OTHER THINGS YOU MAY HAVE MISSED – APRIL 15

Panama Covid-19 update – good news for the Government, in that the Supreme Court has ruled that pandemic curfew is not unconstitutional.

For myself, after many months delay, my personal effects arrived. Interestingly, the nice team who delivered them had all been tested after one of their colleagues had died of Covid. It brings it home when you meet someone directly affected.

Meanwhile, another 4 fatalities today, and 314 new cases reported. 3,929 active cases include 57 in ICU and 389 in other wards.

15 APRIL 2021

FORMER MEXICAN SENATOR HIT WITH CRIMINAL CHARGES TIED TO ENERGY REFORM

On 13 April, Reuters reported that Mexican prosecutors have filed criminal charges against Jorge Lavalle, a former senator who under the previous government helped to pass a major energy reform which has been attacked as tainted by corruption.

https://www.reuters.com/article/us-mexico-corruption/former-mexican-senator-hit-with-criminal-charges-tied-to-energy-reform-idUSKBN2C033O

HONG KONG: 16 ARRESTED IN POLICE SWOOP ON BOOKMAKING SYNDICATE THAT LAUNDERED MONEY FOR 10 MONTHS

On 13 April, the South China Morning Post reported that the group include 3 from triad backgrounds and it used help of overseas website that offered gambling games and used online banking to avoid detection.  The group is said to have laundered US$23 million in criminal proceeds over 10 months.

https://www.scmp.com/news/hong-kong/law-and-crime/article/3129396/sixteen-hongkongers-arrested-police-swoop-bookmaking

2 AUSTRALIAN BANKS PULLED BANKING SERVICES FROM FINTECH UNICORN AIRWALLEX OVER AML RISK FEARS

On 13 April, the Sydney Morning Herald reported that hyped Australian international payments ‘unicorn’ Airwallex has defended its approach to compliance amid revelations it was denied key banking services by 2 major lenders due to concerns about its adherence to AML laws.  National Australia Bank cancelled transactional banking services for Airwallex’s customers in 2018 and it was later denied services by global banking giant Citigroup.

https://www.smh.com.au/business/banking-and-finance/denied-nab-citi-pulled-banking-services-from-fintech-unicorn-airwallex-over-risk-fears-20210413-p57iv9.html

PHILIPPINES TIGHTENS KNOW-YOUR-EMPLOYEE RULES FOR BANKS

KYC 360 reported on 15 April that the Philippine central bank has approved rules that will strengthen banks’ know-your-employee procedures as financial frauds surge during the pandemic.  There must be adequate understanding of a candidate’s background and character, conflict of interest and “propensity to commit fraud or irregularity”.

https://www.riskscreen.com/kyc360/news/philippines-tightens-know-your-employee-rules-for-banks

2 CHARGED IN SUSPECT $1 BILLION TRANSFER USING NEW YORK CREDIT UNION

On 15 April, KYC 360 reported that 2 people were charged with using a New York state employees credit union to process more than $1 billion in suspect financial transactions while failing to file SAR or maintain adequate AML controls.  It is alleged that the defendants “devised a scheme to bring lucrative and high-risk, international financial business lines to small, unsophisticated financial institutions”.  It is said that the transactions involved had red flags that should have prompted them to report the transactions to US authorities and demand more information about them.

https://www.riskscreen.com/kyc360/news/two-charged-in-suspect-1-billion-transfer-using-n-y-credit-union

FORMER ZIMBABWE CRICKET CAPTAIN BANNED OVER BETTING CORRUPTION

On 13 April, iGB reported that the International Cricket Council (ICC) has handed an 8-year ban to former Zimbabwe captain and coach Heath Streak after ruling that he breached its anti-corruption regulations.

https://igamingbusiness.com/former-zimbabwe-cricket-captain-banned-over-betting-corruption

5 ARRESTS IN SWEDISH TENNIS MATCH-FIXING INVESTIGATION

On 14 April, iGB reported that Swedish Police have arrested of 5 people in Stockholm in connection to a tennis match-fixing investigation.  The alleged match-fixing is said to involve substantial sums of money, though the amount was not revealed.

https://igamingbusiness.com/five-arrests-in-swedish-tennis-match-fixing-investigation/

