OTHER THINGS YOU MAY HAVE MISSED – MARCH 31

Panama Covid-19 update – from the 5 April, the current 2200-0400 curfew changes to 2300-0400. this is despite the ban on people from South America, due to the Brazilian variant threat, and concerns over its presence here.

Tomorrow, 1 April, the main transport routes, including the Bridge of the Americas over the North and South American divide, are made into one-way systems for all the people returning to the countryside to visit family for the Easter holidays…not necessarily a good idea in the pandemic?

Meanwhile, 447 new cases and 4 new fatalities reported today; with 5,033 active cases – 72 in ICU and 512 in other wards…so the virus hasn’t exactly gone away yet.

31 MARCH 2021

US SUPREME COURT LOOKS AT CONSEQUENCES OF FALSELY CALLING SOMEONE A TERRORIST

On 30 March, the Wall Street Journal reported a class-action lawsuit by some 8,000 consumers falsely labelled as potential terrorists on their credit reports.  It involves TransUnion LLC which in 2001 launched a product, OFAC Advisor, which it marketed to creditors faced with USA Patriot Act provisions prohibiting transactions with individuals listed by OFAC.  It follows several cases were people found themselves misidentified as terrorists.

https://www.wsj.com/articles/supreme-court-looks-at-consequences-of-falsely-calling-someone-a-terrorist-11617139228

RUSSIAN BUSINESSMAN OLEG VLADISLAVOVICH NIKITIN AND HIS COMPANY KS ENGINEERING (KSE) PLEADED GUILTY TO EVADING EXPORT CONTROL REGULATIONS

On 31 March, the EU Sanctions blog reported that Nikitin had admitted that he and a KSE employee conspired with an Italian company and its employees to procure and ship a US-origin power turbine on behalf of a Russian state-controlled company for use on an Arctic deep-water drilling platform.

https://www.europeansanctions.com/2021/03/russian-national-his-company-plead-guilty-to-violating-us-export-controls/

https://www.justice.gov/usao-sdga/pr/russian-national-and-engineering-company-admit-guilt-scheme-evade-us-national-security

US: ANTI-MONEY LAUNDERING ACT 2020 EXPANDS THE US GOVERNMENT’S AUTHORITY TO SUBPOENA RECORDS FROM FOREIGN BANKS WITH NO US BRANCHES

On 26 March, Law.com carried an article from Evershed Sutherland partners which says that this expansion has the potential to dramatically impact future white-collar investigations. This article provides insight into how the legislation could affect cross-border, white-collar investigations, how foreign banks can (or should) respond if they receive these subpoenas, and what affirmative measures foreign banks can take to prevent coming under scrutiny themselves.

https://www.law.com/newyorklawjournal/2021/03/26/prosecutors-new-weapon-in-cross-border-investigations

UGANDA’S REFORESTATION PLAN CUTS ILLEGAL LOGGING

On 2 March, ENACT Africa reported that 80% of Uganda’s timber trade is illegal and the illegal timber from Uganda – mostly logs and plywood and other panels – is smuggled to Kenya and Rwanda. Yet there are innovative, long-term efforts that are showing that coordinated prevention at source is a key element to effective responses.

https://enactafrica.org/enact-observer/ugandas-reforestation-plan-cuts-illegal-logging

UK: EX-SERCO DIRECTORS ALLEGEDLY HID MILLIONS FROM GOVERNMENT

On 31 March, KYC 360 reported that 2 former Serco group Plc directors concealed £12 million in profits from an electronic-tagging contract from the MoJ, ultimately defrauding both the government and taxpayers, prosecutors have told a London court.  The company allegedly reduced an apparent profit of around £27 million to roughly £15 million in the financial models given to the Ministry.

https://www.riskscreen.com/kyc360/news/ex-serco-directors-hid-millions-from-government-prosecutors-say/

https://www.lawgazette.co.uk/news/ex-directors-in-dock-as-serco-tagging-fraud-trial-opens/5107997.article

AUSTRALIA: AUSTRAC PUBLISHES REGULATORY GUIDES ON STRENGTHEN AML CONTROLS

On 31 March, Regulation Asia reported that the various guides cover governance, risk assessments, CDD, IFTI reporting, and correspondent banking relationships.  A set of new guidance resources including a video animation, fact sheet and FAQ on how to submit more effective SMR (suspicious matter reports) is also available.

