Panama Covid-19 update – last day of tighter restrictions, before weekend lockdown, and then many/most shops reopen and gender-based restrictions end on Monday. Not a total opening up (and the media already warning of a “third wave” as a result of the loosening of controls before the vaccination programme can take effect.
Meanwhile (and ironically that Panama was on the verge of launching a tourism initiative linked to the 200th anniversary of independence from Spain when the pandemic hit), the hotel sector has reported a claimed $400 million debt mountain.
In the daily data, there are still 998 new cases and 33 new fatalities. There are reported to be 32,215 active cases, with 227 in ICU and 2,060 in other wards.
5 FEBRUARY 2021
AML INNOVATION AND WHISTLEBLOWER PROVISIONS OF THE NDAA MEAN IMPORTANT CHANGES AHEAD
On 21 January, ABA Risk & Compliance from the American Bankers Association published an article saying that, in September, FinCEN took a significant first step toward building a next-generation framework for AML regulation with the release of an advanced notice of proposed rulemaking focused on re-orienting the approach to AML to focus on effectiveness. Then in the National Defense Authorization Act, the Anti-Money Laundering Act 2020 (AMLA), reinforces and expands FinCEN’s efforts. The article says that it is the most significant overhaul to the AML regime in the US since the Patriot Act, and includes several improvements to AML rules long=advocated by the ABA. It says that there are 3 important themes in the legislation, which it goes on to consider. The article concludes that AMLA represents a meaningful opportunity to improve effectiveness in blocking financial crime and terrorist financing while simultaneously reducing the regulatory cost to the financial industry; and that this is possibly the first time in regulatory history that it has been possible to achieve both goals simultaneously.
- Unlocking innovation, for regulators and banks.
- Collaboration and better information.
- Reinforcing culture
US: ACCURATELY ASSESSING FINANCIAL CRIME RISK AT MIDSIZE BANKS IN 2021
On 28 January, ABA Risk & Compliance from the American Bankers Association published an article pointing out that, in the US, banks with less than $10 billion in assets represent 97% of the total number of banks and 14% of the market. It says that mid-sized banks are just as vulnerable to money laundering as larger banks, and a scandal could bring fines as well as long-term reputational damage. The article provides a few ways mid-sized banks can address common anti-money laundering challenges and create a more efficient and impactful system.
WHY UK COMPANIES SHOULD PAY ATTENTION TO CHINA’S NEW EXPORT CONTROL REGULATION
The Institute of Export and International Trade has published an article and a 1-hour You Tube presentation on 22 January about the Chinese government having unveiled a revised draft of its new Export Control Law. This reform did not make the news in the UK and has not even been a major talking point for companies trading strategic dual-use items with China. However, the article says, not paying attention to the law changes could prove costly and disruptive for such businesses. The article and video look at the implications of the law and what UK companies can do now. It points out that, as in the US, an export can take many forms, including cross-border product sales, service delivery, technology transfer, overseas exhibition, repair, and donation. EBO (Export Business Operators – all Chinese citizens, legal persons or other organisations exporting controlled items) fall under this law and are subject to administrative and criminal fines for export violations. The draft ECL also introduces a blacklist and a temporary control mechanism, which together appear to fulfil a similar function to various lists in the US export control regime, such as the Entity List or Denied Persons List.
MILLIONS OF COUNTERFEIT MASKS FLOODED US CUSTOMS FACILITIES LAST YEAR
On 4 February, the Wall Street Journal reported that US Customs agents seized nearly 13 million counterfeit face masks in the 12 months that ended 30 September 2020. Agents also confiscated 177,000 test kits prohibited by the FDA and 38,000 chloroquine and hydroxychloroquine tablets. There were also nearly 37,000 so-called antivirus lanyards touted to prevent Covid-19 infection and which contain substances prohibited by the Environmental Protection Agency.
CREDIT SUISSE WAS ALERTED TO PRIVATE BANKER’S MISCONDUCT YEARS BEFORE CRIMINAL CHARGES
On 4 February, the Wall Street Journal reported that the Credit Suisse Group AG overlooked red flags for years while a rogue private banker (Patrice Lescaudron – who was sentenced to 5 years in prison in 2018 for fraud and forgery) stole from billionaire clients, according to a report by a law firm for Switzerland’s financial regulator, Finma. It is said that Lescaudron’s activities triggered hundreds of alerts in the bank that were not fully investigated in the 2009-15 period studied. In addition, around a dozen executives or managers in Credit Suisse’s private bank knew that he was repeatedly breaking rules but turned a blind eye, proposed lenient punishment for his misconduct or otherwise glossed over the issues because he brought in around $25 million in revenue a year.