UK PUBLISHES NEW GUIDANCE ON TECHNOLOGY EXPORTS – 5 KEY TAKEAWAYS FOR COMPANIES USING THE CLOUD

On 13 April, Baker Mckenzie published an article saying that the UK Export Control Joint Unit has published revised guidance on exporting military or dual-use technology. This clarifies a number of common queries regarding technology exports, particularly around the use of cloud storage and remote data infrastructure through which information could be routed.  The guidance also addresses the application of the special arrangements in Northern Ireland under the EU-UK Withdrawal Agreement.  The guidance affirms the position on how key definitions and concepts in UK export control laws will be interpreted in relation to technology exports.  The article provides its 5 key takeaways for companies using the cloud and remote infrastructure to store and share export-controlled technology:

https://sanctionsnews.bakermckenzie.com/uk-publishes-new-guidance-on-technology-exports-5-key-takeaways-for-companies-using-the-cloud/#page=1

ANTI-CORRUPTION IN LATIN AMERICA

On 9 December, Latin Lawyer published a report which considers some of the background diversity in anti-corruption risks that companies confront across the region.  It then explores some of the most important recent trends in anti-corruption enforcement in the region, including standardisation in anti-corruption legislation and the increase of coordinated enforcement actions and resolutions.  Finally,  it focuses on important ways to mitigate the challenges of navigating and avoiding a cross-border corruption crisis: whether by effectively gathering and sharing information when a problem arises, or by ensuring that compliance programmes are effectively designed and implemented with certain key elements.

https://latinlawyer.com/guide/the-guide-corporate-crisis-management/third-edition/article/anti-corruption-in-latin-america

IRELAND: MLD5 TRANSPOSITION AND AML HORIZON-SCANNING

On14 April, Irish law firm A & L Goodbody published an article as a Q&A on the implementation of the EU 5th AML Directive in Ireland, as well as clarification on the scope of the framework for the beneficial ownership of express trusts and other AML news, including elements of the EU AML Action Plan.

https://www.arthurcox.com/wp-content/uploads/2021/04/MLD5-Apr-2021.pdf

MALTA: BNF BANK DISTANCES ITSELF FROM FORMER MANAGER FACING MONEY LAUNDERING CHARGES

On 15 April, the Times of Malta reported that the BNF Bank has distanced itself from a former manager Albert Buttigieg, who faces money laundering charges.  He and ex-footballer Darren Debono’s step-daughter Florinda Sultana, are facing money laundering charges.  The latter fronted companies that manage 2 fish restaurants allegedly involved in laundering money linked to oil smuggling. 

https://timesofmalta.com/articles/view/bnf-bank-distances-itself-from-former-manager-facing-money-laundering.864777

DIGITAL ID PERCEIVED AS BENEFICIAL IN COMBATTING FINANCIAL CRIME

On 15 April, regulations Asia reported that digital ID are perceived as beneficial for the fight against financial crime, an ACAMS-RUSI survey finds. However they may also present risks.  Some 86% of 300 participants surveyed view Digital ID as a positive innovation, though respondents remained split on whether they face legal barriers to its widespread use.  85% of respondents say that Digital ID would most benefit customer onboarding.  In the context of financial crime, 62% of participants cited the provision of consistent customer ID data as the most important advantage conferred by Digital ID, while 57% indicated that it would enhance the ability of institutions to identify red flags and typologies of illicit finance.  However, the survey highlighted that use of digital ID may also present risks to users and to the institutions that accept them.  The greatest risks of Digital IDs are perceived to come from data breaches (69%), the exploitation of the vulnerable (67%), identity theft (58%), increased cybercrime (57%), and increased fraud (43%) – but respondents felt that paper-based ID are still more vulnerable than Digital ID.

https://www.regulationasia.com/digital-id-perceived-as-beneficial-in-combatting-financial-crime/.

