Panama Covid-19 update – ignoring the lead story on the nightly news (that Panama remains on the EU tax “blacklist”), I noted that Phase 2 of the vaccination programme (which hopefully includes me) starts on 3-4 March, and that people wearing spectacles (like me) are reportedly 3 times less likely to contract the virus (according to an Indian research paper) – good news for us glasses wearers.
Today, 566 new cases and 13 new fatalities, with now less than 10,000 active cases (9,892), with 195 in ICU and 1,144 in other wards.
22 February 2021
THE DEVELOPING REGULATORY APPROACH TO CLIMATE CHANGE AND THE IMPORTANCE FOR FINANCIAL SERVICES
On 19 February, an article from Gowling WLG explores why climate change is important for financial services and explains the key climate change related regulatory initiatives underway in the UK. The Green Finance Strategy in July 2019 recognised the crucial role of the financial services sector in delivering global climate and environmental objectives.
US REPORT ALLOWS NORD STREAM 2 RUSSIAN PIPELINE PROJECT TO PROCEED, FOR NOW
On 21 February, the Wall Street Journal reported that a State Department in a report to Congress did not name new companies as targets for sanctions related to an $11 billion pipeline designed to transmit Russian natural gas to Germany, allowing work on the pipeline to continue unabated for now. Although expected to name a list of companies involved in pipeline construction and are therefore subject to US sanctions. Instead, the State Department named 2 entities previously sanctioned by the Trump Administration — the main pipe-laying vessel and its owner — along with 18 companies, mostly insurers, that already have left or were leaving the project. The failure to name any new targets for sanctions allows the work to continue while also providing the Administration with time to discuss the project with Germany and to formulate its own policy on the pipeline.
PODCAST: EVERYTHING YOU ALWAYS WANTED TO KNOW ABOUT P&I, BUT WERE AFRAID TO ASK
On 19 February, Lloyds List published this 22-minute podcast saying that the entire world fleet now works to an annual cycle of shipping protection and indemnity insurance from one 20 February to the next. It is said that clubs have gone into this renewal round seeking sharp increases in prices, which they regard as entirely justified. Equally unsurprisingly, shipowners don’t like paying more, and their insurance brokers have gone into bat to keep those rate hikes down. Did you know the 20 February P+! renewal date exists because that was the first day on which sailing ships could call at formerly ice-bound Baltic ports in Victorian times?
HOW THE US BUSTED A $50 MILLION ‘SAKAWA’ EMPIRE RUN BY 6 GHANAIANS
On 19 February, Ghana Web carried an article saying that authorities in the US have announced the arrest of 6 Ghanaians suspected to be involved in a cyber-fraud operation that saw them rip off victims to the tune of $50 million. The operation that led to their arrest spanned between 2013 and 2020 during which period the group committed a series of business email compromises (BEC) and romance scams against individuals and businesses located across the US. The frauds perpetrated consisted of, among other frauds, business email compromises, romance scams, and fraud schemes related to the novel coronavirus/COVID-19 pandemic.
UK INCREASES MONEY LAUNDERING RISK-RATING OF SOME REAL ESTATE BUSINESSES
On 15 February, Brodies LLP published an article saying that on 17 December, HM Treasury and the Home Office published an AML/CFT National Risk Assessment which increased the risk rating of some real estate businesses to high risk. It explains that real estate businesses are categorised as one of either property, estate agency or letting and the article goes on to examine the risks for each category in turn. It then offered practical tips to avoid a breach of the AML regulations.
KIDS COMPANY DIRECTOR DISQUALIFICATION PROCEEDINGS – SOME INITIAL THOUGHTS
On 17 February, Shoosmiths LLP reminded one that Kids Company was a well-known charity which provided support to vulnerable children and young people. After nearly 20 years of operation it closed in August 2015 following the launch of a police investigation into allegations of sexual abuse at the charity, which subsequently proved unfounded. A subsequent Parliamentary report said that primary responsibility for Kids Company’s collapse rested with the charity’s trustees. There followed proceedings brought by the Official Receiver seeking to disqualify the trustees and the CEO from acting as company directors, and the article considers the outcome of these, and the judgment released on 12 February. This inter alia concluded that in all the circumstances the trustees did not act unreasonably in taking account of an expectation of support from the government. While a postponed Charity Commission investigation will now be continued, the article says that, at a time of great strain for many charity trustees doing their best in very difficult circumstances to discharge their duties this judgment will provide some welcome reassurance.
