OTHER THINGS YOU MAY HAVE MISSED – OCTOBER 26

Panama Covid-19 update – protests on the news by trainers and gym staff – which seems to be about the only business sector not yet reopened. However, unlike others, I have some doubts about adequate biosecurity, at least for that proportion of their membership that is more at risk – the young, fit people (which gyms always seem to be mostly catering for) are the least at risk, I guess. I have a gym membership, and used to go every weekday morning, but that (and the fee) has been suspended by law since March or April, and (though I would like to return, I am not sure I’d feel happy doing so…).

The daily statistics seem to be slowly ameliorating – although another 551 new cases today and 5 more fatalities. Another 3,655 tests carried out, with now said to be 21,403 active cases.

26 October 2020

UBS CUTS TIES WITH IVORY COAST CLIENTS

On 25 October, Bloomberg reported that a Swiss newspaper says that UBS Group AG has severed ties with customers in Ivory Coast.  It is said that Switzerland’s biggest wealth manager is closing the accounts and credit cards of all clients who live in the country.

https://www.bloomberg.com/news/articles/2020-10-25/ubs-cuts-ties-with-ivory-coast-clients-sonntagszeitung-reports

IN US LAWSUIT TO SEIZE JET ENTREPRENEUR’S $22 MILLION BEL AIR MANSION

On 23 October, Bloomberg reported that the US is seeking to confiscate a $22 million Los Angeles mansion from a company controlled by a private-jet entrepreneur, as it goes after assets it says the home’s previous owner bought with the spoils of corrupt Nigerian oil deals.  The case involves Sarbonne Estate Inc., or SEI, and Nigerian businessman Kolawole Aluko. Aluko.  Court documents have named Thomas Flohr as the sole owner of SEI, which he controls through an entity registered in the BVI.  SEI counters in filings that Flohr understood the Nigerian to be a man of legitimate means and had no reason to believe the businessman had acquired the property with ill-gotten gains.

https://www.bloomberg.com/news/articles/2020-10-23/u-s-out-to-seize-jet-entrepreneur-s-22-million-bel-air-mansion

PANAMA: CASE AGAINST 102 ODEBRECHT CORRUPTION CASE DEFENDANTS BEFORE COURTS IN DECEMBER

On 25 October, Newsroom Panama reported that until now 102 individuals  have been investigated but legal manoeuvres  have enabled some high profile figures to dodge the  bullet and others like former President Ricardo Martinelli have an army of   prominent lawyers  to stave off  prosecutors.  The investigation of the Special Anti-Corruption Prosecutor’s Office in the Odebrecht case is concerned with bribes that the Brazilian company gave in exchange for the allocation of public infrastructure works.

https://www.newsroompanama.com/news/case-against-102-odebrecht-defenfants-before-courts-in-december

ENFORCING US JUDGMENTS IN CANADA: A PRACTICAL GUIDE

On 1 August, Fasken Martineau DuMoulin LLP published an article poses the question: how does one enforce a US judgment against a Canadian party in Canada?  The article says that there have been significant developments in Canadian law respecting the recognition and enforcement of US and other foreign judgments in Canada over the past 30 years.  As a result of these developments, it is now easier, faster and cheaper to enforce foreign judgments in Canada.  However, it says, strict legal and procedural requirements remain.  The purpose of this article is to provide US lawyers practical advice respecting the legal and procedural requirements which will need to be met before a Canadian court will recognise and enforce a US judgment.  More unusual topics like foreign state immunity are beyond the scope of the paper.

https://www.lexology.com/library/detail.aspx?g=43439ed4-a7dd-4fdf-8f88-909205a33c1e

CIVIL LIABILITY FOR MONEY LAUNDERING IN SWITZERLAND: NEW CASE LAW IN THE FIELD OF ASSET RECOVERY COMES TO THE AID OF VICTIMS OF FINANCIAL CRIME

