OTHER THINGS YOU MAY HAVE MISSED – MARCH 25

Panama Covid-19 update – La Prensa reported today that the Children’s Hospital has treated 783 cases of Covid-19 in children under the age of 14 since the pandemic arrived in the country.

Meanwhile, 497 new cases and 8 new fatalities, with 105 in ICU and 579 in other wards.

25 MARCH 2021

SLOVENIAN AUTHORITIES CHARGE VATICAN ‘SECURITY CONSULTANT’ WITH MONEY LAUNDERING

On 25 March, the Catholic News Agency reported that Slovenian authorities have reportedly filed preliminary charges against an Italian woman on suspicion of laundering funds illegally obtained from the Vatican through Slovenian-registered companies.

https://www.catholicnewsagency.com/news/report-slovenian-authorities-charge-vatican-security-consultant-cecilia-marogna-with-money-laundering

HOW ILLICIT OIL IS SMUGGLED INTO NORTH KOREA WITH CHINA’S HELP

On 25 March, KYC 360 relayed a New York Times story about China’s hands-off approach to tankers linked to North Korea.  It is said that The UN sanctions panel’s recommendations, photographs and satellite imagery provide reasonable grounds to believe that such vessels have violated the UN Resolutions, but at the moment, China is giving such vessels safe harbour.

https://www.riskscreen.com/kyc360/news/how-illicit-oil-is-smuggled-into-north-korea-with-chinas-help/

GERMANY: CORONAVIRUS AID TO ISLAMIC EXTREMISTS AND TERRORIST FINANCING

On 14 March, Die Welt reported that, in at least 3 cases, there is evidence that the aid has been used to finance terrorism in war zones in the Middle East. Investigations are already underway in Berlin against more than 60 people and mosque associations.

https://www.welt.de/politik/deutschland/article228201629/Corona-Hilfen-fuer-islamische-Extremisten-Bandenmaessiges-Vorgehen.html

BALKAN STATES UNDER PRESSURE TO PROSECUTE FINANCIERS OF TERRORISM

On 15 March, Balkan Insights carried an article saying that, since hundreds of Balkan extremists went abroad to fight for Islamic State and other militant groups, Albania, Bosnia and Herzegovina, Montenegro, North Macedonia and Serbia have come under increased international pressure to clamp down on the financing of terrorism.  However, only 5 people have so far been found guilty of charges of financing terrorism – 1 in Albania and 4 in Serbia.

https://balkaninsight.com/2021/03/15/balkan-states-under-pressure-to-prosecute-financiers-of-terrorism/

THE COUNCIL OF EUROPE HUMAN RIGHTS COMMISSIONER CALLS ON TURKEY TO REFRAIN FROM FURTHER IMPLEMENTING NEW TERRORISM FINANCING LAW

On 10 March, the Stockholm Center for Freedom reported on a letter to Turkey’s interior and justice ministers from Council of Europe (CoE) Commissioner for Human Rights Dunja Mijatović that called on Turkish authorities to refrain from further implementing new terrorism financing legislation pending the outcome of a Venice Commission review expected in June 2021, and which threaten the very existence of human rights NGO.  The terrorism financing legislation amends seven domestic laws and enables the interior ministry to target non-governmental groups’ legitimate and lawful activities and the right to association of their members.

https://stockholmcf.org/coe-human-rights-commissioner-calls-on-turkey-to-refrain-from-further-implementing-new-terrorism-financing-law/

UK GAMBLING COMMISSION FINES CASUMO £6 MILLION AMID PLAYER INTERACTION FAILINGS

On 25 March, iGB reported that the Commission has fined online operator Casumo £6 million for AML and social responsibility failings, including allowing a player to lose £1.1 million without a responsible gambling interaction.  Its AML failings included a finding that customers could deposit “significant sums of money” without AML checks, while source of funds checks were found to be “insufficient” as payslips and invoices presented as evidence of funds were not corroborated with bank statements.

https://igamingbusiness.com/gambling-commission-fines-casumo-6m-amid-player-interaction-failings

“ILLEGAL PMC” EXPOSED IN UKRAINE

On 24 March, UNIAN reported that the Security Service of Ukraine (SBU) says it has exposed and terminated the activity of an illegal armed group, or a “private military company” (PMC).  It is said that the PMC consisted of over 150 people and operated under the guise of security firms and NGOs. PMC members would undergo training at a training base in Kyiv region, including combat training, weapon handling, and warfare skills.  Also, part of the PMC members attended training centres abroad,

https://www.unian.info/society/sbu-illegal-pmc-exposed-in-ukraine-11364889.html

CANADA ANNOUNCES HUMAN RIGHTS SANCTIONS AGAINST CHINA

On 23 March, McCarthy Tetrault LLP reported that Canada has imposed economic sanctions against the People’s Republic of China for the first time since the 1989 crackdown on student protestors in Beijing’s Tiananmen Square. On 22 March, it initially targeted 4 Chinese government officials and a Chinese entity in response to what the Canadian government has deemed to be “gross and systematic human rights violations” against Uyghurs in China’s north-west region of Xinjiang.

https://www.mccarthy.ca/en/insights/blogs/terms-trade/canada-announces-human-rights-sanctions-against-china#page=1

EU SANCTIONS SOUTH SUDAN GENERAL OVER HUMAN RIGHTS VIOLATIONS

On 25 March, The East African reported that the EU has sanctioned South Sudan army general Gabriel Moses Lokujo over human rights violations.  The EU described the sanction as a signal and strong determination as a stand up for human rights and taking tangible action against those responsible for violations and abuses.

https://www.theeastafrican.co.ke/tea/news/east-africa/eu-sanctions-south-sudan-general-3335382

EU: 5 ARRESTS IN HIT AGAINST INVESTMENT FRAUDSTERS

On 25 March, a news release from Europol advised that, on 4 March, Europol supported a hit on a large investment fraud network operating in several EU Member States. The investigation led the by Lithuanian Police and involving law enforcement authorities from Germany, Sweden and the UK was also assisted by Eurojust.  The criminal network was specifically targeting academics in Germany. The victims were interested in investing their retirement funds in saving accounts hosted on foreign online deposit platforms.

https://www.europol.europa.eu/newsroom/news/five-arrests-in-hit-against-investment-fraudsters