SUPREME COURT CONFIRMS UK JURISDICTIONAL GATEWAY FOR PARENT COMPANY LIABILITY
A set of 3 article from different law firms are concerned with the judgment in the high-profile case of Okpabi v Shell in which the Court allowed a jurisdictional appeal relating to group claims brought by claimants against a UK domiciled parent company of a multinational group and its Nigerian subsidiary. The Supreme Court concluded that the claimants had an arguable case in the English courts on whether the parent owed a duty of care to communities affected by oil spills caused by the subsidiary in the Niger Delta. This decision comes shortly after a Dutch appeals court also found the subsidiary liable for the damage caused by the same oil spills in Nigeria. Although the Dutch court did not hold the parent directly responsible for the damage caused, it was held to have a limited duty of care to act on prevention and was ordered to install leak detection systems in the oil pipelines to prevent similar oil spills happening in the future.
GERMANY: ONLINE FORMATION OF A GmbH WILL SOON BE POSSIBLE
On 16 February, SKW Schwarz Rechtsanwälte reported that the German Federal Cabinet had approved the draft of the Act Implementing the EU Digitalisation Directive (DiRUG). The use of digital tools and procedures is intended to facilitate the establishment of companies and branches within the EU. The DiRUG is therefore intended to enable the formation of a GmbH in an online procedure in the future, and the founders will no longer have to appear in person at a notary’s office.
BVI CABINET IS MOVING TO PASS NEW LAWS TO TACKLE TAX EVASION AND MONEY LAUNDERING
On 22 February, BVI News reported that the EU, the UK and other international financial lobbies have been pressuring the BVI to improve its financial laws and make its systems more transparent to prevent the world’s richest from hiding money there. Now the Cabinet has said the Criminal Justice (International Cooperation) (Amendment) Bill 2021 will be introduced for its first reading in the House of Assembly at the next convenient sitting. It also considered and approved the Proliferation Financing (Prohibition) Bill 2021 and the Criminal Code (Amendment) Bill 2021, which will criminalise tax crimes as a predicate offence for money laundering. The Cabinet also reviewed the Counter-Terrorism Bill 2021.
UKRAINE EXHIBITS MILITARY AND DUAL-USE ITEMS AT INTERNATIONAL DEFENCE EXHIBITION & CONFERENCE (IDEX 2021) IN ABU DHABI
On 22 February, Interfax Ukraine reported that state concern Ukroboronprom presents new military equipment and armaments of its own production at the International Defence Exhibition & Conference (IDEX 2021) in Abu Dhabi. It is said that the exhibition will showcase a number of promising developments and products of the concern, such as a model of the Neptune ground anti-ship missile system and Vilkha high-precision jet system. IDEX-2021 will also present the capabilities of the Oplot tank, which is said to be the best in the world in a number of characteristics, the BTR-4 combat vehicle and other advanced developments of the concern member companies.
HUNGARY TO RETURN OVER 400 SMUGGLED ARTIFACTS TO TURKEY
On 22 February, Hurriyet in Turkey reported that, following 6 years of meticulous research conducted by experts at the Turkish Culture and Tourism Ministry, Hungary will return over 400 smuggled historical artifacts to Turkey. It is said that a Turkish man was detained with some 412 smuggled artifacts at the Hungarian border in 2015. The artifacts included a marble statue head, a marble figurine, medals, and coins, as well as other historical objects belonging to the Roman period.
AUSTRALIA: CIGARETTES SMUGGLED FROM CHINA AND HIDDEN INSIDE SOFA
On 22 February, The Australian reported that a man who imported almost 100,000 cigarettes hidden inside a sofa shipment from China has been sentenced to 4 months in jail. The cigarettes were concealed inside a shipping container that arrived in Fremantle from China in January 2018. Australian Border Force officers intercepted it and found 149 cardboard boxes containing modular sofas. Suspicions were raised when 10 of the boxes at the rear of the container were marked differently and scented air fresheners were scattered through the container.
TURKEY: RESTRICTIONS ON BEARER SHARES TO COUNTER FINANCING OF TERRORISM
On 22 February, an article from Kayum & Demir says that Turkish Grand National Assembly has promulgated an Act which foresees material amendments to the Commercial Code’s provisions regarding bearer share certificates.
