Panama Covid-19 update – to be fair, workers have been working non-stop to restore water supplies after the huge mains burst yesterday, but we have been without water (except for our stored supplies) all day so far – it’s due back tonight. Not the best situation when there’s an infection about (so we haven’t been out today, as we can’t clean up properly on return), and not good if you have a business relying on a water supply.
Meanwhile, another 323 new cases reported today, plus 5 fatalities; with 3,897 active cases – 66 in ICU and 269 in other wards.
AIRBUS SUBSIDIARY PLEADS GUILTY IN SAUDI BRIBERY CASE
The Wall Street Journal reported that the SFO said that GPT Special Project Management had pleaded guilty to corruption and was ordered to pay $38.9 million, plus costs. The case arose from a defence contract with Saudi Arabia.
NORTH KOREA TO BUILD ‘EXPORT PROCESSING ZONE’ IN BORDER TOWN NEAR CHINA
On 29 April, Yonhap News reported on plans to build an “export processing zone” – the “Musan Export Processing Zone” – near the border with China in a move that appears to be aimed at increasing trade with China amid economic challenges due to global sanctions.
INSIDE AN ONLINE TRADING CRIME RING THAT GRIFTED MILLIONS FROM MOM-AND-POP INVESTORS
On 27 April, the Gizmodo website published an article providing the inside story of Antonio Giacca – an Italian music producer and marketer living in Florida – who, in November 2020, pleaded guilty to criminal wire fraud charges. Between 2013 and 2018, Giacca and his fellow marketers made at least tens of millions of dollars advertising cryptocurrency cons, and recruiting investors for “binary options”, primarily used as a front for flimflam. The story involved copywriters, producers, and actors – and infomercial videos advertising apps with names like Cash Code, Binary Cash Creator, Secret Millionaire Society, and Golden Goose Method, each of which offered automated, easy to use, push-button money-making systems, supposedly using some genius new trading algorithm or financial loophole.
NIGERIAN POLITICIANS OWN 800 PROPERTIES WORTH $400 MILLION IN LONDON, DUBAI
On 28 April, the Premium Times reported that an expert has said that education and real estate sectors provide opportunities for PEP in Nigeria to launder money. He advised investigators to focus on real estate and education sectors, when tracking illicit financial flows and money laundering.
CANADA: PONZI SCHEME VICTIMS CALL FOR REOPENING OF PROBE OF TRANSFERS IN ISLE OF MAN
On 28 April, CBC reported that victims of a massive investment fraud that operated for years out of Montreal and siphoned more than $500 million offshore are calling on federal politicians to resume an inquiry into Canadian shell companies set up in the Isle of Man. 3 Montreal companies — Cinar, Norshield and Mount Real —bilked thousands of average Canadian investors. It also reminded one that KPMG had helped set up offshore shell companies for unknown wealthy Canadian clients. In 2016, a House of Commons finance committee closed its inquiry after objections were raised by KPMG about the potential impact on ongoing court cases. The Canada Revenue Agency eventually settled 3 of the tax cases out of court, but the committee never resumed its inquiry. The Montreal-based fraud operated for several years until 2005, when investors in the 3 companies learned hundreds of millions of their money had gone missing offshore. 3 executives of the companies were found guilty of fraud in 2016, but most of the money misappropriated has not been located.
DANSKE BANK MAY HAVE TO LOOK INTO ESTONIA DIRTY MONEY CASE AGAIN
On 28 April, Reuters reported that the Danish Danske Bank has said it may be required by authorities to conduct a further investigation into its former Estonian branch, possibly prolonging a money-laundering saga. Danske is under investigation in several countries, including the US, over some €200 billion of suspicious transactions that passed through the bank’s small Estonian branch between 2007-2015. Late last year, the bank completed a year-long internal investigation into its non-resident portfolio in the now shuttered Estonia branch and handed it over to authorities.
CORRUPTION IN THE SHIPPING AND PORTS SECTORS
On 27 April, an article from Clyde & Co was concerned with corruption within Rotterdam’s shippers and operators which it says should serve as an alarm call for companies across the sector to revisit their anti-bribery and corruption controls and reinforce employee codes of conduct. It makes a number of recommendations.
WHY IS IRAN PRODUCING 60%-ENRICHED URANIUM?
On 29 April, the Stockholm International Peace Research Institute published a paper saying that the Iranian move comes against the backdrop of sensitive negotiations happening in Vienna aimed at rescuing the 2015 JCPOA Iran nuclear deal, and bringing the US back into compliance with the deal. Iran’s decision has also inevitably drawn international attention because it brings the country so close to producing 90%-enriched uranium, which is generally considered weapons-grade.
THE LONG ARM OF HMRC
On 26 April, an article from Reynolds Porter Chamberlain outlines the powers HMRC has at its disposal when conducting a criminal rather than civil investigation, and HMRC’s ability to obtain communications data when investigating suspected criminal activity – including requests to access communications data.
SHIPBREAKING: THE SHIPPING INDUSTRY AND THE LAW OF NEGLIGENCE
On 28 April, an article from Leigh Day discusses a judgment of the Court of Appeal which it says will have far-reaching implications across the shipping industry and the way it disposes of end-of-life vessels. It was held that that a shipping company in England selling a vessel for dismantling in South Asia could owe a duty of care to shipbreaking workers in Bangladesh even where there are multiple third parties involved in the transaction, and this intensifies the international spotlight on environmental and health and safety practices across the maritime sector. It is said that the decision is likely to cause considerable concern within the shipping industry. It supports the principle that a ship owner’s liability does not automatically end once it sells a ship. If a duty of care exists at the time of sale, liability may be difficult to avoid if a vessel is sent to be scrapped on the beaches of South Asia.