GETTING SERIOUS? ILLICIT FINANCE IS FINALLY A UK FOREIGN POLICY ISSUE

On 25 March, a Commentary from RUSI says that the UK government’s commitment , in its integrated defence and security review, to reinvigorate its efforts to tackle illicit finance is welcome. Now, it says, the hard work starts. 

https://www.rusi.org/commentary/getting-serious-illicit-finance-finally-uk-foreign-policy-issue

AUSTRIA EXTRADITES FORMER RUSSIAN CULTURE OFFICIAL WANTED ON EMBEZZLEMENT CHARGES

On 25 March, Rferl reported that Austrian authorities have extradited Boris Mazo, a former employee of the Russian Culture Ministry who is suspected in Russia of fraud and embezzlement.

https://www.rferl.org/a/austria-russian-culture-official-embezzlement-extradited/31169161.html

GERMAN MASK SCANDAL: BAVARIA ISSUES ARREST WARRANT

On 25 March, Deutsche Welle reported that public prosecutors in Bavaria have issued an arrest warrant as part of their investigation into corruption following the mask contracts scandal. It does not appear to target the politicians under suspicion.  5 people are being investigated under suspicion of corruption. Among those are the conservative politicians from the Christian Socialist Union (CSU) Georg Nüsslein and Alfred Sauter.

https://www.dw.com/en/german-mask-scandal-bavaria-issues-arrest-warrant/a-56989192

HM TREASURY AML ADVISORY: HIGH-RISK COUNTRIES

On 25 March, an Advisory from HM Treasury explained that the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 require the UK regulated sector to apply enhanced customer due diligence in relation to high-risk countries.  It explains that recent amendments remove references to the EU list of high-risk third countries and defines high risk third countries for the purposes of the 2019 Regulations, as countries identified as being of higher risk.  This list for the Regulations replicates the list of those countries listed by FATF as high risk, or under increased monitoring.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/973241/HM_Treasury_Adviosry_Notice_High_Risk_Third_Countries__002_.pdf

CRIME SYNDICATES MUTATE IN THE LEVANT AMID WAR AND COVID-19

On 25 March, OCCRP said that a report from the Global Initiative Against Transnational Organized Crime reports that. combined with the ongoing normalisation of regional instability and violence, the COVID-19 pandemic has brought on new opportunities for criminal expansion in the Levant (Lebanon, Jordan, Syria and Iraq), where illicit activity could become a “permanent and pervasive fixture”, experts say.  Through a cross-analysis of the region’s illicit markets, the report draws on how criminal drugs, arms and people markets have not only been fueled by regional instability and violence, but have in turn fueled it.  Disruptions to supply chains have resulted in a “free-for-all” in the production of narcotics, “as counterfeit drugs and substandard medical supplies circulate in an uncharted and chaotic environment”.

https://www.occrp.org/en/daily/14113-report-crime-syndicates-mutate-in-the-levant-amid-war-and-covid-19

THE US CORPORATE TRANSPARENCY ACT: WHY BENEFICIAL OWNERSHIP IS STILL A BIG DEAL

On 23 March, Ross Delston made available a 37-page Powerpoint presentation about the CTA and planned US beneficial ownership requirements

https://media-exp1.licdn.com/dms/document/C4D1FAQFLs77uWTdn2Q/feedshare-document-pdf-analyzed/0/1616641323881?e=1616770800&v=beta&t=mskq7n2-SPmmjmx1JNiXE6I46tf8GhiYkQ0ZIPM3C2U

TOP PLAYERS LEFT OUT OF CENTRAL BANK OF NIGERIA’S APPROVED LIST OF FOREIGN REMITTANCES OPERATORS

On 24 March, Technext reported that Flutterwave, Interswitch and 45 other International Money Transfer Operators (IMTO) have just been approved by the Central Bank of Nigeria (CBN) to receive foreign remittances into the country.  Of the 47 IMTO approved by the CBN, 18 of them were local. Under new laws, Nigerians in the diaspora will only be able to send money into the country through approved IMTO, and it also forces IMTO and Money Deposit Banks like GTbank to pay recipients of remittances in foreign currencies, rather than Nigerian currency.

https://technext.ng/2021/03/24/transferwise-others-top-players-left-out-of-central-bank-of-nigerias-approved-list-of-foreign-remittances-operators/

THE GLOBAL TRADE IN COUNTERFEIT “MADE IN SWITZERLAND” GOODS CHEATED THE SWISS ECONOMY OUT OF 10,000 JOBS AND $4.9 BILLION IN ONE YEAR ALONE

On 23 March, Swissinfo referred to OECD data, which organisation also says that half of the people buying fake goods were duped into believing they were purchasing the real thing.  The Swiss watch and jewellery sectors were hit the hardest.  The vast majority of fakes that were passed off as Swiss originated in China and Hong Kong, followed by Singapore and Turkey. India is also blamed for counterfeiting of medicinal products.

https://www.swissinfo.ch/eng/fake-goods-cost-switzerland-chf4.5-billion-in-a-single-year/46471768

FURTHER TARGETED RANSOMWARE ATTACKS ON THE UK EDUCATION SECTOR BY CYBER CRIMINALS

On 23 March, the UK National Cyber Security Centre issued an Alert saying that, since late February 2021, an increased number of ransomware attacks have affected education establishments in the UK, including schools, colleges and universities.  It urges organisations to take steps to disrupt ransomware attack vectors and enable effective recovery from ransomware attacks.

https://www.ncsc.gov.uk/news/alert-targeted-ransomware-attacks-on-uk-education-sector

SOUTH KOREA: TAX AGENCY LAUNCHES PROBES INTO OFFSHORE TAX EVASION

On 24 March, the Yonhap News Agency reported that South Korea’s tax agency has said that it has launched probes into suspected offshore tax evasion by more than 50 individuals and foreign companies as it seeks to strengthen its crackdown on tax dodgers.

https://en.yna.co.kr/view/AEN20210324003300320

MEXICAN LIFESTYLE MAGAZINE RUN BY RELATIVES OF DRUGS CARTEL ASSOCIATES

On 18 March, Kharon reported that Mexican lifestyle magazine Pagina Uno is, and has been, led by multiple individuals with familial ties to associates of drug cartels, including the Cartel de Jalisco Nueva Generacion (CJNG).  The monthly magazine covers luxury, fashion, travel and technology, among other topics.

https://brief.kharon.com/updates/mexican-lifestyle-magazine-run-by-relatives-of-cartel-associates