MALTA: CHAMBER OF ADVOCATES SLAMS GOVERNMENT’S BILL TO REGULATE PROFESSION AS ‘UNFIT FOR PURPOSE’
On 22 February, the Malta Independent reported that since 2008 the Chamber had been vigorously pursuing the enactment of a new law to regulate the profession. However, it is said that the real problem is that the Bill as presented is substantively a far cry from the expectations of the Chamber for a proper regulatory structure for the profession in 2021 and, unless amended significantly, remains, at best unfit for purpose. The Chamber argues that, not only does it fail to address the real issues within the profession, it is just as inadequate to meet the requirements of Moneyval, as it is simply a window-dressing exercise without any real regulatory effect on the legal profession.
HONG KONG: AML/CFT REGTECH CASE STUDIES AND INSIGHTS
On 22 February, an article from Deacons says that the Hong Kong Monetary Authority has published a report – “AML/CFT Regtech: Case Studies and Insights” – highlighting the opportunities that regtech offers to transform the effectiveness and efficiency of AML/CFT efforts, and sharing end-to-end approaches which worked in real-life examples. The report is said to provide insights under 5 themes: getting started; data and process readiness; third-party vendor relationships; people, talent and culture; and performance metrics and indicators. These thematic insights are intended to help institutions identify an adoption process that is applicable to their particular circumstances.
PHILIPPINES: POGO GAMBLING OPERATORS HAVE A MONTH TO REGISTER FOR AML SYSTEM
On 22 February, Gambling Insider reported that Philippine Offshore Gaming Operators (POGO) have less than a month to register for the electronic reporting system managed by the Anti-Money Laundering Council (AMLC), with the deadline being 16 March. This follows an amendment to the Anti-Money Laundering Act of 2001 was passed, including real estate developers and brokers, and offshore gaming operators as people covered by the Act.
VICTORIA THE THIRD AUSTRALIAN STATE TO HOLD INQUIRY INTO CROWN RESORTS OVER MONEY LAUNDERING ALLEGATIONS
On 22 February, the Straits Times reported that Victoria state has said that it would hold a royal commission inquiry into casino operator Crown Resorts and its fitness to hold a gambling licence.
BUSINESS AS USUAL – US ARMS SALES TO EGYPT
An Issue Brief from the Security Assistance Monitor at the Center for International Policy says that the enduring security US partnership with Abdel Fattah al-Sisi’s increasingly repressive government has raised serious ethical and practical concerns, in terms of human rights and broader US interests.
ARMS SALES TO EGYPT BY TYPE SINCE 2008
FOREIGN COMMERCIAL BANKS: THE ESSENTIAL PARTNER IN FUTURE DISCUSSIONS OF THE IRAN NUCLEAR DEAL
On 19 February, the Bulletin of the Atomic Scientists published an article arguing that, in respect of the JCPOA and a possible new or revived deal with Iran, before any serious discussions get underway international commercial banking interests (not just government finance ministers) must be given an opportunity to provide substantive input — because, as a practical matter, these private enterprises will have the final say as to how much sanctions relief Iran effectively receives. It says that, under sanctions, foreign commercial banks can do all the business they want to with Iranian entities, or with US entities, but not both. In 2015, post-JCPOA, most international banks still concluded that it was still too risky to do business with Iran. Also, in 2015, foreign banks had legitimate concerns as to what would happen if the JCPOA broke down, or parties walked away, before any new long-term investments paid off.
THE IMPACT OF BREXIT ON TRADEMARK PROTECTION IN THE UK AND EU
On 22 February, Bird & Bird published an article saying that, now that Brexit has become effective, what does this mean for trademark protection in the UK (and EU)? The article provides a brief summary of the main issues.
IS IT TIME FOR A COMMON LAW REWRITE OF GDPR?
An article in the Law Society Gazette on 22 February asked this question, saying that some are suggesting that, by continuing to pick Europe from the big 3 global data protection regimes (the others being North America and China), the UK is making the wrong choice. And they argue that, in the information economy, there is a choice. Unlike, say, shellfish, data does not decay with distance so there is no reason to ally regulations with those of geographical neighbours. Surely it makes sense to adopt regulations most attuned to our national vision of the future?
