Panama Covid-19 update – well, looking forward to a “dry” lockdown Christmas and New Year with a total quarantine from December 25 to 28 and January 1 to 4. The Ministry of Health has ordered supermarkets to receive 1person per family, except that they are accompanied by a minor or person with a disability (don’t know if/how they are expected to enforce that); but the local mall has already put in place limits on numbers allowed into its shops (e.g. up to in a small shop).
To see why the tight restrictions are needed one only needs to look at today’s statistics – a record number of 3,348 new cases and a record 42 fatalities (the latter figure maybe explaining why the ICU occupancy figure has actually declined to 173, after reaching a record 197 on Tuesday). Also, I think, a record number of active cases at 31,576 – as said, 173 in ICU and 1,390 in other wards.
17 DECEMBER 2020
NORWEGIAN BANK IN HOT WATER OVER “FISHROT” SCANDAL
On 17 December, KYC 360 reported that Norway’s largest bank, DNB, ended its relationship with Icelandic seafood company Samherji after the fishing company gave what the bank deemed inadequate explanations of payments to 3 offshore companies and a company owned by the son-in-law of Namibia’s former fisheries minister. Documents filed in the Windhoek High Court shed new light on why DNB closed the accounts of subsidiaries of scandal-hit Samherji last year. The bank has been under police investigation in Norway since the Fishrot Files were published last year.
EMPTY CONTAINER REPOSITIONING ISSUES CONTINUE TO CREATE SHORTAGES
On 17 December, Seatrade Maritime News reported that container shipping remains disrupted by box equipment shortages which are restricting available capacity and so forcing freight rates to record highs. However, this is being driven by empty container repositioning issues rather than inadequate fleet. The global ocean-borne container equipment fleet is expected to end the year having declined 1.1% to 39.9m TEU compared to a 3.3% projected fall in 2020 global container port handling.
TWO-THIRDS OF ESTONIAN CRYPTO BUSINESSES LOSE THEIR LICENSES
On 16 December, Coin Telegraph reported that one of the countries lauded as being among the most crypto friendly in the EU revoked the licenses of more than 1,000 crypto firms in 2020. It is said that there are 400 crypto-related service providers remaining.
IRELAND: FINANCIAL FIRMS DISREGARDING MONEY-LAUNDERING RULES ACCORDING TO THE CENTRAL BANK
On 17 December, the Irish Independent reported that financial firms are ignoring their legal responsibilities to prevent money laundering and the financing of terrorism and leaving oversight to unqualified staff, according to the Central Bank of Ireland. A supervisory review of compliance with AML/CFT regulations found that boards across a wide segment of the financial industry have been neglecting the rules. However, the CBI did not specify any concrete actions to deal with poor compliance levels across the sector or call out particular firms for bad practices.
PANAMA: NEW VEHICLE – ENTREPRENEURSHIP SOCIETIES (SOCIEDADES DE EMPRENDIMIENTO)
On 15 December, an article from Arias reported that, to promote and support the activity of entrepreneurs, Panama has enacted Law No. 186 of December 2, 2020 which creates a new legal entity. This new vehicle is intended for those who seek to undertake under less complex corporate structures. Similarly, tax rates are set more beneficial than public limited companies and no Resident Agent is required.
WHAT’S NEXT FOR SWISS HUMAN RIGHTS DUE DILIGENCE?
On 15 December, an article from Freshfields posed this question saying that the Swiss Responsible Business Initiative was recently rejected in a nationwide referendum, but that is not the end of the story with less onerous reporting obligations still expected to become law. An alternative counter-proposal that was adopted by the Swiss parliament in June 2020, which does not provide for any civil liability, will most likely enter into force unless another referendum against this counter-proposal is requested.
A PRACTICAL GUIDE TO SUBSTANCE IN GUERNSEY FOR TRUST AND CORPORATE SERVICE PROVIDERS (TCSP)
On 24 November, Carey Olsen published an article saying that Guernsey introduced economic substance requirements at the beginning of last year in order to address concerns by the EU Code of Conduct Group on Business Taxation. The article considers economic substance from the point of view of a TCSP professional who has come for advice on substance requirements when taking on a new structure. In doing so, it summarises some of the key elements of Guernsey’s economic substance legislation which impact different types of companies depending on their activities.