CHINA PROSECUTES SEVERAL CASES OF NORTH KOREAN SMUGGLING CONSPIRACIES

On 19 March, Kharon reported that court documents detail cases of coal, zinc and sand smuggling, activity banned under UN sanctions. 

https://brief.kharon.com/updates/china-prosecutes-several-cases-of-north-korean-smuggling-conspiracies

LATIN AMERICA ANTI-BRIBERY YEAR-IN-REVIEW: 2020 DEVELOPMENTS AND PREDICTIONS FOR 2021

A Client Alert from Wilmer hale on 25 March summarises key Latin America anti-bribery enforcement developments from 2020 and provides predictions for 2021.  It says that DoJ and SEC maintained their extensive cooperation with foreign law enforcement, especially in South America, making 2020 a record-breaking year with well over $6 billion in corporate monetary penalties.  These FCPA enforcement trends are critically important both to Latin American companies and to US companies doing business in Latin America.  Both a report and 17-minute video are available.

https://www.wilmerhale.com/en/insights/client-alerts/20210319-latin-america-and-foreign-corrupt-practices-act

ISLE OF MAN FOLLOWS UK LEAD ON VENEZUELA, IRAN, SYRIA AND GLOBAL HUMAN RIGHTS SANCTIONS

On 25 March, the Isle of Man published a series of news releases advising of, like the UK, changes to the various sanctions regimes.

https://www.gov.im/news/2021/mar/25/financial-sanctions-venezuela/

https://www.gov.im/news/2021/mar/25/financial-sanctions-syria/

https://www.gov.im/news/2021/mar/25/financial-sanctions-iran-nuclear-proliferation/

https://www.gov.im/news/2021/mar/25/financial-sanctions-global-human-rights-regime/

IRELAND: OVER €6B RAISED IN BETTING TAXES, WHILE 55,000 IMPACTED BY SERIOUS GAMBLING DISORDER 

On 25 March, the Kildare Nationalist reported that up to 55,000 Irish people are estimated to have a serious gambling disorder according to a report funded by the Gambling Awareness Trust (GAT), who say tax revenue from the industry is now worth between €6 billion and €8 billion to the State per annum.  Approximately 66% of men, women and under-18s are said to be gambling in Ireland.

https://gamblingcare.ie/

https://kildare-nationalist.ie/2021/03/25/over-e6b-raised-in-betting-taxes-while-55000-impacted-by-serious-gambling-disorder-report/

US-EU NEGOTIATIONS ON TRANSATLANTIC DATA PRIVACY FLOWS

On 25 March, a news release from the EU advised that the EU Commissioner for Justice and the US Secretary of Commerce had made a statement regarding the negotiations on transatlantic data privacy flows.  They said that they have decided to intensify negotiations on an enhanced EU-US Privacy Shield framework to comply with the 16 July 2020 judgment of the Court of Justice of the European Union in the Schrems II case.

https://ec.europa.eu/commission/presscorner/api/files/document/print/en/statement_21_1443/STATEMENT_21_1443_EN.pdf

ISRAEL: EX-DEPUTY MINISTER KIRSCHENBAUM CONVICTED OF BRIBERY

On 25 March, the Jerusalem Post reported that former deputy minister faina Kirshcenbaum has been convicted of bribery by the Tel Aviv District Court, in one of the worst public corruption cases in Israeli history that had already led to over a dozen convictions.

https://www.jpost.com/israel-news/ex-deputy-minister-kirschenbaum-convicted-of-bribery-663214

FinCEN’s $390 MILLION CASE AGAINST CAPITAL ONE – AND WHAT IT MEANS FOR AML ENFORCEMENT

On 25 March, an article from Proskauer says that FinCEN’s recent case against Capital One shows how FinCEN’s approach to AML enforcement is evolving.  Involved was Capital One’s Check Cashing Group (CCG), a business unit under Capital One’s commercial bank through which Capital One provides banking services including processing checks and providing customers with armoured car cash shipments. FinCEN found that Capital One failed to maintain an AML program to guard against money laundering, failed to file SAR on suspicious transactions, and failed to file currency transaction reports (CTR).  The article advises that asset managers should ensure that the financial entities in which they invest have appropriate AML programmes in place.

https://www.privateequitylitigation.com/2021/03/fincens-390-million-case-against-capital-one-and-what-it-means-for-aml-enforcement

CBI RAIDS OVER 100 LOCATIONS ACROSS INDIA IN BANK FRAUD CASES

On 25 March, DNA reported that the Central Bureau of Investigation (CBI) has conducted searches over 100 places in 11 States and Union Territories (UTs) in connection with more than 30 cases of bank fraud.  The complainants include Indian Overseas Bank, Union Bank of India, Bank of Baroda, Punjab National Bank, State Bank of India, IDBI, Canara Bank, Indian Bank and Central Bank of India.

https://www.dnaindia.com/business/report-cbi-raids-over-100-locations-across-india-in-bank-fraud-cases-amounting-to-rs-3700-crores-2883104

US: FORMER MEXICAN GOVERNOR AND PRESIDENTIAL CANDIDATE CONVICTED OF MONEY LAUNDERING

On 25 March, a news release from the US DoJ advised that the former governor of Tamaulipas, Tomas Yarrington Ruvalcaba, 64, has admitted he accepted over $3.5 million in illegal bribe money and used it to fraudulently purchase property in the US.  Yarrington admitted he accepted bribes from individuals and private companies in Mexico to do business with the state of Tamaulipas while he served as governor.  Yarrington was in that position from 1999 to 2005. He was also an Institutional Revolutionary Party candidate for president of Mexico in 2005.

https://www.justice.gov/usao-sdtx/pr/former-mexican-governor-and-presidential-candidate-convicted-money-laundering

US: FINANCIAL ADVISOR OF GLOBAL INVESTMENT BANK SENTENCED TO 5 YEARS IN PRISON FOR $6 MILLION WIRE FRAUD AND INVESTMENT ADVISER FRAUD SCHEME

A news release from US DoJ on 25 March advised that Michael Barry Carter, 47, had been sentenced to 5 years in federal prison, followed by 3 years of supervised release, on charges of wire fraud and investment adviser fraud, in connection with a scheme to steal more than $6 million.  The judge also ordered Carter to pay a money judgment in the amount of the net proceeds he obtained from the scheme, which was at least $4,355,110.39.  Having control of a number of accounts, Carter made numerous unauthorised transactions from the victim accounts for his personal benefit, defrauding the 5 identified victims of at least $5 million.