OECD HAS RELEASED THE FINAL BATCH PEER REVIEWS, ON THE EFFORTS OF 13 JURISDICTIONS TO IMPROVE HOW THEY RESOLVE TAX-RELATED CROSS-BORDER DISPUTES
On 22 February, Tax News reported that the peer reviews are for Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, UAE and Vietnam. They evaluate how the jurisdictions have implemented a minimum standard which seeks to improve the mechanisms available to multinational taxpayers to resolve double tax disputes.
“MADE IN USA” LABELLING STANDARD LEGISLATION REINTRODUCED INTO CONGRESS
On 22 February, Sandler Travis Rosenberg reported that similar legislation was also approved by the Senate Committee on Commerce, Science, and Transportation in 2020. The Reinforcing American-Made Products Act would address this problem by giving the federal government exclusive authority to regulate the extent to which a product is introduced, delivered for introduction, sold, advertised, or offered for sale in interstate or foreign commerce with a “Made in the USA” or “Made in America” label.
CHINA: GUANGZHOU CUSTOMS SEIZES 13.5 KG IMPORTED BATTERY WASTE
On 22 February, the Global Times reported that Customs officers in Guangzhou Baiyun International Airport seized lithium battery waste when checking imported goods. They were assessed as wasted batteries and were confirmed as such after professional authentication. They are one category of imported solid waste which is banned to be imported to China.
MINOR PLAYERS TAKE CENTRE STAGE IN GUATEMALA DRUG TRADE
An article from Insight Crime on 22 February reported that an anti-narcotics operation targeting an alleged trafficking ring in Guatemala has shed light on the increasing importance of small, often discrete transport networks in the country’s cocaine trade. Guatemalan authorities arrested 25 people, including 6 police officers. Small-scale operations are part of a wider pattern that in recent years has seen the decline of dominant groups make way for smaller networks that control minor stretches of the land routes crisscrossing Guatemala.
UK WILL NOT INTRODUCE NEW LEGISLATION TO ENABLE NON-PROFIT GROUPS TO RAISE DATA PROTECTION CLAIMS ON BEHALF OF INDIVIDUALS WITHOUT THEIR PERMISSION
An article from Out-Law on 22 February said that, after reviewing the feedback to a consultation process last year, it concluded that the case for introducing an opt-out procedure into law was not strong enough. It says that there is insufficient evidence of systemic failings in the current regime to warrant new opt-out proceedings. Currently, NPO have the right under UK data protection law to take a range of actions on behalf of individuals where those individuals have given their permission to be represented.
UKRAINIAN AND POLISH FOREIGN MINISTERS CALL ON US TO HELP STOP NORD STREAM 2
On 22 February, Rferl reported that the Ukrainian Foreign Minister and Polish Foreign Minister have appealed to President Biden to prevent the completion of the Nord Stream 2 gas pipeline from Russia to Germany, which they called a “dangerous, divisive project”. The pipeline would affect Ukraine by depriving it of transit fees from existing pipelines that transverse its territory.
US JUDGE SUSPENDS UKRAINIAN OLIGARCHS’ FORFEITURE TRIAL AMID CONCERN OF IMPACT ON CRIMINAL PROBE
On 22 February, Rferl reported that a judge in Florida has suspended the US Government’s asset forfeiture trial against 2 Ukrainian tycoons – Ihor Kolomoyskiy and Hennadiy Boholyubov – and their American associates – Mordechai Korf and Uriel Laber, who run a real estate business from Miami – amid concerns its continuation could harm an ongoing criminal investigation into their activities.
NEW HACK ALLOWS ATTACKERS BYPASS MASTERCARD PIN BY USING THEM AS A VISA CARD
On 19 February, the Hacker News reported that cybersecurity researchers have disclosed a novel attack that could allow criminals to trick a point of sale terminal into transacting with a victim’s Mastercard contactless card while believing it to be a Visa card – permitting bad actors to leverage a victim’s stolen or lost Visa EMV-enabled credit card for making high-value purchases without knowledge of the card’s PIN, and even fool the terminal into accepting unauthentic offline card transactions.
ASIAN DRUG LORDS LIKELY PRODUCING PRECURSOR CHEMICALS IN GOLDEN TRIANGLE – NORTHEAST MYANMAR AND PARTS OF THAILAND AND LAOS
On 12 February, Reuters reported that crime syndicates in Asia’s drug-producing Golden Triangle region have likely begun producing ingredients to manufacture methamphetamine, enabling them to avoid restrictions on importing precursors such as pseudoephedrine and ephedrine. This is said to demonstrate a new level of sophistication by drug syndicates as “pre-precursors” such as propionyl chloride are far less tightly regulated and easier to obtain.