WHITE-COLLAR AND REGULATORY ENFORCEMENT: WHAT MATTERED IN 2020 AND WHAT TO EXPECT IN 2021
On 5 February, the Compliance & Enforcement blog at the Program on Corporate Compliance & Enforcement at the New York University School of Law published this post offering educated guesses on what to expect going forward.
JAPAN’S KIRIN TO END JOINT BEER VENTURES IN MYANMAR AFTER COUP
On 5 February, Nikkei Asia reported that Japan’s Kirin Holdings announced it will terminate its 2 joint ventures in Myanmar, becoming the first Japanese company to denounce the military coup; due to the military’s actions which were “against our standards and Human Rights Policy,” the brewer said.
US: HOUSE DEMOCRATS URGE YELLEN TO REINSTATE DAN GERTLER SANCTIONS
On 5 February, KYC 360 reported that several Democratic House lawmakers are urging the new US Treasury Secretary Janet Yellen to reverse the Trump administration’s decision in its final days to ease sanctions on Israeli billionaire Dan Gertler.
EU PARLIAMENT SNUBS ANTI-CORRUPTION RESEARCHERS
On 5 February, KYC 360 reported that the European Parliament refused to cooperate with an EU institutional-wide study on integrity and ethics by Transparency International, one of the world’s most prestigious anti-corruption NGO. The Parliament did the same in 2014, when the NGO launched a similar probe.
HOW BILLIONAIRE ROBERT SMITH AVOIDED INDICTMENT IN A MULTIMILLION-DOLLAR TAX CASE
On 5 February, KYC 360 reported that US prosecutors and IRS agents spent four years piercing the veil of secrecy that billionaire money manager Robert F. Smith wove to hide more than $200 million in income. However, a non-prosecution agreement only required him to admithe had committed crimes, pay $139 million and cooperate against a close business associate indicted in the largest tax evasion case in US history — Texas software mogul Robert T Brockman.
THE RISE AND FALL OF BITCOIN BILLIONAIRE ARTHUR HAYES
On 4 February, Vanity Fair reported that the BitMEX cofounder created a cryptocurrency exchange that has traded trillions. Now he is wanted by US authorities, and insiders wonder whether he and his partners are villains — or victims of a 2-tier justice system that favours big banks over brash outsiders. Prosecutors allege that Hayes and his business partners violated the Bank Secrecy Act by failing to implement and maintain an adequate AML programme.
UN GRANTS SANCTIONS WAIVER TO SOUTH KOREAN GROUP FOR IMPROVING DRINKING WATER IN NORTH KOREA
On 5 February, the Yonhap News Agency reported that the UN has granted a sanctions waiver for an organisation working on a project to provide safe drinking water to North Korea. The organisation was given an exemption for 9 months until 22 October. The UN website did not identify the name of the organisation, nor did it specify the size of the assistance and other details.
PODCAST: UNRAVELING THE ISRAELI BALLISTIC MISSILE PROGRAMME
On 4 February, a podcast from the Arms Control Wonk website says that Israel maintains a technologically advanced but understudied ballistic missile arsenal. The hosts look into the French, South African, and US influences on the arsenal, how to model the Jericho missile families, and the history of the Israeli ballistic missile programme.
OFFSHORE DUTY-FREE SHOPS — A LIKELY BONANZA IN CHINA OPEN TO FOREIGN INVESTORS
On 4 February, an article from Zhong Lun Law Firm says that duty free shops are a high-gross-margin business, also a drive of international tourism. In contrast with its flat growth rate worldwide, duty-free sales in China picks up a phenomenal gaining momentum in the recent years. It reports that, according to Generation Research, from the year 2002 to 2018, the compounded growth rate of global duty-free sector arrives at 8.7%, whereas the duty-free business in China soared at a stupefying speed.