https://www.regulationasia.com/austrac-publishes-regulatory-guides-on-strengthen-aml-controls/

https://www.austrac.gov.au/business/how-comply-guidance-and-resources/reporting/suspicious-matter-reports-smr

GERMAN COURT UPHOLDS CONVICTION OVER ILLEGAL ARMS EXPORTS TO MEXICO

On 30 March, Courthouse News reported that Germany’s highest court has upheld a ruling fining gunmaker Heckler & Koch millions of dollars and handing suspended jail terms to 2 of its former employees for illegally exporting rifles to violence-torn Mexican states.  Heckler & Koch had exported military-style weapons including 4,219 assault rifles and 1,759 magazines of ammunition to Mexico between 2005 and 2007.  While the deliveries had been approved by German export authorities, they were held to be illegal because the weapons ended up in especially violence-torn Mexican states in breach of the export licence

https://www.courthousenews.com/german-court-upholds-conviction-over-illegal-arms-exports/

KYRGYZSTAN: SMUGGLING OF 2 TONS OF LEMONS FOILED

On 31 March, AKI Press reported that the lemons and 54,000 eggs had been detected being imported from a neighbouring country.

https://akipress.com/news:656261:Smuggling_of_2_tons_of_lemons_foiled_in_Batken/

INDONESIA: SNIFFER DOGS TO DETECT SMUGGLED WILDLIFE

On 30 March, Arab News reported that the training of new sniffer dogs follows the success of Bailey, Indonesia’s first wildlife detection dog, who was first deployed by authorities in 2018.  This is giving rescue dogs a chance of a new career path by detecting and tracking smuggled wildlife. 

https://www.arabnews.com/node/1834116/world

HUNGARIAN AUTHORITIES BREAK UP €8 MILLION MTIC VAT FRAUD SCHEME

On 31 March, a news release from Europol advised that the Hungarian National Tax and Customs Administration (NTCA) has dismantled an organised criminal group (OCG) suspected of facilitating VAT fraud and money laundering using “missing traders”.  The criminal activities caused more than €8.2 million in tax loss to the Hungarian state budget.  The ‘missing traders’ were commissioned to perform services, which they did not have the necessary means to perform. The companies were found to have no employees, equipment or premises.

https://www.europol.europa.eu/newsroom/news/hungarian-authorities-break-€8-million-vat-fraud-scheme

WHAT MEASURES SHOULD BE TAKEN AGAINST THE TRADE IN GOODS USED FOR THE PURPOSE OF EXECUTION OR TORTURE?

On 30 March, the Council of Europe advised that the Coucnil had adopted a new Recommendation inviting Member States to take measures against the trade in goods used for the death penalty, torture and other cruel, inhuman or degrading treatment or punishment.  It is said to be  deeply concerned by the fact that certain equipment and goods whose only practical use is for torture.

https://www.coe.int/en/web/portal/-/what-measures-should-be-taken-against-the-trade-in-goods-used-for-the-purpose-of-execution-or-torture-

https://search.coe.int/cm/pages/result_details.aspx?objectid=0900001680a1f4e5

MEMBERS OF DRUG TRAFFICKING NETWORK ARRESTED FOR MONEY LAUNDERING IN GERMANY AND LUXEMBOURG

On 31 March, a news release from Europol advised that, at the request of France, authorities in Germany and Luxembourg carried out a coordinated blow on the network which was set up to launder proceeds from drug trafficking.   Authorities in Germany and Luxembourg have arrested four members of a criminal group suspected of laundering the proceeds from drug trafficking.

https://www.europol.europa.eu/newsroom/news/follow-money-members-of-drug-trafficking-network-arrested-for-money-laundering-in-germany-and-luxembourg

EU SPECIAL REPORT – CUSTOMS CONTROLS: POOR HARMONISATION HAMPERS EU FINANCIAL INTERESTS

The European Court of Auditors has advised that Special Report 04/2021 (Customs controls: poor harmonisation hampers EU financial interests) was published on 30 March.  It says that within the EU Customs Union, uniform application of customs controls by Member States is necessary to prevent fraudulent importers from targeting border entry points with a lower level of controls.  The Union Customs Code (UCC) requires the Commission to take the necessary action to ensure Member States apply customs controls uniformly.  The report says that the existing framework is not designed well enough to ensure that Member States select controls in a harmonised way. In addition, Member States implement the relevant decision and guidance in different ways.

