review on 1 August asked this question, saying that Turkey is backed by Qatar and wants to control the Muslim Brotherhood in the region and to place the region under Turkey and Qatar.

https://www.eurasiareview.com/01082020-how-did-turkey-gain-control-of-libya-oped/

UK: EXPLAINING PERSONAL INSOLVENCY AND THE LAW

On 29 July, The Faculty of Law at the University of Oxford published a post which outlines the central features of the current personal insolvency system in England and Wales, and highlights key elements of this calculation in the context of the financial difficulties currently facing leaseholders.

https://www.law.ox.ac.uk/housing-after-grenfell/blog/2020/07/explaining-personal-insolvency-and-law

TREATY BANNING CLUSTER MUNITIONS TURNS 10 YEARS OLD – BUT WITHOUT THE US

An article in Just Security on 31 July reminded one that the Convention on Cluster Munitions entered into force 10 years ago, on 1 August 2010.  It was seen as a major advance for protecting civilians both during and after armed conflict.  The international treaty comprehensively banned cluster munitions and requires member countries to clear areas contaminated by cluster munition remnants within 10 years, destroy their cluster munition stocks within 8 years, and provide assistance for victims. The article asks, 10 years later, how is the Convention doing?  What challenges has it faced?

https://www.justsecurity.org/71756/treaty-banning-cluster-munitions-turns-10-but-without-the-us/

https://humanitariandisarmament.org/2020/07/31/convention-on-cluster-munitions-celebrates-10th-anniversary-a-living-legacy/

COOPERATION ON MILITARY TECHNOLOGY FOR THE DEVELOPMENT OF UAV AND CRUISE MISSILES IN THE ASIA-PACIFIC

On 28 July, a research paper from the International Institute for Strategic Studies examines the increased likelihood that UAV and cruise-missile technologies will proliferate throughout the Asia-Pacific. It argues that a technological  revolution is providing state and non-state actors with capabilities that previously belonged only to great powers. Advances in specific technologies and manufacturing are broadening access to long-range precision-strike capabilities, and an increasing number of states have an incentive to take advantage of this – particularly those that share a border with China.  It says that UAV and cruise-missile proliferation is seeing the same pattern of cooperative, facilitated proliferation of ballistic missiles (e.g. North Korea-Pakistan, Ukraine-China, Iran-North Korea).  Moreover, it argues, while developing nations have historically piggybacked on stronger states through technology sharing, today they are assisted through a number of sharing modalities and mechanisms, including technology adoption, overt cooperation (either co-production or co-development) and sales. To complicate matters further, these mechanisms may also be executed by non-state actors (from violent extremist organisations to defence contractors).

https://www.iiss.org/-/media/files/research-papers/cooperation-on-military-technology-for-the-development-of-uavs-and-cruise-missiles-in-the-asiapacifi.pdf

THE ILLICIT TRADE IN SMALL ARMS AND AMMUNITION IN VENEZUELA

On 27 July, Armament Research Services (ARES) announced the release of Research Report No. 10 which examines a new and thriving segment within Venezuela’s black-market arms trade, which has proliferated primarily through social media and secure messaging platforms – and focusing on those trades made via online platforms. Findings include diversion of arms from Venezuelan security forces; and strong connections to the US domestic firearms market.

http://armamentresearch.com/wp-content/uploads/2020/07/ARES-Research-Report-10-Black-Grey.pdf

SINGAPORE: HIGH COURT SETS OUT NEW SENTENCING FRAMEWORK FOR PUBLIC SECTOR CORRUPTION INVOLVING AGENTS

On 31 July, an article from Baker McKenzie reported that the new sentencing framework aims to provide the Singapore courts with a consistent and coherent methodology when dealing with such offences going forward.

https://globalcompliancenews.com/singapore-high-court-sets-out-new-sentencing-framework-for-public-sector-corruption-involving-agents-27072020/