A PRACTICAL GUIDE TO THE ROLE OF DIRECTORS IN FIGHTING RANSOMWARE
On 3 February, an article from Skadden Arps Slate Meagher & Flom LLP says that boards need to take an active role overseeing cybersecurity measures, directors may be held personally responsible for lapses that result in attacks, and US money laundering and sanctions rules may prohibit some ransom payments. It says that the biggest cyberthreat most companies face is not attacks backed by nation-states like the recent SolarWinds hacking episode. It is ransomware, a type of malware that encrypts its victims’ data and holds it hostage until a ransom is paid in untraceable bitcoin.
EU: THE NEW VAT SCHEME FOR E-COMMERCE
A report from CMS Legal says that the EU VAT e-commerce package, first approved in 2017 (Directive 2017/2455) and added to in 2019 (Directive 2019/1995), is finally due to enter into force on 1 July (after being postponed due to the coronavirus crisis). The package aims to adapt the VAT system, which was mostly designed for offline transactions, to the explosive growth of B2C online transactions1 in the context of our technology-driven world. The new rules are set to facilitate online sales within the EU Single Market, by easing compliance with e-commerce while promoting a level playing field between EU and non-EU businesses, thus increasing VAT revenue and targeting fraudulent businesses. One of the cornerstones of this package is the generalisation of taxation at the place of consumption by non-taxable persons, and the EU has approved the extension of the current mini one-stop-shop (MOSS). As a way of introduction to the new VAT rules, the report summarises the main features of the VAT e-commerce package that will apply from July 2021.
ARRESTED: THE PRIMARY SUSPECT IN LEBANON’S LARGEST DRUG SMUGGLING CASE
On 5 February, The 961 website reported that security forces had arrested an individual accused of being one of the primary perpetrators in the biggest outbound drug-smuggling operation recorded in Lebanon. The smuggling operation in question took place in March 2020 when security forces seized 25 tons of cannabis that were destined to African states, and found on its way to the Port of Beirut.
IRELAND: REVENUE SEIZES 31,600 SMUGGLED CIGARETTES FROM UK AT DUBLIN AIRPORT
On 5 February, the Irish Times reported that customs officers seized 31,600 cigarettes a man had been attempting to smuggle into the country through Dublin Airport in his checked baggage, after an Irish man was stopped after he got off a flight from London Heathrow.
PARTNERSHIPS AND PRESENCE ‘ABSOLUTELY CRITICAL’ TO PROTECT SHIPPING AND UNDERSEA CABLES FROM EVOLVING THREATS
On 5 February, Homeland Security Today reported that evolving threats in the maritime domain underscore the importance of security forces being eyes and ears to ensure the safety of merchant shipping and safe supply chain routes, and “partnerships are absolutely critical” to maintain free seas, naval leaders from the US and Sweden have said. While 90% of the world’s trade travels on the ocean, “closer to 100% of the world’s information flows on the seabed in conjunction with satellites and that is something that is a grey zone area
CORRUPTION: A WAKE-UP CALL IN REYJAVIK
An article from Transparency International on 4 February says that 15 years ago, most Icelanders believed that corruption was virtually non-existent in the country. Back then, Iceland’s Corruption Perception Index score was amongst the highest, comparable with the other Nordic countries. However, a lot has changed – with the Panama Papers and Fishrot scandals being indicative, and the Icelandic nation is gradually realising that it has a corruption problem. To start with, the 2008 financial crisis and its aftermath, with prison sentences for managers and owners of Icelandic banks, opened the eyes of many. The Fishrot Scandal involves an Icelandic fishing company paying bribes in Angola.
9 THINGS INVESTORS SHOULD KNOW ABOUT THE CANNABIS INDUSTRY IN 2021
On 5 February, the Visual Capitalist published a large infographic
UK: CONVEYANCERS NEED LIST OF APPROVED DIGITAL ID SUPPLIERS
On 5 February, the Law Society Gazette reported that HM Land Registry should give conveyancers a list of accredited suppliers that can help them meet new digital identity requirements rather than leave them to figure out a market they know little about, the Law Society has said in a response to a consultation paper.
PRIVILEGE CAN BE WAIVED ‘WITHOUT EXPRESS STATEMENT’, ENGLISH HIGH COURT FINDS
On 5 February, the Law Society Gazette reported that the High Court in London has ruled that communications between a Surrey-based law firm and its former client are not subject to legal professional privilege (LPP), finding that privilege can be waived ‘without there being an express statement to that effect’. It said that the court is able to infer in an appropriate case from the available evidence that the person or entity who is entitled to assert the privilege has waived that right from their behaviour or from other indirect evidence.