https://www.eca.europa.eu/Lists/ECADocuments/SR21_04/SR_Customs_controls_EN.pdf

UNITED KINGDOM DRUG SITUATION

On 31 March, a news release from the Home Office about the annual report and data tables from the UK Focal Point on Drugs on the national prevalence, impact, prevention and treatment of drug use.  The 2019 report can be found alongside reports for 2016 and 2017.

https://www.gov.uk/government/publications/united-kingdom-drug-situation-focal-point-annual-report

TENS OF THOUSANDS FEARED DISPLACED IN DEADLY ATTACK ON MOZAMBIQUE GAS TOWN

On 31 March, Defence Web published a short report about the deadly attack by Islamic State-linked insurgents on a gas hub town of Palma in northern Mozambique. 

https://www.defenceweb.co.za/security/human-security/tens-of-thousands-feared-displaced-in-deadly-attack-on-mozambique-gas-town/ 

MOZAMBIQUE NEEDS GAINS IN SECURITY AND CORRUPTION IN NORTH TO DEVELOP LNG

https://www.theafricareport.com/76448/mozambique-needs-gains-in-security-and-corruption-in-north-to-develop-lng

“IRAN-TIED CUSTOMS-EVASION CARTEL RULES IRAQ BORDERS”

An article in the Times of Israel on 31 March claimed that many of Iraq’s entry points are informally controlled by groups within the Hashed al-Shaabi, a powerful state-sponsored armed network close to Tehran, and thisis diverting billions of dollars away from state coffers to line the pockets of armed groups, political parties and crooked officials.

https://www.timesofisrael.com/a-real-mafia-iran-linked-customs-evasion-cartel-rules-iraqs-borders

MORE GERMAN POLITICIANS RESIGN OVER FACE MASKS BRIBERY SCANDAL

On 31 March, OCCRP reported that another German politician joined the list of suspects in a corruption scandal involving the procurement of COVID-19 face masks that has rocked the country’s conservatives and prompted the Bundestag to introduce a lobby register.

https://www.occrp.org/en/daily/14134-more-german-politicians-resign-over-face-masks-bribery-scandal

SERBIA: QUESTIONS ABOUT THE RELATIONSHIP BETWEEN A SERBIAN BUSINESSMAN WHO EARNED MILLIONS FROM SELLING LAND AROUND BELGRADE’S AIRPORT, AND A PORTUGUESE EX-MINISTER WHOSE LAW FIRM ADVISED ON THE AIRPORT DEAL

On 31 March, OCCRP carried a report saying that on winning the concession to expand Belgrade’s airport, a French construction company bought nearby land from a controversial Serbian businessman for €47 million — over 4 times more than projected by an internal government assessment.  The businessman then became business partners in a newly-founded real estate company with a former Portuguese government minister whose law firm had advised the Serbian government on the airport deal.

https://www.occrp.org/en/openlux/businessman-nets-47m-for-belgrade-airport-land-then-partners-with-lawyer-whose-firm-advised-on-deal

COMBATING MARITIME CRIME IN COMOROS

On 31 March, a report from the UN Office on Drugs & Crime says that the Comoros is strategically situated within the Indian Ocean’s Mozambican channel, nestled between Madagascar and Mozambique. Recent data sourced by UNODC reveals that the amounts of heroin seized along the Indian Ocean trafficking route have more than doubled over 2018 and 2019, and that wildlife trafficking has also seen a boon due to widespread poverty in the region. 

https://www.unodc.org/unodc/frontpage/2021/March/combating-maritime-crime-in-comoros.html

BELGIUM: CUSTOMS OFFICERS TO GO ON STRIKE IF GOVERNMENT DOES NOT IMPROVE WORKING CONDITIONS

On 30 March, the Brussels Times reported that Customs officers in Belgium, including those at airports, will be going on strike in the coming days if the federal government does not commit to improving their working conditions, the public sector trade union ACOD said.  The union is demanding additional recruitment, priority for coronavirus vaccination for the frontline staff who work alongside police, and consideration of the difficult and strenuous nature of the profession for pension purposes.