https://www.justice.gov/usao-md/pr/financial-advisor-global-investment-bank-sentenced-federal-court-maryland-five-years

TAX AND THE BVI: SEPARATING MYTH FROM REALITY

An article from law firm Conyers on 25 March sets out to, as it says, to dispell some of the the “most glaringly misguided notions relating to the use of offshore jurisdictions”, with a focus on the BVI.  It discusses the tax (or rather, the non-taxation) situation there, and then moving on to regulation, saying that s that the BVI has a robust AML/CFT regime through the enactment of the Proceeds of Criminal Conduct Act 1997 (PCCA); the Anti-Money Laundering Regulations 2008 (AML regulations); and the Anti-Money Laundering and Terrorist Financing Code of Practice 2008.  The article then moves on to ownership of BVI vehicles, asking “is it as impossible to establish the beneficial owners of a British Virgin Islands company as the media would have you believe?” – however, the response is somewhat ambivalent – “in short, not quite” with, as in many other jurisdictions, reliance on the local “registered agent” model.

[In my view, the practical effect of such arrangements as employed by the BVI is to make it more difficult, if not actually impossible, to carry out meaningful searches, and meaning that you need to know exactly who and/or what you are looking for, and where, with quite specific requests – thus aiding opacity, whether by design or otherwise…].

https://www.jdsupra.com/legalnews/tax-and-the-british-virgin-islands-1444954/

$50 MILLION RANSOM DEMAND “LARGEST EVER”

On 25 March, Robinson + Cole Data published an article saying that, in what is being reported as the largest ransom demand ever, Taiwanese electronics and computer manufacturer Acer has reportedly been hit with a ransomware attack by REvil, which is demanding a ransom of $50 million for the destruction of leaked documents.

https://www.dataprivacyandsecurityinsider.com/2021/03/50-million-ransom-demand-largest-ever/

MALTA: FINANCIAL PRACTITIONER DESCRIBED AS A PROFESSIONAL MONEY LAUNDERER BY A COURT EXPERT APPOINTED IN A MAGISTERIAL INQUIRY

On 25 March, Lovin Malta reported on a sitting where the owner and the director and former MLRO of a financial services firm faced charges of money laundering and corruption amongst others.  2 inspectors exhibited evidence which mainly consisted of documents obtained by the magisterial inquiry as well as transcripts of the statements they had given the police. 

https://lovinmalta.com/news/zenith-matthew-pace-describe-as-professional-money-launderer-by-court-expert-in-inquiry/

A VERY MODERN FORM OF PIRACY: CYBERCRIME AGAINST THE SHIPPING INDUSTRY (PART 1)

On 25 March, Clyde & Co published the first part of a series of articles that will consider some of the key issues surrounding the threats posed to the shipping industry and highlight some of the most important steps that can be taken to mitigate that risk. This first article considers examples of the risks and vulnerabilities that particularly affect the shipping industry as well as highlighting the importance of reacting to developments in market knowledge by reference to contract of carriage claims. 

https://www.clydeco.com/en/insights/2021/03/a-very-modern-form-of-piracy-cybercrime-against-th

WIDOW OF BANGLADESH SHIPBREAKER CAN PURSUE TEST CASE IN UK

On 25 March, Insurance Marine News reported that a Bangladeshi woman whose husband died during the dismantling of an oil tanker in a Bangladesh shipyard has been given permission to persist with a claim for compensation from a UK company that is linked to the vessel.  The Court of Appeal has rejected a request by London-based shipbroker Maran (UK) Ltd that the negligence case to be dismissed. It was the second appeal the company had lost.  Her UK-based lawyers assert that working conditions in Bangladesh’s yards were known to be dangerous. They argue that Maran bore responsibility for her husband’s death because it sold the tanker to an intermediary, knowing that it would probably end up in Chittagong.

https://insurancemarinenews.com/insurance-marine-news/widow-of-bangladesh-shipbreaker-can-pursue-test-case-in-uk/

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UK ADDS NEW MYANMAR ENTITY TO HUMAN RIGHTS SANCTIONS LIST

On 25 March, a Notice from HM Treasury advised that MYANMAR ECONOMIC HOLDINGS PUBLIC COMPANY had been added to the UK sanctions lists.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/973250/Notice_Global_Human_Rights_250321.pdf

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FinCEN ISSUES NOTICE RELATED TO THE TRADE OF ANTIQUITIES AND ART

On 24 March, Crowell Moring reported that FinCEN had published its first Notice related to one of the many changes made in the Anti-Money Laundering Act of 2020, passed as part of the National Defense Authorization Act 2021.  Its guidance informs financial institutions about the AML Act’s provisions related to trade in antiquities and art, underscores that illicit activity related to antiquities and art may involve financial institutions and trigger reporting requirements, and provides specific instructions for filing SAR related to suspicious activity involving antiquities and art.  The AML Act broadened the definition of “financial institutions” in the Bank Secrecy Act.  According to FinCEN’s Notice, illicit activity involving trade in antiquities and art might include looting, theft, illicit excavation of archaeological items, smuggling, the sale of stolen or counterfeit items, money laundering and sanctions violations.

https://www.cmtradelaw.com/2021/03/fincen-issues-notice-related-to-the-trade-of-antiquities-and-art

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UK AMENDMENTS TO SYRIA AND IRAN SANCTIONS REGIMES

UK AMENDS 2 ENTRIES ON SYRIA SANCTIONS LIST

On 25 March, a Notice from HM treasury advised that the entries for HAMSHO TRADING and INDUSTRIAL ESTABLISHMENT OF DEFENCE have been amended.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/973240/Notice_Syria_250321.pdf

UK AMENDS 3 ENTRIES ON IRAN SANCTIONS LIST

On 25 March, a Notice from HM Treasury advised that 3 existing entries, subject to sanctions for reasons connected to that country’s nuclear programme – ASHTIAN TABLO, the IRAN CENTRIFUGE TECHNOLOGY COMPANY and SUN MIDDLE EAST FZ COMPANY, have been amended.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/973237/Notice_Iran__Nuclear__250321.pdf

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UK AMENDS 1 ENTRY ON VENEZUELAN SANCTIONS LIST

On 25 March, a Notice from HM treasury advised that the entry for Delcy Eloina RODRIGUEZ GOMEZ has been amended.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/973233/Notice_Venezuela_250321.pdf