THE TACTICS AND TARGETS OF DOMESTIC TERRORISTS IN THE US

On 30 July, a briefing from the Center for Strategic and International Studies says that, with a rise in domestic terrorism, it is increasingly important to analyse trends in terrorist tactics and targets.  According to CSIS data, firearms were the most common weapon used in fatal attacks over the past 5 years by far-right, far-left, and Salafi-jihadist terrorists. In addition, the most common targets were individuals based on their ethnicity, race, or religion (such as African Americans, Latinos, Jews, and Muslims) for right-wing extremists; and government, military, and police targets for left-wing extremists and Salafi-jihadists.

https://www.csis.org/analysis/tactics-and-targets-domestic-terrorists

IMPACT OF PENTAGON WEAPONS SPENDING ON JOBS (AND VOTES) IN 4 BATTLEGROUND STATES FOR THE 2020 US ELECTION

On 30 July, Forbes Magazine published an article saying that Pentagon weapons spending can potentially play a role in the election. Major programme awards can be worth billions of dollars and generate thousands of jobs within a state. For instance, the Navy recently selected a struggling Wisconsin shipyard to build a future class of frigates, potentially transforming that yard into a reliable source of jobs for decades to come. The Trump White House lost little time in taking credit.

https://www.forbes.com/sites/lorenthompson/2020/07/30/impact-of-pentagon-weapons-spending-on-jobs-and-votes-in-four-battleground-states/#3b148c4742e4

CORRUPTION IN CORONAVIRUS-RELATED PUBLIC TENDERS IN GEORGIA

An article from Bellingcat on 31 July says that, with the coronavirus pandemic and the sudden need for new government services, instead of utilising electronic tenders, so-called simplified state procurements take place in Georgia. This practice implies awarding non-competitive government contracts to companies, which may result in graft and breaches that include bribery, favouritism, influence peddling and self-serving purposes of the ruling party.

https://www.bellingcat.com/news/rest-of-world/2020/07/31/corruption-in-coronavirus-related-public-tenders-in-georgia/

WHEN GODFATHERS BECOME ENTREPRENEURS: ORGANISED CRIME’S INFILTRATION IN LEGAL ECONOMY – ITALY AND POTENTIAL EFFECT OF COVID-19

On 1 August, a post from VOX, the Centre for Economic Policy Research in Europe, says that criminal organisations invest vast sums of money within the legal economies of many countries worldwide. These investments provide criminal organisations with a powerful tool to raise forms of social consensus in some portions of the population. The article provides a characterisation of organised crime’s investment in Italy’s legal economy, a country historically plagued by the presence of criminal groups. The results indicate that during periods of economic and social downturn, organised crime may capitalise on the weaknesses of the institutional response to the crisis, consolidating and possibly expanding, its role as an investor in the legal economy.

https://voxeu.org/article/organized-crime-s-infiltration-legal-economy

THE EFFECTS OF THE DIFFUSION OF DUAL-USE ENABLING TECHNOLOGIES ON STRATEGIC STABILITY

On 27 July, an article from the Center for International and Security Studies at the University of Maryland argues that, left unchecked, the diffusion of dual-use enabling technologies — such as additive manufacturing, AI, and advanced communication technologies — may pose threats to strategic stability. The rapid development of these technologies by the US and its allies and partners has taken place primarily in the private sector, and is largely stored and transported in easily-diffused digital formats.  It could lead, the article says, to significant innovation in, or even transformation of, competitors’ military forces.  To counter these threats, the US and its allies and partners need a common awareness of the factors that enable and constrain technological diffusion, adoption, and transformation.  This paper develops a model of the pathways through which enabling technologies could affect strategic stability, drawing on the literatures on technological invention, innovation, and evolution; nuclear proliferation; and conventional arms flows. It identifies 4 pathways – buy, beg, steal or copy; but it says that none of these pathways guarantee successful diffusion of technological inventions, and are subject to a variety of countermeasures.

https://cissm.umd.edu/sites/default/files/2020-07/Dual_use_tech_Strategic_stability_072720.pdf

