Day: November 19, 2020

A release on Mondo Visione on 19 November reported that federal financial institution regulatory agencies have issued a joint fact sheet clarifying that bank and credit union compliance efforts to meet Bank Secrecy Act due diligence requirements for customers that are charities and other non-profit organisations should be based on the money laundering risks posed by the customer relationship.  It stresses that that charities and NPO as a whole do not present a uniform or unacceptably high risk of being used or exploited for money laundering, terrorist financing, or sanctions violations, and that banks and credit unions must develop risk profiles that are appropriate for the risks presented by each customer.  It provides examples of customer information that may be useful to banks and credit unions in determining those risk profiles.

https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20201119b1.pdf

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20201119b.htm

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On 19 November, the NCA published the latest annual report, saying that the year saw another record number of SAR, receiving and processing 573,085 (a 20% increase on the previous period of 478,437), with an 81% increase in requests for a defence against money laundering or terrorist finance (62,408).  Over the year £172 million was denied to suspected criminals as a result of Defence Against Money Laundering (DAML) requests – up 31% on the previous year’s £132million and over 3 times the £52 million denied in 2017/18.  The report also includes, for example, details of an additional £56 million that HMRC obtained through matching SAR with other data sets for criminal and civil intervention.

https://www.nationalcrimeagency.gov.uk/news/publication-of-the-2020-annual-report-on-the-suspicious-activity-reports-regime

The report is at –

https://www.nationalcrimeagency.gov.uk/who-we-are/publications/480-sars-annual-report-2020/file

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On 17 November, a report from C4ADS says that global internet connectivity has opened up a new era of distribution, facilitating direct-to-consumer transactions, rapid reaction to enforcement trends, and the delivery of retail, rather than wholesale, drug volumes through legal commercial delivery systems.  C4ADS says that it conducted extensive multilingual analysis of Chinese corporate entities, the open web and social media, to better understand the methods used.

https://c4ads.squarespace.com/s/Lethal_Exchange_Spread.pdf

See also the article from NPR –

https://www.npr.org/2020/11/17/916890880/we-are-shipping-to-the-u-s-china-s-fentanyl-sellers-find-new-routes-to-drug-user

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On 19 November, an article from Eversheds Sutherland reported that new figures from FCA reveal that half of its investigations into breaches of UK money laundering regulations have been discontinued since the beginning of 2020. The article reviews the current criminal enforcement landscape and takes a look at the numbers of investigations in more detail.  It is suggested that the data may be evidence of the FCA’s gradual realisation that prosecuting breaches to the criminal standard is very far from straightforward; that it is much quicker, easier and less expensive to pursue a civil outcome against regulated firms for breaches of MLR; and that, in view of the nature of many of the breaches under investigation, a civil/regulatory sanction is invariably the more proportionate outcome in any event.

https://www.eversheds-sutherland.com/global/en/what/articles/index.page?ArticleID=en/Financial-services-and-dispute-investigation/FCA_discontinues_half_of_its_investigations_into_criminal_breaches

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On 19 November, a Notice from HM Treasury advised that Houka Houka AG ALHOUSSEINI had been added to the UK Consolidated List.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/936820/Notice_Mali_Correction.pdf

https://www.gov.im/news/2020/nov/19/financial-sanctions-mali/

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On 19 November, OFAC announced that entities involved in exporting and using North Korean workers have been added to the SDN List.  Involved are 2 entities, Mokran LLC, a Russian construction company, and Korea Cholsan General Trading Corporation, a North Korean company operating in Russia, for having engaged in, facilitated, or been responsible for the exportation of forced labour from North Korea, including exportation to generate revenue for the Government of North Korea or Workers’ Party of Korea.  The amended entries also relate to those who have have engaged in, facilitated, or been responsible for the export of North Korean workers, to provide additional information regarding names and locations of the enterprises. These companies have been involved in sending North Korean workers to Russia and China and operate under a variety of assumed names.

https://home.treasury.gov/news/press-releases/sm1189

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201119

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On 18 November, Radio Free Asia claimed that the Iranian state shipping routes are continuing to evade US sanctions by operating via a complex network of companies and subsidiaries registered in Hong Kong, dozens of which are traceable to a purported individual in Shanghai named on publicly available records as Shen Yong.  It had earlier linked Shen Yong to 4 shipping companies registered in Hong Kong that were named as having done business with the IRISL.  It now says that further investigations have shown that Shen Yong is named on the records of some 37 companies registered in Hong Kong, which between them control at least 10 ocean-going container vessels and 5 oil tankers. Most are connected in some way with IRISL.

https://www.rfa.org/english/news/china/hongkong-iran-11182020174050.html

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