ITALY: CLAIM THAT 2 TUNISIANS USED BENEFIT TO FUND TERRORISM
On 2 December, ANSA reported that police in Bologna have filed charges against 2 Tunisian citizens accused of illegally benefitting from the ‘citizenship wage’ basic income to finance terrorism. The suspects are accused of using some 12,000 euros they had received as basic income to finance a dangerous Islamic ‘foreign fighter’ who is wanted by Belgian authorities.
GLOBAL PROTECTIONISM – A NEW ERA?
Gowling WLG has published a new paper saying that protectionist measures are continuing to populate the global trading environment. Businesses and markets must now navigate: the trade war between China and the US; increasing populism and nationalism; security concerns; the growth in importance of regionalisation; the limited access to capital; cross border data flows; the disruptive impact of technology; and, of course, the COVID-19 pandemic. It examines the rate at which trade protectionism measures are being implemented globally.
US TREASURY DESIGNATES VIETNAM AND SWITZERLAND AS CURRENCY MANIPULATORS
On 16 December, the Wall Street Journal reported that the US Treasury says the 2 countries had intervened in foreign exchange markets in a persistent, one-sided manner to limit appreciations of their currencies. The Treasury Secretary has said that the US Treasury will follow up on its findings with respect to Vietnam and Switzerland to work toward eliminating practices that create unfair advantages for foreign competitors.
EMERGING SUPPLIERS IN THE GLOBAL ARMS TRADE
A new report from the Stockholm International Peace Research Institute says that, even though the volumes of arms exported by emerging suppliers are lower than those of the established exporters, they can nonetheless have a direct impact on international and regional security. Brazil, South Korea, Turkey and UAE are examples of emerging suppliers. Despite a continuous reliance on foreign technologies, they have managed to establish themselves in several niche categories of armaments or, in the case of South Korea, to widen the types of arms that they export. Exports of these emerging suppliers tend to go primarily to Africa, Asia and the Middle East, where most active armed conflicts are located, and also to Latin America. However, the drivers of the 4 countries’ arms exports differ: some have supplied with the intent to gain political influence, while others have primarily focused on the economic benefits.
HOW SIGNIFICANT ARE THE US CAATSA SANCTIONS ON TURKEY AND ITS MILITARY INDUSTRY?
On 17 December, an article from Ahval reported that the CAATSA sanctions are in response to Ankara’s acquisition of sophisticated Russian S-400 air defence missile systems. The sanctions include a ban on all US export licences and authorisations to SSB and an asset freeze and visa restrictions on Dr Ismail Demir, SSB’s president, and other SSB officers, it is said that the sanctions “will make life more complicated, but the denial of export licences for US items could hinder future SSB contracts”. Separately, a Turkish defence official sanctioned by the US is quoted as saying that the move would leave most of the Turkish defence industry unaffected.
TURKISH COURT TO HOLD SECOND TRIAL OVER GHOSN SMUGGLING
Republic World reported on 17 December that a Turkish court is set to hold the second trial of 4 pilots on charges of smuggling former Nissan Motor Company Chairman Carlos Ghosn out of Japan to Lebanon, via Turkey. Ghosn was arrested over financial misconduct allegations in Tokyo in 2018, but skipped bail while awaiting trial late last year and was flown from Osaka to Istanbul and was then transferred onto another plane bound for Beirut.
CREDIT SUISSE FACES AML CHARGES LINKED TO BULGARIAN MAFIA
On 17 December, Financial News reported that the bank has been accused of failing to take all the measures that were reasonable to prevent the laundering of assets belonging to and under control of the criminal organisation. It has been drawn into a criminal investigation by the Office of the Attorney General into money laundering related to a Bulgarian mafia allegedly responsible for trafficking drugs.
SYRIA (UNITED NATIONS SANCTIONS) (CULTURAL PROPERTY) (OVERSEAS TERRITORIES) ORDER 2020
This Order extends with modifications the Syria (United Nations Sanctions) (Cultural Property) (EU Exit) Regulations 2020, as amended from time to time, to all British Overseas Territories except Bermuda and Gibraltar (which implement sanctions under their own legislative arrangements).