On 23 October, Baldi & Caratsch published an article saying that a recent judgment of the Swiss Federal Supreme Court comes to the aid of victims of financial crimes with a Swiss connection, as it extends and clearly defines the limits of civil liability for money laundering in Switzerland.  To understand the full significance of the new judgment, it is worthwhile to start with a review of the general principles of Swiss tort law and the earlier case law of the Swiss Federal Supreme Court before turning to the most recent developments.  It is said that the new case law is likely to lead to an increase in legal claims against banks and other providers of auxiliary services used by fraudsters, as it introduces a more reasonable burden to prove their ancillary liability.

https://www.lexology.com/library/detail.aspx?g=d2706c73-305f-4e64-9aa3-855dcac25b82

LAWSUIT AGAINST QATAR IN US FOR HAMAS FUNDING

On 25 October, the Saudi Gazette reported British newspaper reports that Palestinian terror group Hamas is secretly operating a facility in Turkey where it is carrying out cyberattacks and counterintelligence operations.  The headquarters, which is separate from Hamas’s official offices in the city, was set up without the knowledge of Turkish authorities, the report said.  According to the lawsuit, several Qatari financial institutions, controlled to a large extent by Emir Tamim Bin Hamad Al-Thani, provided millions of dollars to the Palestinian Hamas and Islamic Jihad movements under the cover of “charitable donations.”.

https://www.saudigazette.com.sa/article/599565/World/Mena/Lawsuit-against-Qatar-in-US-for-Hamas-funding

RUSSIA SENDS MORE MILITARY EQUIPMENT TO CENTRAL AFRICAN REPUBLIC

On 26 October, Defence Web reported that Russia has opened a representative office in the Central African Republic and donated 10 armoured vehicles to the country, the RIA news agency has said.  Russia has been solidifying its presence in the CAR in recent years, sending weapons and contractors and political advisors.

https://www.defenceweb.co.za/joint/diplomacy-a-peace/russia-sends-more-military-equipment-to-central-african-republic-ria/

EU ONE STEP CLOSER TO GLOBAL HUMAN RIGHTS SANCTIONS REGIME

On 23 October, an article from White & Case reported that the European Commission and the EU Foreign Policy High Representative have put forward a proposal for a new, non-country-based sanctions programme to address human rights violations and abuses with asset freezes and travel bans. This proposal must be approved by all 27 Member States within the EU Council before it becomes law, and before any designations can be made under the programme.

https://www.whitecase.com/publications/alert/eu-one-step-closer-global-human-rights-sanctions-regime

BANGLADESH: 36 TONNES OF BABY FOOD SEIZED OVER ‘SIGNATURE FORGERY’

On 26 October, the Daily Star reported that Customs had seized 36 tonnes of baby food items, citing of finding evidence of the importer – Siam Enterprise – using a fake website and forging the commerce ministry’s seal and signature.  Importers are required to secure a clearance permit (CP) from the commerce ministry for non-declared goods as well as restricted items such as baby food.

https://www.thedailystar.net/business/news/36-tonnes-baby-food-seized-over-signature-forgery-1984373

PRIVATE TRUST COMPANIES – OWNERSHIP AND GOVERNANCE STRUCTURES

On 26 October, an article from Appleby explores aspects of private trust companies, as well as the formation and ownership structures of US and non-US private trust companies.

https://www.applebyglobal.com/publications/ownership-and-governance-structures/

UK – FRESHWATER 5: RADAR CASTS DOUBT ON GUILTY VERDICT FOR £53 MILLION COCAINE HAUL

On 26 October, the Guardian reported that compelling new evidence from the radar of a Border Agency surveillance vessel casts doubt over the safety of the convictions of 5 men who were jailed in June 2011 for up to 24 years each for conspiracy to import cocaine.  Not disclosed during the original trial, the nautical navigation data from the vessel’s Electronic Chart Display and Information System (ECDIS) appears to show that information presented to the jury was incorrect.