UK FINTECHS SEEK ‘CURE FOR BREXIT’ IN LITHUANIA
On 21 February, France 24 reported that Lithuania is becoming a fintech hub as a growing number of UK-linked digital financial companies are getting licences there so they can continue to operate in the EU.
GREECE: NEW TILLS TO BEAT TAX EVASION
On 19 February, Ekathimerini reported on the online connection of more than 600,000 tills and card terminals with the tax and inspection authorities. The rollout of the plan will start in the second half of the year, provided the economy has overcome the health crisis. Also to be employed is artificial intelligence, to be used for uncovering tax evasion cases, financed by the recovery fund.
THIRD IRANIAN GASOLINE TANKER ARRIVES IN VENEZUELA
On 22 February, Hellenic Shipping News reported that a shipment of around 44 million litres of gasoline has secretly arrived at El Palito, Venezuela from Iran aboard the tanker Forest.
LAW SOCIETY SCOTLAND: AML LPP LEGAL PROFESSIONAL PRIVILEGE SOLICITOR GUIDANCE
On 22 February, the Law Society Scotland published a blog post in which one of the lawyers involved in the update of the Society’s AML guidance sets out why and how she re-worked the Legal Professional Privilege (LPP) section to be a practical, decision-making framework for lawyers. She says that the new legal sector AML guidance on LPP builds on the original material, but tries to focus on the “real-life” decision-making process and any potential defence on the part of the lawyer, should their decision be questioned at some future date.
There are obviously also links to the new guidance for Scottish advocates.
US DEBT: CHAPTER 11 CASES SOARED IN 2020, WITH MORE DISTRESS LIKELY IN 2021
On 19 February, White & Case published an article saying that, in 2020, commercial chapter 11 bankruptcy filings climbed to their highest levels in recent years, as COVID-19 disruption sparked sharp declines in GDP and volatile stock market swings. Notably, it says, the pandemic accelerated the restructurings of some companies that were already on the precipice of financial distress, particularly in the retail, energy, travel and hospitality sectors. However, after a significant spike in the number of commercial chapter 11 filings in the second and third quarters of 2020, the pace of new chapter 11 filings slowed significantly toward the end of the year.
SEC AND NEW YORK AG HAVE CHARGED A DIGITAL ASSET TRADING COMPANY AND ITS CEO WITH OPERATING AN UNREGISTERED, UNEXEMPT INVESTMENT OFFERING
On 19 February, Cadwalader Cabinet reported that Coinseed Inc and its CEO, Delgerdalai Davaasambuu, faced charges that it and he had purported to offer a mobile investment application that enabled users to invest in digital assets. The SEC has alleged that the company sold digital tokens to investors with the promise that the investors would receive a portion of the revenues generated from the fees associated with digital assets transactions on the platform.
EU: UPDATE ON PROPOSAL FOR FINANCIAL TRANSACTION TAX
On 22 February, KPMG reported that the Portuguese presidency of the EU Council has proposed an inclusive discussion among all EU Member States regarding tax design issues of a financial transaction tax at the EU level.
OFAC ADVISES RUSSIA-RELATED SANCTIONS AMENDMENTS
On 22 February, OFAC announced that the entries relating to the vessel Fortuna and the associated company KVT-RUS had been amended.
IRELAND: FORMER SOLICITORS WHO CREATED FALSE IDENTITIES IN €400,000 FRAUD ARE JAILED
On 22 February, the Irish Times reported that 2 former solicitors have been jailed after they admitted a series of fraud offences where they created false identities, donned disguises and paid homeless people for their PPS numbers (an identifier issued by the Client Identity Services section of the Department of Social Protection) to steal almost €400,000 from banks and credit unions. They created 80 fake accounts using 60 false identities to obtain personal bank loans dishonestly.
