October 23, 2020 – Page 2

NETHERLANDS: A BAN ON CASH PAYMENTS OF €3,000 AND MORE

On 13 October, NautaDutilh published an article saying that the Dutch government has drawn up a joint ‘Plan of action Anti-Money Laundering’ including various measures to increase the barriers to money laundering. One of the proposed measures is to limit large cash payments – there is currently no maximum for cash payments in the Netherlands. Now a draft law includes a total ban on cash payments of €3,000 or more for traders, and that ban cannot be circumvented by means of several individual cash payments. It is said that, given that the Council of Ministers approved the bill on 25 September and will forward it to the Council of State, it still seems feasible for the ban to enter into force by 2021.

https://www.nautadutilh.com/en/information-centre/news/legislative-bill-prevention-of-money-laundering-act-a-ban-on-cash-payments-of-eur-3000-and-more-for-traders

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at https://www.buymeacoffee.com/KoIvM842y

UK (AND ISLE OF MAN) ADDS RUSSIANS AND GRU ENTITY TO CYBER SANCTIONS LIST

On 23 October, a Notice from HM Treasury advised that Dmitry Sergeyevich BADIN and Igor Olegovich KOSTYUKOV (who is already listed under the chemical weapons sanctions), as well as the 85^th MAIN CENTRE FOR SPECIAL SERVICES (GTSSS) OF THE MAIN DIRECTORATE OF THE GENERAL STAFF OF THE ARMED FORCES OF THE RUSSIAN FEDERATION (GU/GRU) have been added to the UK Consolidated List pursuant to EU Regulation 2020/1536/EU.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/928912/Notice_Cyber-Attacks_2020_1536.pdf

https://www.gov.im/news/2020/oct/23/financial-sanctions-cyber-attacks/

IRAQ EMERGES AS NEW FRONT FOR ENFORCEMENT OF IRAN OIL SANCTIONS

On 23 October, the Wall Street Journal reported that Iranian tankers now regularly transfer crude to other ships just miles offshore the major Iraqi port of Al Faw, according to officials. The oil is then mixed with cargoes from other places to disguise its origin, and it eventually ends up on sale in world markets. For example, it says, in March 230,000 barrels of oil from the state-run National Iranian Oil Co. were transferred to a vessel moored in Iraqi waters.

https://www.wsj.com/articles/iraq-emerges-as-new-front-for-enforcement-of-iran-oil-sanctions-11603445401