https://www.theguardian.com/law/2020/oct/25/freshwater-five-radar-casts-doubt-on-guilty-verdict-for-53m-cocaine-haul

‘UNTOUCHABLE’ ATTORNEY ARRESTED AND CHARGED WITH HUMAN TRAFFICKING

On 25 October, USA Today reported that, following its investigation, Michael Mearan, 74, a former Portsmouth, Ohio, city councilman and still-practising attorney, trapped his victims in a cycle of drug abuse and sexual servitude.  After decades of rumours and investigations, Mearan was arrested on human trafficking, racketeering and related charges.

https://www.usatoday.com/story/news/nation/2020/10/24/michael-mearan-charged-sex-trafficking/6027744002/

UK SPECIAL FORCES STORM TANKER AND DETAIN STOWAWAYS IN ENGLISH CHANNEL

On 26 October, Hellenic Shipping News reported that British special forces stormed a Greek-operated oil tanker in the English Channel to wrestle control of the vessel from seven stowaways who had threatened the crew in a suspected hijacking.  Refinitiv vessel tracking data showed the Liberia-flagged Nave Andromeda had been expected to arrive in the English port of Southampton and the vessel had left from Lagos.

https://www.hellenicshippingnews.com/uk-sbs-special-forces-storm-tanker-and-detain-stowaways-in-channel/

UK: SANCTIONS (EU EXIT) (CONSEQUENTIAL PROVISIONS) (AMENDMENT) REGULATIONS 2020

On 26 October, a briefing from the House of Lords Library was concerned with the above Regulations, which would make amendments to 3 existing sets of regulations made under the Sanctions and Anti-Money Laundering Act 2018.  These amendments would allow the 2019 sanctions regulations to amend other existing pieces of primary and secondary legislation to ensure they contain up-to-date references to counter-terrorism sanctions legislation.  These changes form part of the legislative preparations for the UK to implement sanctions under domestic law after the end of the Brexit transition period. They would make amendments to the 3 regulations that have already been made under the 2018 Act. 

https://lordslibrary.parliament.uk/sanctions-eu-exit-consequential-provisions-amendment-regulations-2020/

THE COUNTY LINES MENACE, ITS FINANCIAL SYSTEM DEPENDENCE: A SOCIAL OBLIGATION TO DETECT VIA TECHNOLOGY

A briefing note from Themis International Services briefing note examines “county lines” drugs supplies as a financial crime typology, highlighting and educating the importance to understand its nuances and its dreadful impact.  Therefore, the briefing says, there is a call to action, to initiate and continue the conversation for a more practical, technical and data science-led response as well as addressing what steps need to be taken in ensuring a sufficiently informative SAR that could lead to the rapid safeguarding of our most vulnerable in society.  It says that, in the UK, the National County Lines Coordination Centre (NCLCC) estimated there have been 11,000 active deal lines reported as operational at any one time; and the principal commodity remains crack cocaine and heroin.  It is further said that the business model is very much reliant on exploiting the UK’s most vulnerable in society, predominantly children and vulnerable adults.  The majority of those involved in the operations are coerced and intimidated, representative of the tactics involved in cases of human trafficking, such as fear and violence.  Often forced into committing risky activities, such as acting as a drugs mule; carrying and transporting money, drugs, and weapons; street dealing, and perpetrating violence.

US: ELECTRONIC EXPORT INFORMATION (EEI) IN THE AUTOMATED EXPORT SYSTEM (AES) – FILING GUIDE

Torres Law has produced a guide to EEI, saying that the Foreign Trade Regulations (FTR) establishes the “mandate” for reporting all US export information via the Electronic Export Information (EEI) in the Automated Export System (AES).  The FTR requires that the United States Principal Party In Interest (USPPI), the USPPI’s authorised agent, or the authorised US agent of the Foreign Principal Party In Interest file an EEI through AES for all exports of physical goods.  It explains when an EEI filing is required.