If you would like to make a modest contribution for my time and ongoing expenses, I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y

CANADA ANNOUNCES HUMAN RIGHTS SANCTIONS AGAINST CHINA

On 23 March, McCarthy Tetrault LLP reported that Canada has imposed economic sanctions against the People’s Republic of China for the first time since the 1989 crackdown on student protestors in Beijing’s Tiananmen Square. On 22 March, it initially targeted 4 Chinese government officials and a Chinese entity in response to what the Canadian government has deemed to be “gross and systematic human rights violations” against Uyghurs in China’s north-west region of Xinjiang.

https://www.mccarthy.ca/en/insights/blogs/terms-trade/canada-announces-human-rights-sanctions-against-china#page=1

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OFAC SANCTIONS CHANGES: BURMA/MYANMAR, COUNTER-TERRORISM AND HUMAN RIGHTS AMENDMENTS; NEW LICENCES AND FAQ

On 25 March, OFAC announced that 2 Myanmar companies linked to the Burmese military have been added to the sanctions lists, and a military unit deleted from the lists.  The entry for a Tanzanian national has also been amended.  OFAC has also issued 4 General Licenses linked to the Myanmar sanctions, together with 2 new FAQ.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210325

https://home.treasury.gov/news/press-releases/jy0078

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NORD STREAM 2: RUSSIA’S TRICKS TO DODGE US SANCTIONS

On 24 March, Deutsche Welle reported that EU technology is being harnessed to help a Russian pipe-laying ship to complete the controversial Nord Stream 2 gas pipeline, and an investigation reveals just how Russia is bypassing US sanctions.  The investigation reveals how the latest precision tube processing technology from Italian company Nuova Patavium is being used onboard the ship.  The revelations are remarkable in light of the financial penalties facing anyone involved in the construction of Nord Stream 2 with contracts worth more than $1 million.  The article examines how the sanctions are evaded.

https://www.dw.com/en/nord-stream-2-russias-tricks-to-dodge-us-sanctions/a-56972537

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OTHER THINGS YOU MAY HAVE MISSED – MARCH 24

Panama Covid-19 update – the virus continues to circulate, with another 415 new cases reported today – meaning that there are 5,043 active cases, of which 107 are in ICU and 581 in other wards. There were another 5 fatalities.

24 MARCH 2021

GERMANY HIRES TOP SWISS REGULATOR TO HEAD ITS FINANCE WATCHDOG
On 22 March, Reuters reported that Mark Branson, the head of Switzerland’s financial markets regulator, is to become president of Germany’s finance watchdog BaFin, as part of a shake-up at the regulator after the Wirecard fraud.

https://www.reuters.com/article/idUSKBN2BE17S

SINGAPORE CHARGES 33-YEAR-OLD IN ALLEGED $750 MILLION FRAUD

On 22 March, Bloomberg reported that Singapore has accused Ng Yu Zhi. 33, of fraud over his alleged involvement in cheating investors to put at least S$1 billion into nickel deals that never took place.  This followed an investigation into Envy Asset Management Pte and Envy Global Trading Pte, where Ng served as a director. Investors were promised varying returns, which averaged 15%, over a period of three months, and many rolled over their contracts to reinvest their principal and returns, according to court proceedings.

https://www.bloomberg.com/news/articles/2021-03-22/singapore-charges-director-in-alleged-nickel-trading-fraud?sref=ldCf194q

WIRECARD AIDED ONLINE MARIJUANA SALES, US PROSECUTORS ALLEGE

On 23 March, the Wall Street Journal reported claims in a US court that Wirecard AG and its fugitive former No. 2 executive played a key role in an alleged scheme to trick banks into processing marijuana sales.  It is alleged that Wirecard was one of several European banks that opened fraudulent accounts to disguise around $160 million in marijuana purchases made through Eaze Technologies Inc, a California-based marijuana-delivery service.  The supply of marijuana remains technically illegal under federal law, even where legalised at state level.

https://www.wsj.com/articles/wirecard-aided-online-marijuana-sales-prosecutors-allege-11616502728

AUSTRALIAN AUTHORITIES TO BLOCK A FURTHER 10 GAMBLING WEBSITES

On 24 March, iGB reported that the Australian Communications and Media Authority (ACMA) has ordered the blocking of a further 10 online gambling websites it said have been operating in the country illegally.  Since November 2019, a total of 238 illegal gambling websites have been blocked in the country, and another 130 illegal services have pulled out of the country’s market since it began to enforce new illegal offshore gambling rules in 2017.

https://igamingbusiness.com/australian-authorities-to-block-a-further-10-gambling-websites

AUSTRALIA: 2 VIDEOS ON DEALING WITH THE PROCEEDS OF CRIME

On 18 March, Sydney criminal lawyers published 2 new videos –

·         Dealing With Property Reasonably Suspected of Being Proceeds of Crime – $100,000 or More; and

·         Intentionally Dealing in Proceeds of Crime – Any Value.

https://www.sydneycriminallawyers.com.au/videos/dealing-with-property-reasonably-suspected-of-being-proceeds-of-crime-100000-or-more/#page=1

https://www.sydneycriminallawyers.com.au/videos/intentionally-dealing-in-proceeds-of-crime-any-value/#page=1 

LITHUANIA: CUSTOMS SEIZES SOFTWARE FOR WMD AND CONVENTIONAL WEAPONS

On 24 March, Delfin.com reported that Lithuanian customs officers had detained software that can be used for WMD and conventional weapons.  The software concerned was seized during an attempt to export it to UAE without the required documents. The consignor was an Irish company which initially failed to submit the required export licence.

https://www.delfi.lt/en/politics/customs-seize-software-for-weapons-of-mass-destruction-and-conventional-weapons.d?id=86772685

INDIA: SMUGGLERS BUSTED WITH $382,000 IN GOLD AND CASH UNDER THEIR TOUPEES

On 23 March, the New York Post reported that 2 suspects were busted at an airport trying to smuggle gold and money under their wigs.  They concealed black packets of gold paste weighing 698 grams, and gold was also discovered in the hapless traffickers’ socks and even rectums. All told, the confiscated contraband was reportedly worth a whopping $382,943.

https://nypost.com/2021/03/23/smugglers-busted-with-382k-in-gold-and-cash-under-toupees/