The survey can be accessed at –

https://www.acams.org/en/media/document/18401

COUNCIL OF EUROPE URGES STATES TO PREVENT CORRUPTION RISKS WHEN TACKLING THE COVID-19 PANDEMIC’S ECONOMIC IMPACT

On 15 April, Council of Europe body GRECO said that governments should rigorously manage the corruption risks that have emerged due to the need to take extraordinary measures to combat the COVID-19 pandemic, including the infusion of large amounts of money into the economy to alleviate its economic and social impact.  It says that risks may be particularly pronounced in respect of public procurement systems when it comes to issues such as conflicts of interest and the role of lobbying.

https://search.coe.int/directorate_of_communications/Pages/result_details.aspx?ObjectId=0900001680a2260f

UK: LAW SOCIETY WARNS THAT OVERSEAS INVESTMENT CURBS COULD HIT LEGITIMATE BUSINESS

On 15 April, the Law Society Gazette reported that the Law Society for England & Wales has said that the well-intentioned bid to tackle foreign investments that present a security risk to the UK could hit legitimate international business at a time when the economy can least afford it.

https://www.lawgazette.co.uk/law/overseas-investment-curbs-could-hit-legitimate-business-law-society-warns/5108131.article

WHY THE DEFENCE INTEGRATED REVIEW MATTERS FOR THE UK’S DOMESTIC RESPONSE TO ECONOMIC CRIME

A Commentary from RUSI on 14 April says that the Integrated Review offers an opportunity to reposition economic crime as a ‘whole of system’ responsibility rather than a domestic one, and a hope that the Government may have grasped the importance of tackling the UK’s problem with dirty money.  It says that the reference to issues such as fraud against UK citizens and UK corporate registry reform within national security policy seemed inconceivable even just a few months ago.  It is argued that policymakers will be required to take the good ideas scattered throughout the Integrated Review’s ‘Strategic Framework’ and grow them for the future. The Integrated Review could provide useful leverage in the internecine battleground of the next spending round negotiations. In short, it is time for UK economic crime policy to move up a league.

https://rusi.org/commentary/keep-home-fires-burning-why-integrated-review-matters-uks-domestic-response-economic

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

CORRUPTION PLAGUES LITHUANIA’S PRISON LABOUR SYSTEM 

On 15 April, LRT reported that a state-owned company manufacturing goods by employing prison labour stands at the centre of a complicated alleged corruption scheme, linking to a former justice minister as well as senior officials in the country’s prison system.  In January, the Lithuanian Prison Department’s Criminal Intelligence Unit announced a pre-trial investigation into influence peddling and embezzlement at the state-owned company Mūsų Amatai.  Scandals have been plaguing the company for several years. Amatai is a state-owned company and employs prison labour to manufacture various goods, mostly furniture used in schools.

https://www.lrt.lt/en/news-in-english/19/1387482/corruption-plagues-lithuania-s-prison-labour-system-lrt-investigation

OECD AND AFRICAN DEVELOPMENT BANK TO TACKLE CORRUPTION, BRIBERY IN NIGERIAN BUSINESSES

On 15 April, the People’s Gazette reported that the OECD and the African Development Bank have increased efforts in tackling corruption and bribery among businesses in Nigeria and other African countries.  It is mentioned that the only African country that has ratified the OECD Anti-Bribery Convention is South Africa. 

https://gazettengr.com/oecd-afdb-to-tackle-corruption-bribery-in-nigerian-businesses 

US WARNS OF PUNITIVE ACTIONS FOR LEBANESE BLOCKING CORRUPTION REFORMS

On 15 April, Naharnet reported that A senior US official has warned that Lebanese politicians who continue to block reforms in the crisis-hit country could face punitive actions.  It is thought that the US and its allies may impose sanctions on Lebanese politicians in order to force them to end a months-long political deadlock and start badly needed reforms to fight corruption.

https://www.naharnet.com/stories/en/280918-u-s-warns-of-punitive-actions-for-lebanese-blocking-reforms

OFFICIALS SAY CROATIAN PORT APPEARS TO BE NEW ENTRY POINT FOR DRUGS

On 15 April, OCCRP reported that Croatian police confiscated nearly 600 kg of cocaine concealed in a shipment of bananas that arrived from South America to the Adriatic port of Ploče, saying that organised crime seems to be looking for alternative routes in the south of the continent.  The port of Ploče seems to be attractive to drug smugglers, as it is not equipped with special x-ray monitors for containers, so illegal goods can only be detected by random inspections or sniffing dogs.  3 serious drug seizures were conducted in the port since the beginning of this year, according to Croatian customs officials.

https://www.occrp.org/en/daily/14234-officials-say-croatian-port-appears-to-be-new-entry-point-for-drugs