https://www.torrestradelaw.com/ckfinder/userfiles/files/EEI%20Filings%20Guide.pdf

AL-QAEDA REMAINS CLOSE TO TALIBAN, SAYS UN OFFICIAL

On 17 October, Tolo News reported that a UN official had said the Taliban consulted with Al-Qaeda during the peace negotiations with the US, and that Al-Qaeda leader Ayman al-Zawahiri has maintained close ties with the Taliban despite the Taliban’s assurance to the US to cut ties with the group.  

https://tolonews.com/afghanistan-167111

PANAMA: REPORTING RELIEF FOR COMPANIES REGISTERED IN THE PANAMA-PACIFIC AREA

On 23 October, KPMG reported that Panama’s tax authority has issued Resolution No. 201-5503 (September 2020) that authorises an exemption for registered companies from having to use certain tax processes (equipos fiscales). 

https://home.kpmg/us/en/home/insights/2020/10/tnf-panama-reporting-relief-for-companies-registered-in-the-panama-pacific-area.html

PODCAST: THE ORDER THAT COULD POLITICISE THE US CIVIL SERVICE

On 26 October, Government Executive released a podcast in which former OMB official Robert Shea joins the podcast to discuss the latest executive order.  President Trump has signed an executive order that would create a new classification of “policy-making” federal employees; which it says is arguably the biggest effort in history to change more than 100 years of government policy promoting professional expertise in government.  The order has been roundly criticized by governance experts, employee groups and lawmakers, with many saying it could have far-reaching consequences on the federal workforce and the way government is executed.

https://www.govexec.com/management/2020/10/govexec-daily-order-could-politicize-civil-service/169540/

https://www.govexec.com/management/2020/10/agencies-have-wide-latitude-deciding-which-jobs-strip-civil-service-protections/169533/

MONEYVAL KEEPS ISLE OF MAN IN ENHANCED FOLLOW-UP BUT NOTES IMPROVED AML COMPLIANCE

On 26 October, STEP reported that MONEYVAL has kept the Isle of Man in its ‘enhanced follow-up’ special measures regime, although its evaluation report found the jurisdiction is fully or largely compliant on 20 of the FATF 40 recommendations.  It is reported that the remaining ‘serious’ deficiency relates to FATF Recommendation 23, largely concerning the reporting obligations on designated non-financial businesses and professions (DNFBP) when handling certain transactions, on which the jurisdiction remains partially compliant.  The rating on group-wide requirements for DNFBP is being put on hold, pending a FATF decision on the issue.

https://www.step.org/industry-news/moneyval-keeps-isle-man-enhanced-follow-notes-improved-aml-compliance

NETHERLANDS: HILVERSUM TRADERS GET UP TO 2½ YEARS FOR MONEY LAUNDERING AND €25 MILLION IN BITCOIN SEIZED

On 26 October, the NL Times reported that a court in Rotterdam sentenced a man and woman from Hilversum to 2 years and 2½ years in prison for money laundering. The court forfeited a total of 2,532 bitcoins, currently worth around €25 million, and €250,000 in cash. According to the Public Prosecution Service (OM), the Hilversum couple laundered over €16 million in 2½ years.

https://nltimes.nl/2020/10/26/hilversum-traders-get-25-years-money-laundering-eu25-million-bitcoin-seized

https://beincrypto.com/29-million-in-bitcoin-seized-from-dutch-dark-web-money-launderers/

CANADA: LOTTO CORPORATION STAFF WERE TOLD NOT TO INTERVENE IN SUSPICIOUS CASINO TRANSACTIONS

On 26 October, Global News reported that the restarted inquiry into money laundering through casinos in British Columbia has been told that investigators at the BC Lottery Corporation were ordered not to question high-rollers about massive cash transactions at a casino in Richmond.

https://globalnews.ca/news/7422199/cullen-commission-resumes-beeksma/

https://www.theglobeandmail.com/canada/british-columbia/article-bc-money-laundering-commission-resumes-hearings/