IAB IRELAND LAUNCHES THE GOLD STANDARD TO TACKLE AD FRAUD & BRAND SAFETY
On 5 February, Ad World reported that IAB Ireland, the trade organisation for digital advertising, has introduced the Gold Standard, a series of initiatives that are aimed at reducing ad fraud, increasing brand safety, improving the advertising experience for users while creating greater cross-industry transparency around consumer data. The Gold Standard was developed by IAB UK and it has been widely adopted by the UK digital ad industry. Companies that register for the Gold Standard will also be required to complete a period of training within 6 months of registering before they can be accredited.
UK: COUNTERFEIT HANDBAG TRADER LANDS “HUGE” FINE AFTER SUCCESSFUL PROSECUTION
On 5 February, a news release from Manchester City Council advised that Jamie Bags Ltd of Manchester had been fined £37,500, with costs of £3,843.88 to be paid. A forfeiture order was also made.
GERMAN POLICE SEIZE €50 MILLION OF BITCOIN, BUT FRAUDSTER WON’T GIVE THEM THE PASSWORD
On 5 February, City AM and others reported that German prosecutors have confiscated more than €50 million worth of bitcoin from a fraudster. There’s only one problem: they can’t unlock the money because he won’t give them the password. The man was sentenced to jail and has since served his term, maintaining his silence throughout while police made repeated failed efforts to crack the code to access more than 1,700 bitcoin, said a prosecutor in the Bavarian town of Kempten.
BREXIT – UK-EU TRADE AND COOPERATION AGREEMENT: TEMPORARY BUSINESS TRAVEL
On 5 February, the House of Commons published a Research Paper which sets out to explain what has changed for UK business and individuals who seek to sell their services in the EU and vice versa. It also mentions that, on 8 February, the House of Commons will hold an e-petition session on arrangements for UK Musicians in the EU, and this briefing summarises the main issues facing this sector. It points out that business travel that may be essential to supply a service abroad is facing major changes. The end of free movement between the UK and EU means new barriers to travel for service providers. UK citizens no longer have freedom to work, start a business or live in the EU. They are subject to EU Member State immigration rules and requirements regarding the right to work. They need visas for long-term stays in the EU. The same applies to EU citizens seeking to provide services in the UK. However, the UK and EU have agreed arrangements that facilitate short-term business travel and temporary placements of highly-skilled employees and independent professionals.
US: INVESTIGATIVE JOURNALISTS LOSE FREEDOM OF INFORMATION BID TO OBTAIN GTO INFO REPORTED TO FinCEN
On 5 February, an article from Ballard Spahr LLP says that the case highlights confidentiality of BSA reporting and continued focus on real estate as money laundering tool. The California case involved an an attempt by a group of investigative journalists to obtain information reported to FinCEN on the beneficial owners of high-end real estate.
US: HEAD OF MERCHANT BANK SENTENCED TO 24 MONTHS IN PRISON IN CONNECTION WITH SECURITIES FRAUD SCHEME
A news release from the US DoJ on 5 February advised that CRAIG ZABALA, the chairman, CEO, and president of Concorde Group Holdings Inc, was sentenced to 24 months in prison in New York for participating in a scheme to defraud investors in the company, a purported merchant banking firm. Among other things he fraudulently induced at least 17 investors to invest approximately $4.38 million based on false and misleading statements, by failing to use investors’ funds as promised, and by converting investors’ money to his own use.
SERBIAN MAN EXTRADITED TO US, CHARGED WITH $70 MILLION FRAUD IN NORTH TEXAS
A news release from the US DoJ on 5 February advised that a Serbian man has been extradited from Serbia to the US to face allegations that he and others duped investors out of more than $70 million. Serbian authorities arrested Antonije Stojilkovic, 32, pursuant to a US provisional arrest request on 24 July in Belgrade. Mr. Stojilkovic and more than a dozen other alleged fraudsters were indicted by a Dallas-based federal grand jury on charges of conspiracy to commit wire fraud and conspiracy to commit money laundering in July 2020. The defendants allegedly helped create and market more than 20 fraudulent investing platforms, including Options Rider, Bancde Options, Start Options, Dragon Mining, BTC Mining Factor, and Trinity Mining.
