Day: March 10, 2021

On 9 March, a news release from the US State Department advised the designation of Islamic Revolutionary Guard Corps (IRGC) interrogators Ali Hemmatian and Masoud Safdari for gross violation of human rights.  This is for involvement in gross violations of human rights, namely the torture and/or cruel, inhuman, or degrading treatment or punishment (CIDTP) of political prisoners and persons detained during protests in 2019 and 2020 in Iran.  The 2 individuals and their immediate family members are ineligible for entry into the US. 

https://www.state.gov/designation-of-iranian-officials-due-to-involvement-in-gross-violations-of-human-rights/

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On 10 March, OFAC announced that 3 individuals (1 Tanzanian and 2 Burmese) and 7 entities (6 Burmese plus Islamic State in Mozambique) had been added to its SDN List.  Entries for 1 individual and 1 entity were also amended.  The Burma/Myanmar changes target family members profiting from connection to the Burmese coup leader.  OFAC has sanctioned the 2 adult children of the commander-in-chief of the Burmese military forces, Min Aung Hlaing, who is the leading actor in the overthrow of Burma’s democratically elected government, as well as 6 companies of his 2 adult children.  The US Commerce Department also announced new export controls on Burma and makes entity list additions in response to the military coup and escalating violence against peaceful protesters.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210310

https://home.treasury.gov/news/press-releases/jy0051

https://www.commerce.gov/news/press-releases/2021/03/commerce-implements-new-export-controls-burma-and-makes-entity-list

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On 9 March, the Basel Institute on Governance reported that a new Working Paper presents the findings of a novel application of social network analysis (SNA) to study a criminal network surrounding an East Africa-based wildlife trafficker.  It is said to shed new light on the dark networks of wildlife traffickers that operate mainly between East Africa and SE Asia but have tentacles reaching around the world.  The Working Paper explores several of these features of the criminal network in the case study, including the size and shape of the network and the concentration of power around the main trafficker and his close relatives and co-offenders.  The analysis can support the efforts of investigators and prosecutors to discover new leads and suspects, or to better understand the meaning of financial and information flows.  It is also said that the results also demonstrate that by combining SNA (a primarily quantitative method) with network ethnography (a qualitative method), one can gain important new insights into the structures, functions and mechanisms of criminal networks engaged in illegal wildlife trade and other forms of trafficking. 

https://baselgovernance.org/publications/SNA_IWT

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An Alert from FinCEN on 9 March is intended to advise those involved in the art and antiquities sector about the Anti-Money Laundering Act of 2020 efforts related to trade in antiquities, sources of information about existing illicit activity related to antiquities and art, and specific instructions for filing SAR related to trade in antiquities and art.

https://www.fincen.gov/sites/default/files/2021-03/FinCEN%20Notice%20on%20Antiquities%20and%20Art_508C.pdf

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On 10 March, Hellenic Shipping News reported that Risk Intelligence has published a set of guidelines concerning the use of privately contracted government security forces in Nigeria. The publication was released following the recent developments on the disbanding of the Secure Anchorage Area (SAA) and to provide clarity in the use of armed security (armed escort vessels) in Nigerian waters.  The use of armed guards on merchant ships has been expressly prohibited by the Nigerian Navy’s Chief of Naval Staff since 2016.  This has resulted in the Nigerian Navy entering contractual relationships with private security companies which have been governed by a MoU since 2012 (revised 2016).  These Private Maritime Logistics Support Companies (PMLSC) now number to 30 MoU holders.  The article lists the highlights from the guidelines.

https://www.hellenicshippingnews.com/nigeria-guidance-on-contracting-government-security-forces/

https://www.skuld.com/topics/port/piracy/nigeria-guidance-on-contracting-government-security-forces/