The following Orders made similar changes for a range of other sanctions regimes –
COUNTER-TERRORISM (INTERNATIONAL SANCTIONS) (OVERSEAS TERRITORIES) ORDER 2020
RUSSIA (SANCTIONS) (OVERSEAS TERRITORIES) ORDER 2020
COUNTER-TERRORISM (SANCTIONS) (OVERSEAS TERRITORIES) ORDER 2020
IRAN (SANCTIONS) (NUCLEAR) (OVERSEAS TERRITORIES) ORDER 2020
SYRIA (UNITED NATIONS SANCTIONS) (CULTURAL PROPERTY) (OVERSEAS TERRITORIES) ORDER 2020
BUSINESS EMAIL COMPROMISE (BEC) ATTACKS HAVE SURGED OVER THE PAST YEAR-AND-A-HALF
On 17 December, Infosecurity Magazine reported news that BEC attacks have surged over the past year-and-a-half, while scams designed to part users with their money remain a persistent phishing threat. It says a new report details spam, malware, BEC, data exfiltration, URL phishing, scamming, spear-phishing, domain impersonation, brand impersonation, extortion, conversation hijacking, lateral phishing and account takeover. It is said that COVID-19 attacks have not grown much since March, when research recorded a 667% spike. Between June and October this year they represented around 2% of all spear-phishing attacks, with scams (72%) comprising the vast majority, followed by regular phishing (18%), extortion (6%) and BEC (3%).
WHISKEY FRAUD RING UNCOVERED IN SPAIN
On 17 December, Drinks Business reported that Spanish authorities have uncovered what they believe is one of the largest criminal networks for the production and distribution of counterfeit whiskey, with 3 operation bases in Rioja, Jaén and Campo de Criptana in Ciudad Real. The Ciudad Real base was run by an Asian businessman who imported fake tax stamps, labels and caps from Asia from a well-known whiskey brand. The counterfeit whiskey was produced and bottled in Rioja, then send to Cuidad Real, where the labels and seals were added to ready the bottles for distribution.
UK: 33,000 SAR LINKED TO THE COVID-19 PANDEMIC
On 17 December, City AM reported that some 33,000 suspicious activity reports (SARs) linked to the Covid-19 pandemic have been filed this year, suggesting government schemes designed to help people and businesses through the pandemic are open to abuse. The 33,000 Covid-related SAR pales in comparison to SAR submitted more generally, with some 570,000 submitted between 2019 and 2020.
2025 UK BORDER STRATEGY
On 17 December, the Cabinet Office published a policy paper about the strategy that the UK Government says will support its ambition of having the world’s most effective border that creates prosperity and enhances security for a global UK. The purpose of the strategy is to set out:
- the approach to working in partnership with the border industry and users of the border to design, deliver and innovate around the border;
- a long-term Target Operating Model (TOM) for the border that describes the border it is intending to create; and
- the major transformations that government and industry will need to deliver by 2025 and beyond to implement the Target Operating Model.
The strategy sets out 6 transformations that government proposes to implement across the UK border and a series of cross-cutting, multi-year programmes that government will take forward in partnership with stakeholders. The planned programmes include the development of a Single Trade Window, to create a single gateway for all data from traders into government; implementation of an Electronic Travel Authorisation to speed passenger journeys through ports; and a major review of the agencies and checks that occur at the border, to rationalise these wherever possible.
BREXIT: EXPORTING OR IMPORTING OBJECTS OF CULTURAL INTEREST FROM 1 JANUARY
On 17 December, the Department of Digital, Culture, Media & Sport published updated information about the export or import objects of cultural interest from 1 January.
UK: LAW COMMISSION SEEKS VIEWS ON SMART CONTRACTS
On 17 December, the Law Commission in the UK advised that it had launched a call for evidence about “smart contracts”. It explains that a smart contract is a legally binding contract in which some or all of the contractual obligations are recorded in or performed automatically by a computer program deployed on a distributed ledger. The responses to the call for evidence will inform the Law Commission’s scoping study on smart contracts, which will provide an accessible account of the current law and set out how it will, or may, apply to smart contracts. The project is intended to inform public debate and seek a consensus about where reform may be needed to create an environment that encourages the use of this technology.