CHINESE CUSTOMS BEEF UP CRACKDOWN ON SMUGGLING OF ALIEN SPECIES UNDER NEW BIOSECURITY LAW

On 15 April, Global Times reported that customs authorities have strengthened checks on international travellers, transportations, containers, cargos and articles, packages and ballast water discharges from ships on international voyages in and out of the country.  Customs authorities across the country were already engaged in a campaign called Green Gate Shield 2021.  The new law has 8 provisions to manage and supervise biosecurity threats like major emerging infectious diseases, epidemics and sudden outbreaks, and biotechnology research, development and application.

https://www.globaltimes.cn/page/202104/1221133.shtml

FENTANYL SEIZURES EXPLODE ACROSS THE US

On 15 April, Insight Crime reported that seizures of the synthetic opioid fentanyl by customs agents in the US have skyrocketed with over 2.5 tons seized nationwide between October 2020 and March 2021, representing a 322% increase year-on-year.  It says that heroin has increasingly been displaced by fentanyl, with customs having seized just under 1.2 tons of heroin during the last 6 months, less than half the amount of captured fentanyl.

https://insightcrime.org/news/fentanyl-seizures-explode-united-states/

UK: PROFESSION HAS STRUGGLED WITH AML RULES, SAYS LAW FIRM FINED £10,000

On 15 April, Legal Futures reported that a Surrey law firm has been fined £10,000 for breaches of the AML rules, but that it argued that a “significant proportion” of law firms had “struggled to achieve compliance” with the 2017 Money Laundering Regulations.  Regulator the SRA described the firm’s level of culpability as “moderately high” because the failures on risk assessment and training “continued over a prolonged period”, despite the specific transaction that triggered the action only yielding £850 in fees.

https://www.legalfutures.co.uk/latest-news/profession-has-struggled-with-aml-rules-says-firm-fined-10000

THE UK-US EXTRADITION TREATY IN THE SPOTLIGHT

A blog post from law firm Corker Bining on 14 April considering the case of Mike Lynch, facing extradition from the UK to the US for alleged fraud leading to huge losses by US computer company, Hewlett Packard.  It is said that logic dictates that if there is to be a trial of Mr Lynch, it should be in the UK. Indeed, it is pointed out, Hewlett Packard, chose to bring civil fraud proceedings in London, in what is reportedly the UK’s largest ever civil trial – judgment in that case has yet to be handed down. It makes the point that it would seem perverse if Hewlett Packard were unable to prove on a balance of probabilities in the High Court in London that fraud had been committed and yet at the same time extradition courts in London allowed the US DoJ to continue to pursue the case before a US criminal court on substantially the same facts (where they would have to persuade a jury beyond reasonable doubt).  On the extradition issue, Lynch is unable to challenge it on the basis that there is insufficient evidence to demonstrate a prima facie case – and so would have to rely on the “forum bar”, which the post explains and which it says was intended to provide real protection against the extra-territorial, over-zealous overreach of US (and other) prosecutors.

https://www.corkerbinning.com/uk-us-extradition-treaty/

SEC ANNOUNCES AN AWARD OF OVER $50 MILLION TO JOINT WHISTLEBLOWERS WHOSE INFORMATION ALERTED SEC STAFF TO VIOLATIONS

A release on Mondo Visione on 15 April advised that the joint whistleblowers provided exemplary assistance to the SEC staff during the investigation, including meeting with staff numerous times and providing voluminous detailed documents. The information provided by these individuals resulted in the return of tens of millions of dollars to harmed investors.  The SEC has now awarded approximately $812 million to 151 individuals since issuing its first award in 2012. 

https://mondovisione.com/media-and-resources/news/sec-awards-over-50-million-to-joint-whistleblowers-awards-this-fiscal-year-ex/

NORTH KOREA BUILDS NEW RAIL ROUTE TO HANDLE CHINESE FREIGHT DURING PANDEMIC

On 14 April, Radio Free Asia reported that North Korea has built a new rail route to its border with China designed to isolate freight in order to prevent the spread of coronavirus, an important first step toward restarting imports from its largest trading partner.  The new railroad is said to be directly connected to the Sino-Korean Friendship Bridge.

