A news release from FinCEN on 10 December reported a speech given by the director-general to the annual American Bankers Association/American Bar Association Financial Crimes Enforcement Conference, in which he discussed how information-sharing is critical to identifying, reporting, and preventing financial crime.  He provided important clarification on FinCEN’s information-sharing program under s.314(b) of the USA PATRIOT Act, and announced that FinCEN is issuing a new factsheet and rescinding previously issued guidance as well as a former administrative ruling (parts of which are incorporated into the guidance in the new Fact Sheet). 

https://www.fincen.gov/news/news-releases/fincen-director-emphasizes-importance-information-sharing-among-financial

https://www.fincen.gov/news/speeches/prepared-remarks-fincen-director-kenneth-blanco-delivered-virtually-american-bankers

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In its 11 December edition, the Express Tribune in Pakistan reported that sanctions have been imposed on 11 individuals, including a former Karachi police “encounter specialist” Anwar Ahmed Khan.  In Pakistan, Anwar Ahmed Khan is suspected of being behind more than 190 “hits” that led to more than 400 deaths, the UK claims.

https://tribune.com.pk/story/2275468/ex-karachi-cop-among-11-sanctioned-by-uk

 

 

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On 10 December, Al Jazeera reported that the head of Bosnia and Herzegovina’s top judicial body says he is standing down following pressure from fellow judges and Western diplomats to resign over corruption allegations, which he has denied.  Milan Tegeltija, a Serb, as headed the High Judicial and Prosecutorial Council (HJPC) since 2014.

https://www.aljazeera.com/news/2020/12/10/bosnias-top-judge-to-resign-amid-corruption-allegations

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On 10 December, the Daily Maverick reported that the board of Delta Property Fund – which owns a range of office properties that are largely occupied by government departments and entities – has seemingly taken a page out of Steinhoff’s playbook in informing shareholders about a forensic investigation that points to accounting failures and fraud at the real estate company.  The board appointed Mazars Forensic Services to conduct a forensic investigation into alleged procurement irregularities and misappropriation of funds at the company by senior executives.  However, it told shareholders that the Mazar forensic report will not be released as it is “confidential and subject to legal privilege” – a line used by Steinhoff after PwC, in a 7,000-page report, revealed a web of fraud at the retailer.  The article says that the “legal privilege” excuse has been used by others: Sasol when it commissioned a review of delays and cost overruns at its US-based Lake Charles chemical project and EOH, which suffered years of corruption.

https://www.dailymaverick.co.za/article/2020-12-10-another-sa-corporate-scandal-fraud-and-accounting-failures-at-delta-property-fund

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On 10 December, the Isle of Man Customs & Excise published an updated edition of its Notice 1000 MAN, first published in 2015 [and of which I wrote the original and updates to 2018…].  The Notice has been updated to refer to the just-published report from FATF, which is described as a valuable new resource which uses numerous case studies to explain how criminals exploit trade transactions to move money.

https://www.gov.im/media/1348726/notice-1000-man-trade-based-money-laundering-10-dec-20.pdf

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A Notice from HM Treasury on 10 December advised that 11 names had been added to the UK Consolidated List pursuant to the e Global Human Rights Sanctions Regulations 2020.  The 11 names comprise 10 individuals and the Terek Special Rapid Response Unit in Chechnya.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/943108/Notice_Global_Human_Rights_101220.pdf

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A 38-minute video presentation on 9 December involved expert analysts from Vortexa, Windward and C4ADS on the impact of trade sanctions on oil and shipping markets.  It looked at the tanker trade and Venezuela.  The reports referred to in the presentation are also available through the links below.

https://www.vortexa.com/insight/event-news-maritime-trading-risk-analysis-in-a-volatile-market

THE INTERWOVEN GLOBAL TANKER TRADE: THE VENEZUELA CASE STUDY

https://www.vortexa.com/insight/the-interwoven-global-tanker-trade-the-venezuela-case-study

SHIPPING NETWORKS IN THE WAKE OF U.S. SANCTIONS ON VENEZUELA

https://raytoddblog.files.wordpress.com/2020/12/18d8c-stayingafloat.pdf

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On 10 December, OFAC advised that a number of new names had been added to its Global Magnitsky sanctions lists.  OFAC describes those listed as being involved in serious human rights abuses in Haiti, Yemen and in Chechnya in Russia.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201210

https://home.treasury.gov/news/press-releases/sm1208

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Financial Transparency Advisers GmbH in Austria produced in November a 2-page factsheet on the potential consequences of inclusion in the FATF list of countries subject to enhanced monitoring (aka ICRG listing).  It explains the purpose and consequences of the process when FATF (or a FATF-style regional body) mutual evaluation has found significant shortcomings in a country’s AML/CFT systems, so that there might be a heightened risk of money laundering etc resulting.

https://media-exp1.licdn.com/dms/document/C4E1FAQFhxVveBsxIBg/feedshare-document-pdf-analyzed/0/1606237125625?e=1607702400&v=beta&t=pSNqw0nfX1SfJP3KntMr-peeig4_uEV_oM_DFHQxyk8

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A news release from the US DoJ on 9 December advised that DANIEL DANIEL of Miami, had pleaded guilty to the charge of conspiring to commit money laundering by concealing the proceeds of criminal activity.  It involved the proceeds of the illicit activities of the Shulaya Enterprise, a prolific criminal organisation dismantled in June 2017 upon the arrests of Shulaya and over 25 other members and associates of the Shulaya Enterprise.  The Shulaya Enterprise was an organized criminal group controlled by Razhden Shulaya, a “vor v zakone,” which is a Russian phrase translated roughly as “Thief-in-Law,” and which refers to high-level criminal figures from the former Soviet Union who receive tribute from other criminals and laypersons within the vor’s protection, licence criminal activity by others, and resolve disputes between members of the criminal community.  

https://www.justice.gov/usao-sdny/pr/thief-law-s-money-launderer-pleads-guilty-manhattan-federal-court

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