EU STUDY ON DIRECTORS’ DUTIES AND SUSTAINABLE CORPORATE GOVERNANCE

On 29 July, the EU published this report which sets out to assess the root causes of “short-termism” in corporate governance, discussing their relationship with current market practices and/or regulatory frameworks, and to identify possible EU-level solutions  It also takes into account contributing to the attainment of the UN Sustainable Development Goals and the goals of the Paris Agreement on climate change.  It suggests that a possible future EU action in the area of company law and corporate governance should pursue the general objective of fostering more sustainable corporate governance and contributing to more accountability for companies’ sustainable value creation.  For this reason, for each driver, alternative options characterised by an increasing level of regulatory intervention have been assessed against the baseline scenario (no policy change).

https://op.europa.eu/en/publication-detail/-/publication/e47928a2-d20b-11ea-adf7-01aa75ed71a1/language-en

IMF COVID-19 ANTI-CORRUPTION TRACKER

Transparency International has looked at all countries currently receiving COVID-19 financial assistance and debt relief from the IMF to see which funds include specific anti-corruption measures and which do not. At present, of 81 countries receiving such aid, 57 have some anti-corruption measures, 21 do not, and 3 are where a review is still pending.

https://www.transparency.org/en/imf-tracker

https://www.transparency.org/en/blog/the-imf-covid-19-and-anti-corruption-the-story-so-far

FALLING FOUL OF AML LAWS RESULTS IN MULTI-MILLION DOLLAR FINES FOR KIWI COMPANIES

In its 2 August edition, Stuff in New Zealand reported that 2 linked operations processed well over $400 million of transactions between 2015 and 2019 in breach of laws designed to deter money laundering.MSI Group, was currency changing and the remittance of money, mainly from New Zealand to China, and OTT Trading, was doing the same thing in Auckland, running up $196 million of transactions in the same period 2015-19. They have been fined a total of over $7.5 million.

https://www.stuff.co.nz/business/money/122281820/falling-foul-of-antimoney-laundering-laws-results-in-multimillion-dollar-fines-for-kiwi-companies

ENCRYPT

 

 

 

 

 

 

 

 

 

 

 

 

WCO ISSUES ITS 2019 ILLICIT TRADE REPORT

On 30 July, the World Customs Organisation published its Illicit Trade Report for 2019 which offers a comprehensive study of illicit trade flows through an in-depth analysis of seizure data and case studies voluntarily submitted by 137 customs administrations worldwide. The report consists of 6 sections: cultural heritage; drugs; environment; IP rights, health and safety; revenue and security.

http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/enforcement-and-compliance/activities-and-programmes/illicit-trade-report/itr_2019_en.pdf?db=web

HONG KONG: AML/CFT MEASURES IN THE PERIOD OF COVID-19

On 30 July, the Hong Kong Monetary Authority issued a Circular to share observations and industry practices to assist Authorized Institutions in developing sustained efforts to cope with the evolving COVID-19 situation and support operational responses which are consistent with the risk-based approach.  Key observations and practices are highlighted in the Circular and further details are summarised in an Annex. It covers CDD under social distancing and travel restrictions, pressure on AML/CFT resources, and emerging threats and changes in customers’ behaviour.

https://www.hkma.gov.hk/media/eng/doc/key-information/guidelines-and-circular/2020/20200730e1.pdf

https://www.hkma.gov.hk/media/eng/doc/key-information/guidelines-and-circular/2020/20200730e1a1.pdf

CHINESE FISHING NEAR NORTH KOREA IS A SYMPTOM OF A BIGGER IUU FISHING PROBLEM

An article in The Diplomat on 31 July says that the Chinese government has been both lenient on North Korea sanctions and reluctant to tackle illegal fishing by its distant water fleet. It says that a study found more than 900 Chinese vessels fishing in these waters in 2017, and 700 in 2018, said to be roughly one-third of China’s entire distant-water fishing fleet, and that further research has shown similar levels of Chinese fleet activity in 2019. The article says that the evidence is indicative of a larger problem of illegal, unreported, and unregulated (IUU) fishing and other illicit activities, especially by distant water fishing (DWF) fleets, which threaten the long-term sustainability of fisheries resources and the economic, food, and environmental security of coastal countries, and not just North Korea. It says that China is currently the top DWF nation, comprising about 40% of global DWF operations. China continues expanding its DWF fleets across West Africa, South America, and the South China Sea and, while not all of China’s DWF operations are engaged in IUU, these fleets have often been seen fishing illegally in another countries’ EEZ or right up to the line, and have been caught exceeding fish catch quotas.

https://thediplomat.com/2020/07/chinese-fishing-near-north-korea-is-a-symptom-of-a-bigger-problem/

US SUPREME COURT SET TO REVISIT DECADES-OLD QUESTION: CAN COMPANIES BE HELD LIABLE FOR HUMAN RIGHTS ABUSES COMMITTED OVERSEAS?