FORMER ECUADORIAN GOVERNMENT OFFICIAL SENTENCED TO PRISON FOR ROLE IN BRIBERY AND MONEY LAUNDERING SCHEME

A news release from the US DoJ on 23 March advised that Juan Ribas Domenech, 52, an Ecuadorian and Italian national, was sentenced to 51 months in prison for his role in a scheme to launder bribes paid to him in exchange for helping 3 UK reinsurance companies obtain and retain reinsurance business from Ecuador’s public surety company.  Ribas was the chairman of Seguros Sucre, Ecuador’s state-owned and -controlled surety company and an advisor to the then-president of Ecuador.  Bribe payments were paid through various intermediaries, including two reinsurance introducer companies. A portion of the bribes were laundered through the US.

https://www.justice.gov/opa/pr/former-ecuadorian-government-official-sentenced-prison-role-bribery-and-money-laundering

DRAFT BILL AND THE 7-POINT PLAN TO REFORM GERMANY’S FEDERAL FINANCIAL SUPERVISORY AUTHORITY 

An article from Bird & Bird on 24 March reports developments that follow the Wirecard and Greensill scandals.

https://www.twobirds.com/en/news/articles/2020/germany/implications-following-the-wirecard-case-and-greensill

FORMER IMF CHIEF RATO FACES FRESH FRAUD ACCUSATIONS IN SPAIN

On 24 March, EurActiv reported that the former managing director of the IMF, Rodrigo Rato, is facing fresh allegations fromSpanish anti-corruption prosecutors, including alleged tax fraud, corruption, and document falsification.  It is said that Spain’s anti-corruption prosecutor’s office outlined 11 allegations against the former politician and banker.

https://www.euractiv.com/section/justice-home-affairs/news/former-imf-chief-rato-faces-fresh-fraud-accusations-in-spain/

RUSSIAN REGIONAL GOVERNOR FIRED AFTER BRIBERY CHARGE

On 24 March, Rferl reported that Russian President Vladimir Putin has dismissed Ivan Belozertsev, one of his staunch supporters, the governor of the Penza region in the Volga Federal District, after he was arrested on suspicion of taking a bribe.

https://www.rferl.org/a/russia-penza-governor-fired-after-bribery-charg/31167255.html

FINANCIAL CRIME COMPLIANCE COSTS INCREASED 20.6% ACROSS ASIA-PACIFIC REGION

On 24 March, the Paypers reported that a survey identifies the drivers affecting financial crime compliance and highlights spending trends. The study also explores the business impacts of changes in the financial crime compliance environment particularly regarding new regulations and identifies challenges and impacts associated with the COVID-19 pandemic.  The report found that the total projected cost of financial crime compliance increased for larger financial institutions in the Asia-Pacific (APAC) market. 

https://thepaypers.com/digital-identity-security-online-fraud/financial-crime-compliance-costs-increased-206-across-apac-lexisnexis-shows–1247966

UK: CONFIDENCE IN BEVERAGE SUPPLY CHAINS COMES UNDER PRESSURE AS FRAUD CONCERNS RISE

CLH News in the UK on 24 March said that a combination of widespread incidence of food fraud and significant supply chain disruption signals a rising level of brand and product risk for global beverage manufacturers, according to a new report.   Despite the risk to brands and potential serious consequences for people’s health, only 37% of those surveyed regard managing fraud as a ‘very high priority’, with a significant minority (1 in 5) in the alcohol sector rating it as an ‘average priority’ or lower.

https://catererlicensee.com/confidence-in-beverage-supply-chains-comes-under-pressure-as-fraud-concerns-rise/

UK: REPORT PUTS ‘UMBRELLA’ COMPANIES UNDER THE SPOTLIGHT

On 24 March, the Chartered Institute of Taxation reported that the Low Incomes Tax Reform Group (LITRG) has published a new research report looking at the use of ‘umbrella’ companies and other labour market intermediaries in the UK.  The factual and technical report also considers the nature and scale of disguised remuneration schemes.  It is intended to help increase public knowledge of how labour market intermediaries work and bolster the evidence base in this under-researched area.

https://www.tax.org.uk/media-centre/press-releases/litrg-press-release-litrg-report-puts-‘umbrella’-companies-under

FURLOUGH FRAUD LOSSES: THE TAXPAYER PROTECTION TASKFORCE

An article from White & Case on 24 March says that a year since the introduction of the Coronavirus Job Retention Scheme, or the ‘furlough scheme’ as it is more commonly known, the extent of fraud associated with the government assistance programme has started to become clear.  In the recent Budget, the UK Chancellor announced the creation of the Taxpayer Protection Taskforce.  The Government is investing £100 million in the deployment of a team of 1,265 HMRC officials to investigate individuals and companies who have exploited the various schemes designed to assist businesses and employees to withstand the COVID-19 pandemic.  It is said that HMRC is giving employers some leeway to report excessive claims, noting that it is not seeking to punish mistakes in compliance, but rather to tackle deliberate non-compliance.  It is also said that reported that millions of pounds have been provided to businesses beneficially owned by foreign states and billionaire tax exiles.

https://www.jdsupra.com/legalnews/rishi-rushes-to-recoup-furlough-fraud-2410081/

UK: UPDATED GUIDANCE ON DEFINITION AND SCOPE OF CONTROLLED TECHNOLOGY IN RELATION TO STRATEGIC EXPORT CONTROL LEGISLATION

On 24 March, Notice to Exporters 2021/02 contained updated guidance on –

  • the scope of regulations around transferring military or dual-use technology;
  • the scope of technology transfer including cloud storage and routing;
  • technology control exceptions in the Export Control Order 2008;
  • what licences to use for controlled technology transfer; and
  • UK and EU technology legislation definitions.

