Day: December 23, 2020

On 23 December, OFAC advised that 1 individual and 4 entities have been added to the SDN List in connection with recent events in Belarus.  At the same time, 1 individual and 1 entity relating to Iraq – Sabah AL-KHAFAJI and BABIL INTERNATIONAL – have been removed from the sanctions lists.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201223

https://home.treasury.gov/news/press-releases/sm1222

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On 23 December, an article from Insight Crime says that, in a region where 50% of the population already makes its living in the informal market, it was perhaps of little surprise that black markets exploded in 2020 amidst a worldwide contagion.  Throughout Latin America, there was an explosion in black market resellers to provide virtually any product. The biggest earners remained contraband staples: cigarettes, alcohol and medicine among them. But other, less traditional products, also spiked, including everything from personal protective equipment to bacon.  With millions out of work, heavy restrictions on movement and many conventional criminal economies temporarily hobbled, stealing and reselling oil and its derivatives has also risen to the fore. The article says that it is, quite simply, both a convenient way for criminal groups to shore up their finances and for the public to keep moving.

https://www.insightcrime.org/news/analysis/gamechanger-black-markets-new-normal/

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On 23 December, following published of the follow-up report on Mauritania, FATF has released an updated consolidated schedule of all AML/CFT assessment ratings.

www.fatf-gafi.org/publications/mutualevaluations/documents/assessment-ratings.html

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On 23 December, FATF published the 2^nd follow-up report produced by FATF-style regional body MENAFATF following the 2018 evaluation of the country’s AML/CFT systems.  Its rating for 31 FATF Recommendations for technical compliance have been rerated.  As with other such updates, actual effectiveness of the systems has not been re-assessed.  Mauritania remains in the Enhanced Follow-Up process and will submit its 3^rd Enhanced Follow-Up report to MENAFATF in November 2021.

www.fatf-gafi.org/publications/mutualevaluations/documents/fur-mauritania-2020.html

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On 21 December, Ropes & Gray LLP published an alert saying that the European Commission has published its long-awaited global list of conflict-affected and high-risk areas, or CAHRA.  The relevant EU Regulation is concerned with sourcing from CAHRA anywhere in the world.  The article contrasts with the approach taken by the US Conflict Minerals Rule, which divides the world into the DRC region and everywhere else.  The EU Regulation does not designate specific countries or regions by name as CAHRA; instead, it contains a general principles-based definition of what it means to be a CAHRA.  The EU Commission engaged RAND Europe to prepare the CAHRA list, which includes 27 countries, more than what many industry participants expected. These countries and their listed sub-national areas are included in an Annex to the Alert. RAND Europe will review and update the CAHRA list quarterly.

https://www.ropesgray.com/en/newsroom/alerts/2020/12/Conflict-Minerals-Compliance-European-Commission-Publishes-Global-List-of-Conflict-Affected

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On 23 December, KYC 360 reported that the High Court in London has ordered that an £11 million London flat believed to be owned by Sukhbaatar Batbold, the prime minister of Mongolia between 2009 and 2012, cannot be sold or transferred during an international £185 million corruption and money laundering investigation. He has been accused of receiving hundreds of millions of dollars from kickbacks in illegal deals involving the nation’s 2 largest mines.

https://www.riskscreen.com/kyc360/news/mongolian-leader-barred-from-selling-11m-london-flat/

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