ADDRESSING THE VAT GAP IN THE EU
A research paper from the EU Parliament Research Service on 17 December said that the EU VAT gap stood at €140 billion in 2018 and it was predicted that it could fall below €130 billion in 2019. However, Covid-19-related containment measures have hurt Member States’ economies and eroded the VAT base. As a result, the VAT gap may reach over €164 billion in 2020.
AUSTRALIA: MAN CHARGED OVER ALLEGEDLY CORRUPT BETTING ON TABLE TENNIS
On 16 December, the BBC reported that a man has been arrested in Australia as part of an inquiry into a gambling syndicate placing allegedly corrupt bets on table tennis events in Europe. The police have not named the suspect, but Australian media have reported that it is former professional table tennis player Adam Green.
AUSTRALIA: LEGAL PROFESSIONALS AND ACCOUNTANT CHARGED WITH MONEY LAUNDERING OPERATION
On 16 December, ABC News reported that a lawyer, his associate and an accountant are facing money laundering charges after police raided businesses across Canberra and Queanbeyan. They are said to have been arrested “for their role in facilitating organised crime in Canberra”.
WASTE, NEGLIGENCE AND CRONYISM: INSIDE BRITAIN’S PANDEMIC SPENDING
On 17 December, the New York Times carried an article saying that, in the desperate scramble for protective gear and other equipment, politically-connected companies reaped billions. It reports that, of roughly 1,200 central government contracts that have been made public, together worth nearly $22 billion, about $11 billion went to companies either run by friends and associates of politicians in the Conservative Party, or with no prior experience or a history of controversy. Meanwhile, smaller businesses without political clout got nowhere.
SOMALIA’S OPPOSITION URGES TURKEY NOT TO SEND ARMS TO POLICE UNIT
On 16 December, Reuters reported that Somalia’s opposition says it has written to Turkey urging it not to send a planned shipment of weapons to a special police unit that they fear incumbent President Mohamed Abdullahi Mohamed could use to “hijack” forthcoming elections.
KUWAIT: HOME HELP EXPENSIVE AND EXPLOITIVE
On 17 December, the Newsletter from the Center for International and Strategic Studies reported that critics have described the domestic help market in Kuwait as a form of slave labour after residency restrictions forced many to leave the country. It says that some 60,000 unregistered workers are involved, with agencies taking at least half the fees charged to householders. It is also said that the country’s farmers have also complained of a lack of labour since the rules change. This follows moves to “Kuwaitize” the country in the wake of the Covid-19 pandemic, and to reduce the number of non-nationals from 70% to 30% – in July the parliament tried and failed to cap the number of Indian and Egyptians at 15%. There are said to be signs that the Government thinks that it may have moved too fast.
DESIGNATING THE HOUTHIS AS TERRORISTS WOULD BE A MISTAKE
On 25 November, a Commentary from Defense One explained that the Houthi movement, or Ansar Allah (God’s Partisans) as its members prefer to be called, is a homegrown Yemeni organisation that is partly sectarian, partly regional, and partly tribal. The group arose in the 1990s in northern Yemen to protest what it saw as twin evils: a corrupt Yemeni government and a corrupting Saudi government. It says that designating the Houthis as terrorists would scarcely hurt Iran, which hasn’t invested much in them anyway. It is unclear, in fact, how such a designation would affect the way Iran currently engages with the Houthis, which is largely clandestine. It is also not clear how it would hurt the Houthis, whose power is not threatened and who have mastered methods of extracting wealth from what is already the poorest country in the Middle East. The Commentary says that it would, however, affect 2 groups – the diplomats who are seeking to negotiate an end to Yemen’s conflict, and the millions of Yemenis who are hungry and food-insecure, and the humanitarians who seek to help them.
BERMUDA AND BAHAMAS INTRODUCE SIMPLIFIED ARRIVAL SYSTEM FOR ENTRY INTO US
On 12 December, Homeland Security Today reported that US Customs and Border Protection has announced the introduction of Simplified Arrival at the Lynden Pindling International Airport in Nassau, Bahamas, and at the LF Wade International Airport in Bermuda. The system is an enhanced international arrival process that uses facial biometrics to automate the manual document checks that are already required for admission into the US streamlines international arrivals while fulfilling a longstanding US Congressional mandate to biometrically record the entry and exit of non-US citizens.