It says that trade associations or those who represent exporters should alert their members to this new guidance.

https://www.gov.uk/government/publications/notice-to-exporters-202102-exporting-military-or-dual-use-technology/nte-202102-exporting-military-or-dual-use-technology

UK: MANDATORY CLIMATE-RELATED FINANCIAL DISCLOSURES BY PUBLICLY QUOTED COMPANIES, LARGE PRIVATE COMPANIES AND LLP

On 24 March, a news release from the Department for Business, Energy and Industrial Strategy launched a consultation which seeks views on proposals to mandate climate-related financial disclosures by publicly quoted companies, large private companies and Limited Liability Partnerships (LLP).  The closing date is 5 May.

https://www.gov.uk/government/consultations/mandatory-climate-related-financial-disclosures-by-publicly-quoted-companies-large-private-companies-and-llps

BROCHURE: A GUIDE TO THE UK’S COMMERCIAL SPACEPORTS

On 23 March, the UK Space Agency published a brochure which offers an overview of the proposed commercial spaceports currently being developed across the UK.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/972340/4156_A5_brochure_UKSA_Spaceport_Broch_TC_Proof9.pdf

ECONOMIC SUBSTANCE UPDATE: BERMUDA AND CAYMAN ISLANDS

On 24 March, Appleby published a short article as its first update of 2021.

https://www.applebyglobal.com/publications/economic-substance-update-q1-2021/

EDPB GUIDELINES ON VIRTUAL VOICE ASSISTANTS

On 24 March, CMS Law reported that the European Data Protection Board (EDPB) had published its draft Guidelines on Virtual Voice Assistants (VVA), which are software services that take voice as an input, identify and execute a command or question, and interact with users or other devices. The guidelines provide a hands-on guidance for stakeholders across the whole VVA ecosystem.  The EDPB has launched a public consultation on the draft guidelines. Comments can be submitted by 23 April.

https://www.cms-lawnow.com/ealerts/2021/03/edpb-guidelines-on-virtual-voice-assistants

US AND UK: QUARTERLY FINANCIAL CRIME HORIZON SCANNERS

On 24 March, Eversheds Sutherland published 2 publications that summarise key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources.

https://www.eversheds-sutherland.com/global/en/what/articles/index.page?ArticleID=en/Fraud_and_financial_crime/Financial_Crime_Horizon_Scanner_Q1_2021

FCA CAMPAIGN TO ENCOURAGE INDIVIDUALS TO REPORT WRONGDOING

On 24 March, a release on Mondo Visione reported that the campaign, ‘In confidence, with confidence’, encourages individuals working in financial services to report potential wrongdoing to the FCA, and reminds them of the confidentiality processes in place.  As part of the campaign, the FCA has published materials for firms to share with employees, as well as using its events to highlight the campaign.

It has also produced a digital toolkit for industry bodies, consumer groups and whistleblowing groups to encourage individuals to have confidence to step forward. 

https://mondovisione.com/media-and-resources/news/uk-financial-conduct-authority-launches-campaign-to-encourage-individuals-to-rep/

https://www.fca.org.uk/news/press-releases/fca-launches-campaign-encourage-individuals-report-wrongdoing

CANADA: KYC REQUIREMENTS UPDATED

On 24 March, FINTRAC issued new guidance on KYC, including that for PEP and heads of international organisations.

https://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/1-eng

USING WOOD FORENSIC SCIENCE TO DETER CORRUPTION AND ILLEGALITY IN THE TIMBER TRADE

The World Wildlife Fund and TRAFFIC have released a report saying that illegal logging and the associated illegal timber trade are major global threats to forest conservation and management and are closely linked to corruption, both in the forest and in the supply chain to market.  It also said that wood forensic science has yet to reach its full potential but is improving rapidly; properly supported and used in combination with other approaches, it can make a significant contribution towards combatting crime and corruption in the forestry sector.

https://www.worldwildlife.org/pages/tnrc-topic-brief-using-wood-forensic-science-to-deter-corruption-and-illegality-in-the-timber-trade

DARK SIDE OF CHINA’S ORGANISED CRIME CRACKDOWN REVEALED IN PRIVATE LENDER CASE

On 23 March, the South China Morning Post reported that loans to cash-hungry businesses lead to life imprisonment for woman caught up in a government campaign against crime and corruption.  Her lawyer warns this and similar cases could end the country’s vast private credit market.  The article looks at how lenders vital to the booming private sector have been caught in ever-changing regulatory nets.

https://www.scmp.com/news/china/politics/article/3126274/dark-side-chinas-organised-crime-crackdown-revealed-private

FEDS SLASH SWISS BANKER’S SENTENCE IN VENEZUELAN MONEY LAUNDERING CASE IN MIAMI

On 24 March, the Miami Herald reported that Matthias Krull, a Swiss banker who was thrust into the spotlight of a billion-dollar Venezuelan money laundering case in Miami has received one of the biggest sentence reductions in US history because of his assistance in helping federal authorities unravel an international web of financial corruption.

https://www.miamiherald.com/news/local/article250155995.html

TIME TO RETURN INTEGRITY TO THE UK CORPORATE REGISTRY

On 4 March, RUSI issued this short, 6-minute video saying that, over the last decade there has been a succession of money laundering scandals with the UK and its Companies House at the centre.  Journalist and Author Oliver Bullough explains how this happened, the devastating impact it has across the globe and what the UK government can do about it.

https://www.youtube.com/watch?v=LHTmRPtMXs8

REPORT: EU-TURKEY POLITICAL, ECONOMIC AND TRADE RELATIONS

On 24 March, the EU Sanctions blog reported that the EU Commission has received a report which, amongst other things, says that its relations, and dialogue on Greek-Turkish maritime issues have improved since December 2020 – but it nevertheless on further targeted sanctions and other measures

https://ec.europa.eu/transparency/regdoc/rep/10101/2021/EN/JOIN-2021-8-F2-EN-MAIN-PART-1.PDF

FINCEN DIRECTOR DESCRIBES IMPLEMENTATION EFFORTS FOR 2020 AML ACT

On 24 March, an article from Cadwalader Cabinet about an address to the Florida International Bankers Association AML Conference by FinCEN Director Kenneth Blanco, in which he outlined the bureau’s implementation efforts since the enactment of the 2020 Act.

https://www.findknowdo.com/news/03/23/2021/fincen-director-describes-implementation-efforts-2020-aml-act

REPORT: THE UK’S RELATIONSHIP WITH IRAN

On 24 March, the EU Sanctions blog said that the Parliamentary Foreign Affairs Committee has published a report: “No prosperity without justice: the UK’s relationship with Iran”.  It recommended that the UK work with the US to bring all parties back to compliance and should outline what a replacement to the JCPOA would look like, and prioritise sanctions designations under its human rights sanctions regimes for activities at home and abroad.

https://committees.parliament.uk/publications/3987/documents/40221/default/

EU COUNCIL ADOPTS NEW RULES TO STRENGTHEN ADMINISTRATIVE COOPERATION

On 24 March, Accountancy daily reported that the European Council has adopted new rules designed to improve administrative cooperation in the field of taxation and address the challenges posed by the digital platform economy.  The new rules cover digital platforms located both inside and outside the EU and will apply from 1 January 2023 onwards.