https://www.brusselstimes.com/news/belgium-all-news/162509/customs-officers-to-go-on-strike-if-government-does-not-improve-working-conditions-airport-federal-protest-coronavirus-vaccination-understaffed-pension-brexit-borders/

US: CUSTOMS OFFICERS DISCOVER 29 FINCHES HIDDEN IN MAN’S LUGGAGE AT JFK AIRPORT

On 30 March, ABC7 in New York reported that US Customs and Border Protection officers found 29 finches concealed in hair rollers, inside the bags of a man arriving from Guyana.  The 26-year-old man who was headed to an address in New Jersey, was not criminally charged, however he was fined $300 and put on a return flight to Guyana.

https://abc7ny.com/jfk-airport-finches-bird-discovery-us-customs/10460723/

LATIN AMERICA ELITES SEEK CORRUPT ACCESS TO VACCINES

On 30 March, an article from Insight Crime reported that the seizure in Mexico of COVID-19 vaccine smuggled aboard a private plane linked to a Honduran textile magnate marks the first instance of alleged transnational vaccine smuggling in Latin America.  It says that the case, which is still unravelling, suggests a foiled backroom deal for privileged access to the COVID-19 vaccine – a scheme playing out across Latin America as elites leverage their power to skip waiting lines.  Another example cited is inn Peru, where an investigation dubbed “Vaccine-gate” uncovered at least 487 people who had received priority access to vaccines in late 2020. 

https://insightcrime.org/news/elites-smuggle-vaccines-latin-america/

ILLEGAL, UNREPORTED AND UNREGULATED (IUU) FISHING

On 31 March, the EU Parliament Research Service published a briefing paper about IUU fishing and the EU Regulation designed to combat it.  The European Commission identifies non-EU countries that fail to discharge their duties under international law to take action against IUU fishing, and initiates dialogue with each of them (i.e. with more than 50 countries to date). In most cases, the bilateral discussions result in the countries in question improving the governance of their fisheries.

https://www.europarl.europa.eu/RegData/etudes/ATAG/2017/614599/EPRS_ATA(2017)614599_EN.pdf

PROCEEDINGS OF THE WORKSHOP ON USE OF BIG DATA AND AI IN FIGHTING CORRUPTION AND MISUSE OF PUBLIC FUNDS

On 31 March, the EU Parliament Research Service published a paper on good practice, ways forward and how to integrate new technology into contemporary control frameworks. 

https://www.europarl.europa.eu/RegData/etudes/STUD/2021/691722/IPOL_STU(2021)691722_EN.pdf

WHAT IS THE EU DOING TO COMBAT CYBERCRIME?

On 25 March, the EU Parliament Research Service published an article in its Ask EP series summarising the current position and links to further information.

https://epthinktank.eu/2021/03/25/what-is-the-eu-doing-to-combat-cybercrime-2/

FRENCH GDPR RULING ADDRESSES US SURVEILLANCE POWERS

On 31 March, an article in Out-Law reported on a new summary ruling by the Conseil d’État, the French Council of State.  It says that organisations can deploy legal and technical safeguards to meet their obligations under EU data protection law when seeking to prevent US authorities from accessing personal data stored with their outsourcing providers.  The case involved a legal challenge concerning the data-hosting arrangements relating to the French vaccination programme for Covid-19.  The court confirmed that personal data processing operations subject to the US surveillance framework can comply with the GDPR.

https://www.pinsentmasons.com/out-law/news/french-gdpr-ruling-addresses-us-surveillance-powers

AFTER OIL GIANT SHELL HIT BY CLOP RANSOMWARE GANG, WORKERS’ VISAS DUMPED ONLINE AS PART OF EXTORTION ATTEMPT

On 29 March, The Register reported that Royal Dutch Shell is the latest corporation to be attacked by the Clop ransomware gang.  Hackers siphoned sensitive documents from a software system used by the oil giant, and have now leaked online some of the data – notably a selection of workers’ passport and visa scans – to encourage the corporation to pay a ransom.

https://www.theregister.com/2021/03/29/shell_clop_ransomware_leaks_update/

KNOW YOUR TRANSACTION: KYT TO BOOST KYC?