https://www.rfa.org/english/news/korea/train-04142021175556.html

CHINA HAS TRADEMARKED THE ENTIRE SOUTH CHINA SEA

On 13 April, radio Free Asia reported that, not content with claiming sovereignty over nearly every crag of rock and spit of sand in the South China Sea, China has taken the unusual step of registering trademarks over hundreds of land features scattered throughout those disputed waters.  This may be an attempt by China to control how domestic and even foreign companies use South China Sea branding.

https://www.rfa.org/english/news/china/mark-04132021192429.html

https://www.rferl.org/a/russia-military-buildup-near-ukraine-border/31203623.html

LITHUANIAN MAFIA GANG ‘ALL BUT GONE’ IN IRELAND FOLLOWING GARDA CLAMPDOWN

On 15 April, The Journal reported that gardaí have managed to dismantle the main working aspects of a Lithuanian criminal gang responsible for heroin smuggling and people trafficking across Ireland.

https://www.thejournal.ie/lithuanian-mafia-gang-dismantled-5404046-Apr2021/

DRUG MAP SHOWS HOW CARTELS USING IRELAND TO FLOOD ‘TSUNAMI OF COCAINE’

On 13 April, Dublin Live reported that Irish airspace and airports are being used to smuggle millions of euro worth of cocaine into Europe, Europol has warned.  Sources said they could not discount cartels using private jets to smuggle large amounts of cocaine into Ireland for onward delivery to other European states, but they said it was most likely that they were using drug mules to bring smaller amounts on commercial flights from South America via third countries.

https://www.dublinlive.ie/news/dublin-news/gangland-map-drugs-cocaine-ireland-20374902

IRELAND: BRIBES AND BLACKMAIL UNCOVERED AS FORMER BANK WORKER ARRESTED IN MAJOR FRAUD PROBE

On 14 April, the Irish Independent reported on an an investigation into a former employee of the Central Bank, who allegedly committed fraud crimes after he set up a business to help clients apply for bank licences.

https://www.independent.ie/irish-news/crime/bribes-and-blackmail-uncovered-as-former-bank-worker-arrested-in-major-fraud-probe-40311026.html

CONTAINER SHIP CREW MEMBER SENTENCED TO 5+ YEARS FOR CONSPIRACY TO SMUGGLE $1 BILLION WORTH OF COCAINE INTO THE US

A news release from US DoJ on 13 April announced that Vladimir Penda, 27, of Montenegro, had been sentenced to 5 years and 10 months in prison, and 2 years of supervised release.  For the first half of 2019 until mid-June of that year, Penda, a crew member who worked on board the shipping vessel MSC Gayane as the ship’s fourth engineer, conspired with others to engage in a bulk cocaine smuggling scheme.

https://www.justice.gov/usao-edpa/pr/msc-gayane-crew-member-sentenced-5-years-conspiracy-smuggle-1-billion-worth-cocaine

BACKGROUND TO THE OFFENCE OF MISCONDUCT IN A PUBLIC OFFICE

On 7 April, an interesting post from The Global Anticorruption Blog looks back to 1783, when the English common law offence was created in the case of The King v Bembridge, involving an accountant in the receiver and paymaster general’s office of the army.  The post comments that what makes misconduct in public office a prosecutor’s dream is its vagueness – which also meant it was more a choice for them in certain cases even after the Bribery Act came into force.  A 2020 Law Commission report criticised the offence and recommended it be replaced by statutory offences.

https://globalanticorruptionblog.com/2021/04/07/wickedly-willfully-fraudulently-knowingly-and-corruptly/

MOZAMBIQUE REBELLION BEGINS TO THREATEN SHIPPING

On 14 April, Insurance Marine News reported that there are worries that the current insurgency in Northern Mozambique was steadily transmuting into a serious maritime security threat in the Western Indian Ocean.  It says that the obvious concern is that an increasing ability to work at sea as well as on land could be only a short step towards piracy, as nearly a third of the world’s tanker traffic transits the Mozambique Channel.

https://insurancemarinenews.com/insurance-marine-news/mozambique-rebellion-begins-to-threaten-shipping/

THE EVOLUTION AND ESCALATION OF THE ISLAMIC STATE THREAT TO MOZAMBIQUE – ANALYSIS

On 15 April, Eurasia Review published a report looking at the background to, and prospects for, the insurgency in Mozambique.

https://www.eurasiareview.com/15042021-the-evolution-and-escalation-of-the-islamic-state-threat-to-mozambique-analysis/