CHINESE COMPANY SANCTIONED BY THE US BUILDS A GLOBAL SURVEILLANCE AND SECURITY NETWORK
An article from Kharon on 12 December reported on Chinese company, CEIEC. It says that the company’s foreign subsidiaries have contracts with government security or military agencies across Africa, the Middle East, Latin America and elsewhere. It also has a minority stake in a Norwegian company that produces consumer electronics sold at large European retailers, and was the general contractor for the tallest building in Sri Lanka’s capital city. The US designated the company in November for helping Venezulelan leader Nicolas Maduro undermine democracy by restricting internet service, conducting digital surveillance and carrying out cyber operations against his political opponents. The article says that CEIEC’s government security contracts extend beyond Venezuela – in recent years, the company has secured contracts to supply more than a half-dozen governments in Africa, Central Asia and Latin America with communications and surveillance systems CEIEC is also a significant Chinese military facilitator: It was an agent for more than 200 military-related tenders since 2019.
ANTI-TANK MISSILE IN LIBYA LOOKS LIKE IRAN-PRODUCED WEAPON
On 8 December, Iran Watch from the US-based Wisconsin Project on Nuclear Arms Control reported that the UN has identified an anti-tank guided missile being used by a militia in Libya “had characteristics consistent with the Iranian-produced Dehlavieh”.
SEC (SORT OF) WEIGHS IN ON HOW PERSONAL LIABILITY FOR CHIEF COMPLIANCE OFFICERS MAY UNDERCUT EFFECTIVE COMPLIANCE PROGRAMMES
On 17 December, the Compliance & Enforcement blog at the Program on Corporate Compliance and Enforcement at the New York University School of Law starts by saying that, although regulators often seek to empower compliance officers within their institutions, a troubling question lingers as to whether regulators are undercutting this important message by simultaneously sending mixed or unrefined signals about when a Chief Compliance Officer should be held personally liable for the compliance failings of his or her firm. The post reflect on recent comments on the topic, and the need for additional guidance on when to bring enforcement actions against compliance officers.
UK: COURT OF APPEAL OVERTURNS JERSEY COMPANIES’ TAX RESIDENCY RULING
On 17 December, STEP reported that HMRC has defeated Development Securities in the England and Wales Court of Appeal in a dispute over the tax residency of subsidiaries incorporated by the company in Jersey for tax reasons. The UK-based property development and investment group formed the Jersey special purpose vehicle companies in 2004, in the hope of using latent capital losses on the group’s assets to reduce the capital gains tax on some planned disposals. The scheme’s success relied on the Jersey companies not being UK tax-resident at the time the assets were acquired. To ensure this, the directors held their board meetings in Jersey, in order to meet the accepted central management and control (CMC) test for tax residence. However, HMRC challenged this, and now the Court has held that the companies were indeed tax-resident in the UK as their place of CMC.
POLICE IN INDIA ARREST 54 PEOPLE IN A RAID ON AN ILLEGAL CALL CENTRE THAT TARGETED FOREIGN NATIONALS WITH FRAUD SCAMS
On 17 December, Infosecurity reported that the Delhi cybercrime unit launched an investigation after receiving intelligence that a large-scale fraud operation was being run from a location in New Delhi. Police were informed that a team of scammers were calling up targets in the US and other countries and conning them into transferring money to criminals via Bitcoin wallets and the purchase of gift cards. It is reported that initial investigations suggest that the owner of the call centre is located in Dubai.
EU EARLY WARNING SYSTEM REPORT – PSYCHOACTIVE SUBSTANCES: GLOBAL MARKETS, GLOCAL THREATS AND THE COVID-19 PANDEMIC
On 17 December, a report from the European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) aims to provide insights into what is happening with new psychoactive substances in Europe, based on data from the agency’s early warning and risk-assessment activities. The report covers the period until October 2020 and focuses on global markets, local threats and the COVID-19 pandemic. The Early Warning System is a 3-step legal framework of early warning, risk assessment and control measures which allows the EU to rapidly detect, assess and respond to the public health and social threats caused by new psychoactive substances in Europe
UK: EX-RANGERS FC ADMINISTRATORS SETTLE WITH CROWN OFFICE
On 17 December, the BBC reported that 2 men wrongfully arrested during a fraud probe relating to the sale of Rangers football club have settled a legal claim against Scotland’s top law officer. David Whitehouse and Paul Clark were appointed administrators when the company which ran the club went into administration in 2012. The pair were arrested in 2014 but the Crown has since said the arrests were “malicious”.