A paper from Deloitte says that the current approach to KYC and transaction screening is to look for matches and return hits.  This approach, it says, is not satisfactory anymore, as it generates a lot of waste in the form of repetitive alerts and high operational costs.  It says that computing power and nearly infinite storage available in the cloud can unlock 2 important capabilities – the screening/profiling of all transactions; and creating profiles in real-time.

https://insidenow.deloitte.lu/kyt-to-boost-kyc/article/

US: FORMER HONDURAN CONGRESSMAN TONY HERNÁNDEZ SENTENCED TO LIFE IN PRISON AND ORDERED TO FORFEIT $138.5 MILLION FOR DISTRIBUTING 185 TONS OF COCAINE AND RELATED FIREARMS AND FALSE STATEMENTS OFFENCES

and

“THE DOJ GOES FOR THE HONDURAN PRESIDENT”

A news release from the US DoJ on 30 March advised that JUAN ANTONIO HERNÁNDEZ ALVARADO, a former Honduran congressman and the brother of Juan Orlando Hernández, the current president of Honduras, who was convicted on October 2019, has been sentenced to life and ordered to forfeit $138.5 million.

https://www.justice.gov/usao-sdny/pr/former-honduran-congressman-tony-hern-ndez-sentenced-life-prison-and-ordered-forfeit

Meanwhile, Corporate Compliance Insights reported claims that Juan Orlando Hernandez, the President of Honduras, “played a leadership role in a violent, state sponsored drug trafficking conspiracy”.  It is said that, with the help of the President, the sentenced man controlled cocaine laboratories in Colombia and Honduras, bribed politicians and helped cause at least 2 murders. 

https://www.corporatecomplianceinsights.com/doj-goes-for-the-honduran-presidents-jugular-in-sentencing-of-tony-hernandez/

BELGIUM: FORMER FEDERAL POLICE CHIEF COULD FACE CHARGES OF BRIBERY AND MONEY LAUNDERING

On 31 March, The Bulletin reported that the public prosecutor has asked that Glenn Audenaert, 65, the former director of the federal police, be brought up on charges of accepting bribes, money laundering, breach of confidentiality and forgery. Audenaert was the police commissioner for about 12 years, until he resigned in 2012.  He has been under investigation for years, suspected of accepting bribes from a Dutch real estate magnate.

https://www.thebulletin.be/former-federal-police-chief-could-face-charges-bribery-and-money-laundering

ICC COMPENDIUM OF ANTI-TRUST DAMAGES ACTIONS

On 31 March, the International Chamber of Commerce announced that the ICC Compendium of Antirust Damages Actions provides a comprehensive overview of the complexities and intricacies associated with antitrust litigation across a wide range of key jurisdictions including Brazil, China, France, Germany, and UK.  It is said to be broken down into separate country reports to allow users to select the jurisdictions, court proceedings, and/or decisions of interest to them.

https://iccwbo.org/publication/icc-compendium-of-antitrust-damages-actions

UNDERSTANDING RULES OF ORIGIN

On 31 March, an article from Gowling WLG says that a key aspect of a free trade agreement (FTA) is the ability for businesses to benefit from “preferential tariff treatment” (i.e. reduced or zero tariffs and quotas) in respect of trade in goods – for example, between the UK and countries with which the UK has concluded an FTA. This is, however, only available to businesses which can demonstrate that their goods satisfy the “Rules of Origin” set out within the applicable FTA.  The article sets out an overview of the common Rules of Origin, as well as the key considerations for businesses in complying with these rules.

https://gowlingwlg.com/en/insights-resources/articles/2021/tariff-free-trade-understanding-rules-of-origin

EGYPT: TRANSPARENCY INTERNATIONAL WANTS TO REOPEN CASE INTO MUBARAK ASSETS

On 31 March, Africa Reports said that although the European Council decided to unfreeze the assets of the Egypt’s former President Hosni Mubarak’s family on 12 March, the NGO Transparency International is pushing to reopen the case.  Transparency International France, a civil party in to French court case, wants to reopen the investigation.  The value of the assets located in Europe is difficult to estimate. Only Spain had made public the freezing of nearly €28 million, 7 properties and 5 luxury cars in 2011.  As early as 2012, the BBC had established the presence of nearly 10 companies that remained active in London, only a year after the freeze was introduced in the UK. 

https://www.theafricareport.com/76675/egypt-transparency-international-wants-to-reopen-case-into-mubarak-assets