FinCEN OFFICIAL ACCUSED OF LEAKING SECRET BANK RECORDS REQUESTS TIME SERVED

On 26 October, OCCRP reported that a former US Treasury employee, Natalie Mayflower Sours Edwards, convicted of leaking confidential bank intelligence documents to a journalist has asked a federal court for leniency, portraying herself in a court filing as a dedicated public servant and frustrated whistleblower who wanted to expose misconduct in the agency and protect national security.  She also claims FinCEN may not have been providing complete information to a congressional committee probing Russian interference in the 2016 election.  BuzzFeed News published a series of reports in 2018 that appear to be based on leaked SAR, shared by Edwards.

https://www.icij.org/investigations/fincen-files/fincen-official-accused-of-leaking-secret-bank-records-requests-time-served

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

OFAC – IRAN SANCTIONS: NEW GENERAL LICENSE, UPDATED FAQ, ADDITIONAL INDIVIDUALS AND ENTITIES, PLUS 2 VESSELS, ADDED TO LISTS WITH OTHERS AMENDED

On 26 October, OFAC advised various changes to its Iran sanctions regime –

  1. New General License 8A – Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company;
  2. Several FAQ amended as a consequence;
  3. 8 individuals added to SDN List;
  4. 11 entities connected to the oil or shipping sectors added to SDN List;
  5. 2 crude oil sea tankers added to SDN Lists;
  6. Amendments made to existing entries for ABADAN OIL REFINING COMPANY, NATIONAL IRANIAN OIL COMPANY and NATIONAL IRANIAN TANKER COMPANY.

The additional sanctions measures target the Iranian oil and shipping industries and key associates, including those involved in gasoline supplies to Venezuela.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201026_33

https://home.treasury.gov/news/press-releases/sm1165

https://home.treasury.gov/system/files/126/iran_gl8a.pdf

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

OFAC – AMENDMENT OF CUBAN SANCTIONS REGULATIONS AND UPDATED FAQ

On 26 October, OFAC advised that a new Rule will be published in the Federal Register on 27 October, and will be effective 30 days later on 26 November.  It is also updated several related FAQ.  The idea behind the changes is to remove Cuba’s military-run entities from the remittance process.  Specifically, OFAC is amending the regulations to remove from the scope of certain remittance-related general authorizations any transactions relating to the collection, forwarding, or receipt of remittances involving entities or sub-entities identified on the State Department’s Cuba Restricted List (CRL). 

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201026

https://home.treasury.gov/news/press-releases/sm1164

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

Panama in World War 2 (updated again, again)

I have continued to update, purely for my interest, the notes etc I have made about the experience of Panama during WW2. I just kept finding odds and ends worth looking at and noting – such as the traffic switching from one side of the road to the other, all at once, on the blast of a siren at 5 am one morning in 1943 (though, even today, there is one “English Street”, where traffic runs on the “wrong” side of the road).

UPDATE 1 NOVEMBER 2020 – I have uploaded a replacement, and hopefully finally version of this pdf “scrapbook” (though every time I thin I am done I stumble across something else)…

The file has grown like topsy, and I have made it into a pdf, in large part to make it look better and professional.

Of course, as soon as I thought I’d finished it I found a tale of how 40,000 US sailors were given shore leave, all in one go, as the fleet was traversing the Canal in 1939 (leading to what was described as a “white tide” of men), and a Cole Porter musical featuring a character (“Panama Hattie”) based on a night club entertainer from Panama City during the war. They will have to wait the next update!

The project is entirely for my own interest and wholly non-commercial. I have tried to credit all the sources for any information and photos.

Any comments, corrections, amendments and additions are welcomed. Maybe now that Covid-19 restrictions are eased I can finally get out to see any of the remains of the wartime structures that might still be seen.