https://www.accountancydaily.co/cch_uk/tat/news_014011_rulesadcoop

https://www.consilium.europa.eu/en/press/press-releases/2021/03/22/taxation-council-adopts-new-rules-to-strengthen-administrative-cooperation-and-include-sales-through-digital-platforms/

SINGAPORE REGULATOR TO REVIEW COMMODITY TRADER’S RISK CONTROLS AFTER LOSSES

On 24 March, Global Trade review reported that Singapore’s financial regulator is conducting a review of Envysion Wealth Management’s governance and risk management, after the company lost millions of dollars to an alleged fraudulent nickel trading scheme.  This comes after fraud charges filed against Ng Yu Zhi, a director of Envy Asset Management and Envy Global Trading which is said to have involved the “purported trading of nickel”.  Ng’s companies raised around $750 million in total, police add, with investors promised returns of around 15%. Prosecutors accuse Ng of siphoning off hundreds of millions of dollars into his personal account, however, and a large proportion of investor funds remains unaccounted for.

https://www.gtreview.com/news/asia/singapore-regulator-to-review-envysion-risk-controls-after-losses/

LIBYA LETTER OF CREDIT SYSTEM ABUSED FOR “RAMPANT FRAUD”

On 24 February, Global Trade Review reported that the Libyan central bank’s letter of credit (LC) system may have been exploited for “fraud on a large scale”, researchers believe, after finding LC-based transaction volumes were far higher than actual imports.

https://www.gtreview.com/news/mena/libya-letter-of-credit-system-abused-for-rampant-fraud-report-claims/ 

WHY UK KEPT EXPORTING A DEADLY PESTICIDE THAT KILLS THOUSANDS

A report from Channel 4 TV in the UK on 24 March says that hundreds of secret documents and a whistleblower raise questions about whether manufacturer Syngenta put profit before people, in making and exporting weedkiller Gramoxone, with its active ingredient paraquat.  It is claimed that secret company documents suggest Syngenta had safer more expensive alternatives that it held back from consumers to protect its profits – which the company denies.

https://www.channel4.com/news/revealed-why-uk-kept-exporting-a-deadly-pesticide-that-kills-thousands

TEXAS MAN PLEADS GUILTY TO $24 MILLION COVID-RELIEF FRAUD SCHEME

A news release from US DoJ on 24 March advised that a Texas man, Dinesh Sah, 55, pleaded guilty to orchestrating a fraudulent scheme to obtain approximately $24.8 million in forgivable Paycheck Protection Program (PPP) loans and laundering the proceeds.  He admitted that he submitted fraudulent applications, filed under the names of various purported businesses that he owned or controlled, to 8 different lenders and claimed that these businesses had numerous employees and hundreds of thousands of dollars in payroll expenses when, in fact, no business had employees or paid wages consistent with the amounts claimed in the PPP applications.  He further admitted that he submitted fraudulent documentation in support of his applications, including fabricated federal tax filings and bank statements for the purported businesses, and falsely listed other persons as the authorized representatives of certain of these businesses without the authority to use their identifying information on the applications.

https://www.justice.gov/opa/pr/texas-man-pleads-guilty-24-million-covid-relief-fraud-scheme

SURINAME’S CORRUPTION AND MONEY LAUNDERING CHALLENGES

On 24 March, Global Americans reported on the release of Suriname’s National Risk Assessment of AML/CFT.  The NRA indicates that the country is still plagued by insufficient awareness of the phenomenon of money laundering, and thus will face major challenges in the future.  It is said that, adding to a sense of urgency, Suriname is poised to emerge as a major oil producer.  It is said that the NRA was conducted against the backdrop of a country that has increasingly become associated with corruption.  The NRA flagged many of the same problems as a 2017 UN Development program report, reflecting the extent of the dilemma facing the new government elected in May 2020.  Although the NRA indicates that Suriname has made some improvements with regards to combating money laundering and corruption, it also clearly stressed that considerable work remains to be done.  Suriname has the opportunity to benefit from its potential oil wealth, but corruption and money laundering must be controlled first. 

https://theglobalamericans.org/2021/03/surinames-corruption-and-money-laundering-challenges

https://www.waterkant.net/suriname/2021/03/13/resultaten-national-risk-assessment-nra-rapport-zorgelijk/

STEAMSHIP MUTUAL INSURER WARNS ON BANK TRANSFER FRAUDS

On 24 March, Insurance Maritime News reported that Steamship Mutual P+I Club has informed its members that it had recently become aware of a cyber security incident involving a broker’s systems that resulted in an attempt to induce a Steamship Mutual member to transfer funds to a bank account established for fraudulent purposes.  The attempt was supported by forged documentation using Steamship’s letterhead and an official signature purporting to authorise a third-party factor to receive funds on Steamship’s behalf.

https://insurancemarinenews.com/insurance-marine-news/steamship-warns-on-bank-transfer-frauds/

TECHNIQUE THAT IDENTIFIES EVERY BANKNOTE’S ‘UNIQUE AND UNCLONABLE’ FINGERPRINT TO CURB FORGERY

On 24 March, an article from Engineering & technology reported that researchers at the University of Warwick have developed a technique that identifies every banknote’s ‘unique and unclonable’ fingerprint, which could help prevent the increasing exchange of counterfeit banknotes.

https://eandt.theiet.org/content/articles/2021/03/fingerprint-technique-could-help-prevent-banknote-fraud/

CASHING IN ON GUNS: IDENTIFYING THE NEXUS BETWEEN SMALL ARMS, LIGHT WEAPONS AND TERRORIST FINANCING

Project CRAAFT (Collaboration, Research & Analysis Against the Financing of Terrorism) at RUSI and the International Centre for Counter-Terrorism – The Hague (ICCT) have published this new report which presents the main findings of a year-long research project on Small Arms and Light Weapons (SALW) as a source of terrorism financing. 2 chapters take a regional focus and explore this phenomenon in respectively West Africa and the Middle East.  A final chapter considers the various direct and indirect ways through which terrorists are ‘Cashing in on Guns’, and lists a number of policy recommendations for the EU to take a step forward in addressing this phenomenon.

https://icct.nl/publication/small-arms-light-weapons-terrorist-financing-report/

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