US: HONDURAN FRAUDSTER SENTENCED TO 5 YEARS IN PRISON FOR $2 MILLION PONZI SCHEME
A news release from the US DoJ on 22 February advised that an Honduran man, Jose Anibal Linares, 42, who conned investors out of roughly $2 million has been sentenced to 5 years in federal prison. He was also ordered to pay more than $2.3 million in restitution and, as a Honduran citizen in the US formerly on Temporary Protected Status, he may be subject to removal from the US after serving his sentence. He operated JC Loans Finance and Inversiones JC Dallas, and admitted he falsely told investors their funds were “insured by the FDIC” and promised monthly returns based on investments in commercial and residential real estate, including a water resort and shopping centres in Honduras. He then mailed investors letters thanking them for joining the JC “family”.
US: COLLEGE STUDENT CONVICTED FOR ROLE IN INTERNATIONAL FRAUD CONSPIRACY
A news release from the US DoJ on 22 February advised that Oyindamola Akinrinola, 23, of Lawrence, Kansas, has pleaded guilty in federal court for her role in Nigerian fraud schemes that targeted victims across the US. Akinrinola, a Nigerian national who was granted legal permanent residency in the US in 2018, was part of a scheme to defraud US-based victims out of money and property. Akinrinola’s co-conspirator in Nigeria orchestrated several scams, such as tricking victims into believing they were eligible for fictitious awards or establishing purported (but false) romantic relationships with victims and exploiting their affections.
ISRAEL: COURT SETS NETANYAHU CORRUPTION TRIAL DATE FOR 5 APRIL AFTER GENERAL ELECTION
On 22 February, Raw Story and others reported that Netanyahu, the first Israeli premier to be indicted in office, was formally charged last year over allegations of accepting improper gifts and seeking to trade regulatory favour with media moguls in exchange for positive coverage. The next general election is on 23 March.
UKRAINE ARRESTS EX-PRIVATBANK OFFICIAL AS US PRIORITISES CRIMINAL PROBE OF FORMER OWNERS
On 22 February, Rferl reported that Ukraine’s Anti-Corruption Bureau has arrested Volodymyr Yatsenko, the former deputy chairman of a Ukrainian bank at the heart of an FBI criminal investigation as he attempted to fly abroad. Investigators forced the pilot of the private jet he was traveling on to land. Yatsenko, who was on his way to Vienna after reportedly being tipped off about his arrest, was charged with the embezzlement of funds at PrivatBank, once the nation’s largest lender. The FBI is investigating the 2 owners of PrivatBank — Ihor Kolomoyskiy and Hennadiy Boholyubov.
UK SANCTIONS POLICY: A PROGRESS REPORT
On 22 February, Regulation Asia published an article by a research fellow at RUSI says that, with Brexit and the transition period over, the UK has formally embarked on its independent sanctions regime. What work has been completed so far and what remains to be done? It points out that a 2019 House of Commons Foreign Affairs Committee report labelled the Government’s preparations for a post-Brexit sanctions strategy fragmented and incoherent’, with MPs calling on the government to ‘seize the opportunity to become a global leader in sanctions policy’. Since that report was released, both a British general election and the formal separation from the EU have occurred, so has the government arrived at a more coherent sanctions strategy? The article concludes that in the 2 years since the Committee report, the UK Government has established an independent sanctions regime that is uniquely different to others both in terms of the actual designations, its priorities and its implementation. However, turning initial steps into sustained leadership on sanctions will take work, and the UK’s post-Brexit sanctions journey has therefore only just started.
THE UK’S RESPONSE TO CYBER FRAUD: A STRATEGIC VISION
On 22 February, an Occasional Paper from RUSI sets out to provide targeted, long-term recommendations for stakeholders across government, law enforcement and the private sector to tackle cyber fraud. It calls on the Home Office to lay out the UK Government’s vision for tackling cyber fraud in a dedicated strategy underpinned with investment. This strategy should be designed and implemented with the support of UK business. The authors outline a series of recommendations which should form the basis of this approach moving forward.
GIBRALTAR FIU: FIGHTING ECONOMIC CRIME THROUGH INTELLIGENCE
The Gibraltar FIU has published a strategy paper saying that, in order to communicate effectively to key external and internal audiences, it needs to adopt a flexible and creative approach to raise awareness, provide accurate and factual information, and improve engagement. Key external and internal audiences include the general public, industry professionals, law enforcement agencies and supervisory bodies. Its plan describes how the FIU will improve and increase engagement with the private and public sector using a range of communication channels; and this will allow opportunities to engage through conversation and provide feedback to the FIU. It lays out the 6 objectives of the strategy
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