WHAT ART MARKET PARTICIPANTS NEED TO KNOW ABOUT CHANGES TO AML REGULATIONS

On 26 October, an article from Mishcon de Reya says that a 5-month extension has been granted to the time period that newly regulated art market participants have to register with HMRC for AML purposes – the deadline for registration is now 10 June 2021, instead of 10 January.  If they fails to register by 10 June, they must not carry on the defined activities within the scope of the regulations.  The new regulations will affect many working directly within the art market, such as high value dealers and auction houses, and potentially other parties such as agents, intermediaries and some artists.

https://www.mishcon.com/news/art-market-participants-what-you-need-to-know-about-changes-to-anti-money-laundering-regulations

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

OUTCOMES OF FATF PLENARY

On 23 October, FATF published a series of documents following the FATF Plenary of 21-23 October –

http://www.fatf-gafi.org/publications/fatfgeneral/documents/outcomes-fatf-plenary-october-2020.html

FATF RECOMMEDATIONS UPDATED

Revision of Recommendation 2 and a new Interpretive Note to Recommendation 2.

JURISDICTIONS UNDER INCREASED MONITORING

FATF continues to identify additional jurisdictions, on an on-going basis, that have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. A number of jurisdictions have not yet been reviewed by the FATF and FATF-style regional bodies.

http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-october-2020.html

PUBLIC STATEMENT ON COUNTER PROLIFERATION FINANCING

FATF has  adopted amendments to Recommendations 1 and 2 and their Interpretive Notes that require countries and the private sector to identify, and assess the risks of potential breaches, non-implementation or evasion of the targeted financial sanctions related to proliferation financing, as contained in FATF Recommendation 7, and to take action to mitigate these risks, as well as to enhance domestic co-ordination.

http://www.fatf-gafi.org/publications/financingofproliferation/documents/statement-proliferation-financing-2020.html

HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION

The list of high-risk jurisdictions has not changed since February, i.e. North Korea and Iran.

http://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/call-for-action-october-2020.html

THE IMPORTANCE OF ALLOCATING SUFFICIENT RESOURCES TO AML/CFT REGIMES DURING THE COVID-19 PANDEMIC

Statement by the FATF President.

http://www.fatf-gafi.org/publications/fatfgeneral/documents/covid-19-impact-oct-2020.html

FATF PRESIDENT’S REMARKS TO G20 ANTI-CORRUPTION MINISTERIAL

The FATF President calls for an investment in law enforcement,to plug the holes in the availability of beneficial ownership information, and an increase our oversight of the non-financial sectors, thegatekeepers to the financial system – such as lawyers, accountants and company service providers – need to be inside the regulatory tent.

http://www.fatf-gafi.org/publications/corruption/documents/g20-anti-corruption-2020.html

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

GAS FIELDS AND TENSIONS IN THE EASTERN MEDITERRANEAN

On 26 October, EurActiv said that the discovery in recent years of huge natural gas reserves in the eastern Mediterranean has whetted the appetite of nearby countries but exacerbated geopolitical tensions between Turkey and its neighbours; and relations have been strained in recent months following Turkish exploration and drilling operations in waters claimed by both Cyprus and Greece.  Cyprus, which has aspirations of becoming a major energy player in the region, has a key exclusive economic zone (EEZ), divided into 12 blocks and potentially rich in gas.

https://www.euractiv.com/section/energy-environment/news/gas-fields-and-tensions-in-the-eastern-mediterranean/

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

IRAQ EMERGES AS NEW FRONT FOR ENFORCEMENT OF IRAN OIL SANCTIONS

On 23 October, the Wall Street Journal reported that Persian Gulf waters off Iraq have become a new, important waypoint for Iranian oil smugglers looking to avoid US sanctions, according to US officials, who expressed frustration that Baghdad and other allies aren’t acting more aggressively to enforce curbs on commerce with Tehran.  Iranian tankers now regularly transfer crude to other ships just miles offshore the major Iraqi port of Al Faw, according to the 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.

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

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