WORLD BANK BLACKLISTS SCOTTISH FIRM FOR FRAUD

On 31 March, OCCRP reported that the World Bank has blacklisted an anonymously-owned Scottish company – NovoLine Resources, a limited partnership registered in Edinburgh – for engaging in “fraudulent practices” to win deals under an emergency medical aid programme in Uzbekistan. 

https://www.occrp.org/en/daily/14138-world-bank-blacklists-scottish-firm-for-fraud

FCA NOW REQUIRES FINANCIAL CRIME REPORTS FROM CRYPTO FIRMS

On 31 March, Inside Bitcoins reported that the UK FCA new policy requires all cryptocurrency firms to submit financial crime reports.  The regulator increased the number of businesses required to submit an annual financial crime report known as “REP-CRIM” from 2,500 to about 7,000.

https://insidebitcoins.com/news/fca-now-requires-financial-crime-reports-from-crypto-firms

UK: CPS LAUNCHES AMBITIOUS PLAN TO COMBAT ECONOMIC CRIME

On 31 March, Police professional reported that the Crown Prosecution Service (CPS) has launched an ambitious economic crime strategy to combat the “corrosive threat” that saw scam victims lose almost £480 million last year.  The CPS has said that 86% of reported fraud is now estimated to be cyber-enabled, fuelled by advances in technology.  The CPS also has a unit dedicated to asset recovery and in 2019/20 more than £100 million has been taken from criminals’ ill-gotten gains.

https://www.policeprofessional.com/news/cps-launches-ambitious-plan-to-combat-economic-crime/

ISRAELI PLEADS GUILTY IN GLOBAL PROBE INTO MULTI-MILLION DARK NET SITE

On 31 March, Haaretz reported that an Israeli national living in Brazil – Tal Prihar, 37, who co-owned DeepDotWeb (DDW) – has pleaded guilty in the US for his role in a money laundering conspiracy through his ownership and management of the illicit website, which allowed internet users to access a wide range of contraband in dark net marketplaces

https://www.haaretz.com/israel-news/israeli-pleads-guilty-in-global-probe-into-multi-million-dark-net-site-1.9672019

PERU PRESIDENTIAL CANDIDATE DENIES TAX AND LAUNDERING ALLEGATIONS

On 31 March, BNN Bloomberg reported that Rafael Lopez Aliaga, a hotelier and businessman, and one of the conservative front-runners in Peru’s presidential election denied press reports that he allegedly owes millions in back taxes and is under investigation for money laundering, hours before he was scheduled to appear in an election debate.

https://www.bnnbloomberg.ca/peru-conservative-candidate-denies-tax-laundering-allegations-1.1585008

5 RANSOMWARE THEMES KEEPING DIRECTORS UP AT NIGHT

An article from BDO in the US published an article detailing the top 5 takeaways from our recent discussions with directors and subject matter experts – increased risk; continuous preparation is a board’s best defence; managing cybersecurity requires a layered, risk-based approach; timing is everything – immediate action is critical in responding to ransomware attacks; and fighting cyber-crime takes a village.

https://www.bdo.com/insights/assurance/corporate-governance/five-ransomware-themes-keeping-directors-up-at-nig

ETHIOPIA’S TIGRAY CONFLICT: ALLEGED ATROCITIES, LAW OF WAR VIOLATIONS AND REGIONAL IMPLICATIONS

On 31 March, an article on Lawfare was concerned with the conflict between the Tigray People’s Liberation Front (TPLF) and the Ethiopian National Defense Force (EDNF), and the effects.  It is said that the Tigray conflict constitutes an international civil war that has spawned a humanitarian crisis and risks destabilising the broader region.  It is said that the conflict is evolving steadily into a low-level insurgency. With TPLF leadership ensconced in the mountains and strong popular support, the conflict could endure for some time.  The TPLF will not admit defeat, the government refuses to negotiate and alleged atrocities harden hearts on all sides. Peace does not appear imminent.  The conflict has engendered an acute humanitarian crisis, and indiscriminate violence aggravates these challenges. The region’s crops already suffered from locust swarms in 2020, and fighting now impedes the delivery of food aid.  Food security and refugee flows are not the only ways the Tigray conflict affects the broader region, and the article warns that if the Tigray conflict transforms into a long-running insurgency, Ethiopia could become a source of instability for neighbouring states.

https://www.lawfareblog.com/ethiopias-tigray-conflict-alleged-atrocities-law-war-violations-and-regional-implications

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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