FRAUD CASES IN SWITZERLAND IN 2020

https://home.kpmg/ch/en/home/insights/2021/04/forensic-fraud-barometer-2020.html

https://assets.kpmg/content/dam/kpmg/ch/pdf/forensic-fraud-barometer-2021.pdf

MORE AIRLINES BANNING THE SHIPMENT OF VIVO MOBILE PHONES AFTER A FIRE AT HONG KONG AIRPORT 

On 15 April, Loadstar reported that this is likely to have a serious impact on Vivo, which is ranked number 5 in global smartphone shipments.  Indian carriers Spicejet and Go Air, as well as Garuda, IAG Cargo and Lufthansa Cargo have also told customers the shipments are banned.

https://theloadstar.com/more-air-cargo-carriers-ban-vivo-phone-shipments-as-probe-into-hk-fire-begins/

BUSINESS TEXTS ON PERSONAL PHONES: THE GROWING COMPLIANCE AND ENFORCEMENT RISK AND WHAT TO DO ABOUT IT (PART II) 

On 15 April, the Compliance & Enforcement blog at the Program for Corporate Compliance and Enforcement at the New York University School of Law published Part 2 of 3-part series of posts.  Part 1 discussed recent enforcement actions related to employees’ use of personal devices, and the challenges employees’ use of personal devices pose for compliance with books and records and communication supervision rules.  Part 2 looks at policies and training.

https://wp.nyu.edu/compliance_enforcement/2021/04/15/business-texts-on-personal-phones-the-growing-compliance-and-enforcement-risk-and-what-to-do-about-it-part-ii-of-ii/

US: BRAZILIAN OIL EXECUTIVE PLEADS GUILTY TO BRIBERY IN PETROBRAS SCHEME

On 15 April, Courthouse News and others reported that attorneys for Jose Carlos Grubisich, 64, say he was caught up in a corrupt company culture while serving as CEO of the Odebrecht-owned petrochemical company Braskem SA.   The former CEO of Brazil’s largest petrochemical company pleaded guilty to bribery conspiracy charges, saying he helped to facilitate payments to government officials to secure business deals. 

https://www.courthousenews.com/brazilian-oil-exec-pleads-guilty-to-bribery-in-petrobras-scheme/

UK: ACCOUNTANT JAILED FOR ‘INDUSTRIAL SCALE’ £1.4 MILLION FRAUD

On 15 April, the BBC reported that an accountant who committed “industrial scale dishonesty” to fund a lavish lifestyle has been jailed.  Steven Day, 51, of Perthshire, plundered £1.4 million from businesses and defrauded the NHS 2012-15.  He admitted 12 fraud offences and was jailed at Leeds Crown Court for 11 years and 5 months.

https://www.bbc.com/news/uk-england-merseyside-56765120

SEC RAISES MORE RED FLAGS OVER BROKER-DEALER AML COMPLIANCE

On 15 April, an article from Alston & Bird says that it has analysed a new risk alert from the SEC Division of Examinations and what it means for future enforcement.  The Risk Alert details compliance concerns related to AML obligations of broker-dealers.  It chronicles various compliance deficiencies observed during recent examinations of broker-dealers’ suspicious activity monitoring and reporting obligations under the Bank Secrecy Act (BSA) and related regulations.

https://www.alston.com/en/insights/publications/2021/04/sec-raises-more-red-flags

https://www.alston.com/-/media/files/insights/publications/2021/04/sec-raises-more-red-flags-over-brokerdealer-aml-co.pdf

IRELAND: MAN SENTENCED TO 7 YEARS IN JAIL FOR LAUNDERING €3.7 MILLION

On 15 April, the Irish Times reported that Darren Hoey, 46, has been sentenced to 7 years in prison after pleading guilty under money laundering legislation to possessing almost €3.7 million.  Other charges he pleaded guilty to are related to possession of articles to aid and assist a crime organisation.  He was described as a trusted and responsible member of an organised crime group involved in drug trafficking.

https://www.irishtimes.com/news/crime-and-law/courts/circuit-court/man-sentenced-to-seven-years-in-jail-for-laundering-3-7million-1.4538755

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page, where contributions start as low as $3, at https://www.buymeacoffee.com/KoIvM842y`

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

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s