On 1 August, an article from Baker McKenzie says that the Alien Tort Statute has been the subject of several US Supreme Court decisions over the past decade. The ATS is a statute that gives US federal courts jurisdiction to hear lawsuits filed by non-US citizens for torts committed in violation of international law. In recent years, plaintiffs have tried to use the ATS as a vehicle to hold multinational corporations liable for human rights violations and labour abuses committed abroad by their subsidiaries, suppliers, and other third-party business partners.  However, cases have established a presumption that the ATS does not apply extraterritorially. But in 2019 a new case challenged precedent by seemingly widening the scope of potential ATS liability, and this case is poised to reach the Supreme Court. The case in question is centred on financial support provided by the defendants to the cocoa farms in Ivory Coast where child labour is said to be used.

https://globalcompliancenews.com/united-states-supreme-court-set-to-revisit-decades-old-question-can-companies-be-held-liable-under-the-ats-for-human-rights-abuses-committed-overseas-27072020/

FACTSHEET: US POLICY ON THE EXPORT OF UNMANNED AERIAL SYSTEMS

On 27 July, this Factsheet was issued by the US State Department. It says that, despite the policy change announced by the Trump Administration on 24 July, 5 primary objectives with respect to UAS transfers remain unaltered –

  • To increases trade opportunities for U.S. companies;
  • To bolster partner security and counterterrorism capabilities;
  • To strengthen bilateral relationships;
  • To preserve U.S. military advantage; and
  • To prevent the proliferation of WMD delivery systems.

All potential military UAS transfers will continue to be subject to Department of State-led assessment and Department of Defense (DoD)-led assessment regarding technology security, as applicable.  All UAS transfers, including military UAS transfers, will be reviewed consistent with US international non-proliferation commitments, including under the Missile Technology Control Regime (MTCR).

https://www.state.gov/u-s-policy-on-the-export-of-unmanned-aerial-systems-2/

The statement on the change in US UAS export policy is at –

https://www.state.gov/trump-administration-approves-updated-unmanned-aerial-system-uas-export-policy/

Affected are UAS with a maximum airspeed less than 800 kmh and discretion over the strong presumption of denial for transfers involving such types.

US COURT OF APPEAL AFFIRMS BANK FRAUD CONVICTIONS IN SANCTIONS EVASION CASE

On 31 July, an article from Clifford Chance reported on what it says is the first appellate court decision to affirm a bank fraud conviction in the context of a scheme to evade US sanctions – involving Halkbank, a Turkish state-owned bank.   In the case, Mehmet Hakan Atilla and his co-conspirators helped to steer billions of US dollars to Iran by disguising Iranian oil proceeds as permissible payments and humanitarian assistance. The article points out that, since bank fraud charges carry a longer statute of limitations and do not require the same proof of willfulness as other potential offences, the practice of charging bank fraud heralds a significant expansion of potential criminal liability

https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2020/07/Second-Circuit-Affirms-Bank-Fraud-Convictions-in-Sanctions-Evasion-Case.pdf

OFAC’S LATEST SETTLEMENT PROVIDES AN IMPORTANT REMINDER ON STRENGTHENING COMPLIANCE PROGRAMMES

On 30 July, an article from Clifford Chance said that OFAC announced a settlement with Whitford Worldwide Company LLC, a cookware coating manufacturer based in the US, relating to sales by its non-US subsidiaries to Iran that occurred between 2012 and 2015, and allegedly caused by the company’s failure to identify and adequately manage its OFAC risk.  The article says that, while the conduct is more than 5 years old, the settlement provides important reminders for those focused on OFAC compliance and managing related compliance risks.

https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2020/07/Everything-But-the-Kitchen-Sink-OFACs-Latest-Settlement.pdf