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On 9 March, Insight Crime reported that a new investigative report shows Ponzi and pyramid schemes have proliferated across Caribbean countries during the pandemic, and authorities have been unable to keep up.  It is said that the schemes “have already cost would-be investors in the hundreds of millions of dollars”. It is said that many Caribbean nations have struggled to combat these schemes. Laws are outdated and can contain loopholes, according to the report. In Guyana, for example, pyramid selling is prohibited, but the law “only covers goods and services and not financial investments”.  Following the “Cash Plus” scandal, Jamaica amended its financial laws in 2013 to explicitly ban Ponzi and pyramid schemes. Trinidad and Tobago and Antigua and Barbuda have no targeted legislation in place, according to the report.  It is also said that financial fraud is a low priority of Caribbean governments that are scrambling to combat Covid and its effects.  Across the Caribbean, as well as among Caribbean populations in the US, pyramid schemes are often disguised as communal savings clubs known as “sou-sous”, and the clubs often have innocuous names like “partners,” “box hands” or “blessing looms”.  The clubs — derived in West-Africa — are used by people who don’t have easy access to banks.

https://insightcrime.org/news/caribbean-ponzi-pyramid-schemes/

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On 10 March, an article from Control Risks says that the risk of fraud and corruption has increased substantially across Latin America.  Unfortunately, this situation coincides with troubling anti-corruption enforcement trends in the region. An updated index covers 15 Latin American countries comprising 95% of the region’s GDP. Rather than measuring perceptions of corruption or resulting economic damage, the Index evaluates countries based on how effectively they tackle the problem. Countries with a higher score are deemed more likely to prosecute and punish corrupt actors.  For example, Uruguay ranks highest on the index with a score of 7.78 out of 10, meaning it has been deemed the most likely to uncover, punish and deter corruption.  When comparing results for the 8 countries featured in last year’s index, Chile, Argentina, Colombia and Mexico have stagnated while Brazil, Guatemala and Venezuela saw decreases in their overall scores.  Peru was the standout exception, showing an improvement over the previous year’s assessment.  The article says that the findings have significant implications for companies doing business in Latin America. They reveal an uneven and rapidly changing enforcement landscape complicated by the COVID-19 pandemic. This underscores the need for companies to update their risk assessments and adapt their compliance programs to manage corruption risks. 

https://www.controlrisks.com/our-thinking/insights/headwinds-in-the-fight-against-corruption-in-latin-america

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On 9 March, following the publication of the update report on the Cayman Islands, FATF has issued an updated version of its consolidated schedule of all AML/CFT ratings.

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

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On 8 March, Covington & Burling LLP published an article about a report from the UK Independent Anti-Slavery Commissioner entitled “Preventing Modern Slavery & Human Trafficking: An Agenda for Action across the Financial Services Sector”.  This report concluded that there is a significant lack of awareness of modern slavery risks within the financial services sector.  It calls on the sector to “detect and disrupt this serious organised criminality” and to take proactive steps to mitigate the various risks associated with modern slavery, including financial, regulatory, legal, governance and reputational risks.  The article highlights the fact that the report notes that 45% of board level managers and directors, and 30% of financial services employees polled, agreed with the statement that “modern slavery is not something which occurs in the UK”.  The report identifies a panoply of modern slavery-related risks prevalent across the sector and makes a number of recommendations, noting that over three quarters of those surveyed believe that their organisations can do more to address the risks of modern slavery within the sector.

https://www.covfinancialservices.com/2021/03/the-uk-independent-anti-slavery-commissioners-january-2021-report-mitigating-modern-slavery-in-financial-services/#page=1

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On 10 March, Swissinfo reported that lawmakers have agreed to revise the money laundering law but have rejected new rules for lawyers, notaries and other consultants.  Financial intermediaries be required to verify the identity of customers, record which services have been provided to them, and clarify their background and purpose.  Associations that collect or distribute funds abroad for charitable purposes will also be required to be more transparent.  Banks will also be obliged to inform the Money Laundering Reporting Office Switzerland (MLROS) when they have any “well-founded suspicion” of criminal funds.

https://www.swissinfo.ch/eng/parliament-agrees-modest-tightening-of-anti-money-laundering-law/46435970

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