LUCKIN COFFEE FILES FOR BANKRUPTCY
On 5 February, the Motley Fool reported that the Chinese coffee company, delisted from US stock exchanges during the Summer and racked with corruption scandals involving its succession of CEO, has filed for Chapter 15 bankruptcy. The Associated Press reports the company will keep its physical locations open during the bankruptcy process as it seeks to restructure itself into a viable business.
US: INSPECTOR GENERAL REPORT FINDS $63 BILLION IN UNEMPLOYMENT IMPROPER PAYMENTS — AND THAT’S LIKELY AN UNDERSTATEMENT
A blog post from the American Enterprise Institute on 5 February said that the Inspector General of the US Department of Labor has issued an update about improper payments and fraud involving federal and state unemployment insurance benefits paid since the pandemic struck last March. It suggests “at least $63 billion” in improper payments have been made, which will likely “be higher” when more information is known.
The update can be found at –
INTERIM LIBYAN EXECUTIVE AUTHORITY: P3 + 2 STATEMENT
On 5 February, a news release from the UK Foreign Commonwealth and Development Office says that the governments of France, Germany, Italy, the UK and the US welcome the agreement on a unified interim Libyan executive authority charged with leading the country to national elections on December 24, 2021.
MYANMAR PORTS SAID TO BE OPERATING NORMALLY
On 5 February, Lloyds Loading List reported that, following the coup, ports remain open and customs clearances have resumed, though airports remain closed. Airports have been shut down and all domestic and international flights are cancelled for the foreseeable future. The US is expected to target Myanmar’s oil and gas sector for sanctions, although this is unlikely to hit burgeoning trade ties with China.
US: MUSEUM OF THE BIBLE RETURNS LOOTED ARTIFACTS TO EGYPT AND IRAQ
On 5 February, an article from OCCRP reported that the President of the US arts and crafts store, Hobby Lobby, and board chairman of the Washington DC-based Museum of the Bible, Steve Green, has returned thousands of potentially looted artifacts to Egypt and Iraq, the Museum has announced. Green said he came into possession of the artifacts over years of private collecting, and announced in March his intention to return them. The artifacts were found by the museum’s own researchers to have insufficient providence records, i.e. a documented trail of possession beginning with their excavation.
SERBIAN POLICE ARREST 17 SUSPECTED MEMBERS OF A MAFIA GROUP
On 5 February, OCCRP reported that police in Belgrade arrested 17 people suspected of being members of an organised group that committed serious crimes, including kidnappings and murders. OCCRP reported that the gang was allegedly led by Veljko Belivuk who has been also known as the leader of the so-called “Principi” – a fan club of the Belgrade football club Partizan, and as a member of one of Montenegro’s notorious criminal clans – Kavac. His right-hand man, Marko Miljković, has also been arrested.
US: PASSENGER ARRIVES WITH 3,200 VIAGRA PILLS FOR HIS FRIENDS
A news release from US Customs & Border Protection on 5 February said that, during a baggage exam on 4 February at O’Hare Airport, officers found the passenger was in possession of 3,200 Sildenafil Citrate tablets (100 mg). When he was asked why he was in possession of the pills he stated they were for his friends and they are considered over the counter medication in India. The 9 lb of pills were seized for unlawful importation of mediation. The pills have an estimated manufacturer’s suggested retail price (MSRP) of approximately $96,608.
INSIGHT CRIME PRESENTS GUATEMALA CROSS-BORDER CRIME AND CORRUPTION INVESTIGATION
On 4 February, Insight Crime reported a seminar on 2 February a seminar in which InSight Crime’s Co-director Steven Dudley and investigators Héctor Silva Ávalos and Alex Papadovassilakis presented the results of a long-term investigation on criminal dynamics within Guatemala’s border region. The discussion was moderated by Marielos Monzón, the general coordinator of Cycles of Updates for Journalists (Ciclos de Actualización para Periodistas or CAP). The event was the first in a 6-part series in which InSight Crime will present the results of this 2-year project, focused on 6 countries located within 2 tri-border regions: Central America’s Northern Triangle and the Southern Cone’s Triple Frontier. A video presentation is available in Spanish and English.