Both men launched a £20.8 million claim for compensation over their arrests.
US: RUSSIAN PLEADS GUILTY TO MONEY LAUNDERING IN QQAAZZ INTERNATIONAL CYBERCRIME INVESTIGATION
On 17 December, the Pittsburgh Post-Gazette reported that Maksim Boiko, whose online alias is “gangass,” waived indictment by grand jury and pleaded guilty. He was among 20 eastern Europeans accused in Pittsburgh as part of an investigation of QQAAZZ, an organized crime group that provides money laundering services for cybercriminals around the globe. The indictment alleges that QQAAZZ laundered or tried to launder tens of millions of dollars since 2016.
ROMANIA ISSUES INTERNATIONAL ARREST WARRANT FOR PRINCE PAUL AFTER PROPERTY FRAUD CONVICTION
On 17 December, Universul reported that a Romanian prince, a businessman with political connections and 2 Israelis have been sentenced to prison in an illegal property restitution case. A court sentenced businessman Remus Truica to 7 years in prison; Prince Paul was given a 3-year and 4-month sentence; while Israeli businessmen Benjamin Steinmetz and Tal Silberstein each received 5-year sentences in the case. 8 others including a former mayor and local government official also received prison sentences. It is said that Prince Paul illegally claimed the restitution of 28.6 hectares of land in northern Bucharest, arguing that the land had belonged to his grandfather, King Carol II, before being nationalised by the Communist regime.
US: $8.4 MILLION SEIZED FROM FAKE FLORIDA MINISTRY IN PPP FRAUD CASE
On 17 December, Newsmax reported that a phony family-run “ministry” in Florida is out $8.4 million after the federal authorities found out the ministry was fake. The he Secret Service found the money in various bank accounts linked to ASLAN International Ministry, an Orlando-based non-profit that obtained a large loan from the federal Paycheck Protection Program.
THIRD QUARTER MARITIME PIRACY AND ARMED ROBBERY REPORTS
On 17 December, Hellenic Shipping News reported that the latest report of the International Maritime Bureau (IMB) for the third quarter of 2020 showed a total of 132 incidents of armed robbery and piracy. In comparison to Q3 2019, this represented an increase of 10% in the total number of incidents for the same period. 110 ships were boarded, 2 ships were hijacked, 12 ships experienced attempted attacks, 6 ships were fired upon, 85 seafarers were kidnapped and 31 were held hostage onboard their ships.
DON’T LET THE BEAUTY OF ART DISGUISE MONEY LAUNDERING
An article on Finextra on 17 December says that the art market is particularly vulnerable to exploitation by money launderers due to its secrecy, subjective prices, large transaction sizes, and cash friendliness. Referring to the EU 5th AML Directive, the article provides tips on how institutions can strengthen defences. It also points out that, in the US, the Bank Secrecy Act applies to dealers in precious metals, stones, and jewels, requiring them to file suspicious activity reports and comply with other AML obligations, but no such rules apply to dealers of art – at least at the moment.
UK: ECONOMIC CRIME PLAN ONLINE TRACKER UPDATE
On 17 December, RUSI reported that the Economic Crime Plan (2019-2022) was launched in July 2019 and sets out the UK Government’s response to a range of economic crimes impacting the UK, including money laundering, fraud, market abuse and bribery. It is the first plan of its kind in the UK to set out a public-private response to these problems. The Plan sets contains 52 actions under 7 priorities areas. RUSI has established its tracker to monitor progress (or not).
JERSEY: REMINDING REGULATED BUSINESSES TO MAKE SURE THEY HAVE ADEQUATE AND EFFECTIVE COMPLIANCE MONITORING IN PLACE
On 17 December, a report from the Jersey FSC said that it had conducted a thematic examination on compliance monitoring, which resulted in 41 findings where businesses were not meeting their statutory obligations and regulatory requirements. The FSC says that it assessed whether compliance monitoring plans and activities enabled businesses to demonstrate that compliance risk was being managed effectively. Only one of the 11 regulated businesses we reviewed could demonstrate compliance with the regulatory framework. This included banks, fund services businesses, investment businesses and trust company businesses.
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