IRELAND: BUSINESS INTERRUPTION INSURANCE RULING FAVOURS HOSPITALITY BUSINESSES
On 5 February, an article from Out-Law says that businesses whose operations have been disrupted by the impact of Covid-19-related restrictions in Ireland will welcome a new ruling by the country’s High Court. The High Court ruled in favour of 4 pub owners in a much-anticipated test case concerning the extent to which business interruption insurance (BII) policyholders can claim compensation, under the terms of their BII policies, for closures of their businesses stemming from the pandemic.
ENSURING THE ACCURACY OF WITNESS EVIDENCE IN ARBITRATION
An article from Out-Law on 5 February focused on a new report from the International Chamber of Commerce which makes a number of recommendations aimed at reducing biases, distortion and misinformation. These measures, which are based on scientific research into human memory, are designed to avoid what the report calls the “contamination” of a witness’ memory. The report includes measures directed at counsel, tribunals and in-house counsel; and the article from Out-Law focuses on the measures targeting in-house counsel.
The report from the ICC is at –
ANNUAL UK FRAUD AND CORRUPTION ENFORCEMENT REVIEW 2020.
On 5 February, law firm Eversheds Sutherland published its annual review of the key developments relating to criminal investigations and enforcement actions tackling fraud, bribery and corruption offences in the UK over 2020.
BRITISH PORTS SET OUT FREEPORTS PRIORITIES AHEAD OF APPLICATION DEADLINE
On 5 February, trade body CILT said that the British Ports Association has set out 3 priorities for the establishment of freeports for UK governments ahead of the deadline for bids closing in England. The BPA is now calling on governments to ensure that:
1. The selection process must be fair and transparent;
2. They continue to work with industry to ensure a sound regulatory environment is established, for all ports to flourish; and
3. There is a level playing field across all UK nations.
IRAN ASKS SPAIN TO EXTRADITE FORMER DIPLOMAT’S PLAYBOY SON
On 5 February, the BBC reported that Iran has asked Spain to extradite the son of a retired senior Iranian diplomat who is famous for showing off his lavish lifestyle on social media. Sasha Sobhani, a 33-year-old musician, appeared in court in Madrid after Iran accused him of running illegal gambling websites and money-laundering.
SYDNEY MAN ACCUSED OF TRYING TO BROKER NORTH KOREA MISSILE SALES SPOKE OF CONNECTION TO KIM JONG-UN
On 5 February, the Guardian reported that an Australian court has been told that a Sydney man spoke of his connection to Kim Jong-un as he allegedly worked on behalf of North Korea to export missiles in breach of UN sanctions. South Korea-born civil engineer, Chan Han Choi, 62, allegedly made references to nuclear weapons, “the motherland” and military equipment during negotiations in the 4 months before his arrest in 2017. He has pleaded not guilty to 2 counts of providing services he believed or suspected would or could assist a WMD programme; and has also pleaded not guilty to 2 counts of engaging in conduct that contravened a sanction enforcement law and 3 of engaging in conduct that contravened a UN sanction enforcement law.
SOUTH AFRICA: CUSTOMS MAKE A MASSIVE RHINO HORN BUST
A news release from the South African revenue Service on 5 February advised that the Customs unit of the South African Revenue Service (SARS) made a bust of rhino horn with an estimated value of R53 172 000, in a shipment destined for Malaysia. 18 pieces of rhino horn were found concealed in traditional clothing. The goods weighed 63 kg.
CROWN RESORT-LINKED SUSPECTED MONEY LAUNDERER ARRESTED IN THAILAND
On 5 February, The Age reported that an alleged international drug boss suspected of laundering millions of dollars through gaming giant Crown Resorts has been arrested in Thailand, where he is fighting efforts to be extradited to Australia. Chung Chak “John” Lee was arrested in late December is part of ongoing efforts by Australian authorities to weaken a transnational organised crime syndicate known as The Company which Asia Pacific policing officials and the UN estimated was at times responsible for up to 70% of the methamphetamine entering this country. He operated out of Hong Kong and Bangkok, and allegedly directed a high-roller gambling tour business that had partnered with Crown to use the gaming company’s Melbourne casino to launder millions in drug funds out of Australia in 2012.
I would be grateful for any modest contribution for my time and ongoing costs of computer, relocation, and (still ongoing) removal costs, I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y