RUSSIA MULLS FURTHER EXPORT RESTRICTIONS ON SCRAP METAL
On 28 April, Argus Media reported that higher steel prices driven by seasonal demand in Russia have revived consideration of stricter restrictions on ferrous scrap exports, but scrap market participants warn that any further restrictions will devastate the country’s scrap export industry. The relevant ministry said it may impose a €90/tonne duty on ferrous scrap exports, up from a 5% levy (or a minimum of €45/tonne). Other options such as reinstating export quotas, an export licensing system or measures to reduce the incentive to export could also be introduced.
REGULATING KHAT COULD DISRUPT EAST AFRICA’S ILLEGAL DRUG ECONOMY
On 29 April, the Institute for Strategic Studies published an article saying that different laws and controls among countries in the region allow for a thriving smuggling market. It says that organised crime researchers that the people involved in human trafficking could also be illegally trading khat along the same routes. Khat, a plant-based stimulant drug, is legal in Kenya, Ethiopia, Uganda and Djibouti – but is illegal in Rwanda, where it is classified as a narcotic and listed among other banned psychotropic substances. . It is a source of livelihoods and has become a major cash crop, but internationally, khat is classified as a new psychoactive substance. The illegal khat trade is controlled by criminals who are also involved in moving other illicit goods. The article suggests that regulating the khat trade would disrupt the criminal market and challenge the illegal drug economy – that is, trafficking khat alongside other illicit goods. The cost of the drug would also be regulated, thus limiting the current pattern of price hikes that increase smugglers’ profits. Legally growing and trading khat would enable countries to tap into the revenues generated from the trade, as is the case with Kenya and Ethiopia.
1,600 OFFENCES DETECTED IN A GLOBAL OPERATION AGAINST MARINE POLLUTION
A news release from Europol on 29 April advised that between 1 and 30 March, 300 agencies across 67 countries joined forces against marine pollution during the third global operation 30 Days at Sea. Europol and Frontex coordinated the European leg of the operation. The actions led to the identification of numerous crimes ranging from illegal discharge to waste trafficking and the investigation of thousands of suspects worldwide. Countries were able to connect pollution crime with other serious crimes such as fraud, corruption, tax evasion, money laundering, piracy, and illegal fishing. It is said that, with many enforcement resources being reassigned to tackle the pandemic, criminals have been quick to exploit growing vulnerabilities in different crime areas including environmental crime. A major criminal network trafficking plastic waste between Europe and Asia was exposed, and several countries from Europe, Asia and Africa reported illegal shipments of contaminated or mixed metal waste falsely declared as metal scraps.
UK: EXTRADITION ACT 2003 – CODES OF PRACTICE AND TRANSIT CODE OF PRACTICE
The Extradition Act 2003 (Codes of Practice and Transit Code of Practice) Order 2021 brings into operation codes of practice from 1 May. The revised Extradition Act 2003: Codes of Practice are aimed at police officers and customs officers They deals with Part 4 of the Act, which sets out powers of search and seizure of premises and persons, application for warrants and production orders, entry to premises and the treatment of detained persons after arrest in extradition cases (it does not apply in Scotland. Also involved is the Transit Code (entitled “Code of Practice for Non-UK Extradition Transit”) which is issued for the first time and is made in connection with the transit through the UK of persons being extradited from one foreign country to another foreign country. The Act provide powers to detain and search such persons and powers to seize, retain or return items seized, and this code applies throughout the UK.
MYANMAR (SANCTIONS) (ISLE OF MAN) ORDER 2021
This Order extends to the Isle of Man with modifications the Myanmar (Sanctions) Regulations 2021 as amended from time to time.
GLOBAL ANTI-CORRUPTION SANCTIONS (ISLE OF MAN) ORDER 2021
This Order extends to the Isle of Man with modifications the new Global Anti-Corruption Sanctions Regulations 2021 regime, as amended from time to time.
GLOBAL ANTI-CORRUPTION SANCTIONS (OVERSEAS TERRITORIES) ORDER 2021
THE MYANMAR (SANCTIONS) (OVERSEAS TERRITORIES) ORDER 2021
These Orders extend with modifications the Myanmar Sanctions and the Global Anti-Corruption Sanctions regimes to all British Overseas Territories except Bermuda and Gibraltar (which implement sanctions under their own legislative arrangements).
IRELAND: 3 IN COURT CHARGED OVER €6 MILLION ‘GHOST BROKER’ FRAUD
On 29 April, RTE reported that 2 businessmen and an art teacher have appeared in court charged in connection with €6 million “ghost broker” motor insurance policy fraud. A court was told that more than 2,500 motor insurance policies, valued at €6 million were identified as having been fraudulently obtained from 10 insurance companies. Fraudulent documents were allegedly used get policies with beneficial premiums. The defendants are accused of using false information, including fake licences and no claims bonus certificates, to get genuine insurance policies with reduced premiums.
FCPA: A PRIMER ON GIFTS AND BUSINESS ENTERTAINMENT
On 29 April, an article from Thomas Fox looks at the FCPA rules in this area, cautioning that, as with most matters under the FCPA, there is little direct guidance on what conduct may step over the line.
CALIFORNIA MAN GUILTY IN $100 MILLION PHONY AFGHAN ELECTRIC GRID SCHEME
On 29 April, Manufacturing.net reported that a California manm Saed Ismail Amiri, 38, has pleaded guilty in a scheme to defraud the Afghanistan government out of more than $100 million with a phony bid to build an electric grid, authorities said. The scheme involved Amiri’s Afghan company, Assist Consultants Incorporated, federal prosecutors said. It is alleged that in 2015 and 2016, Amiri and others tried to win a US-funded contract to build 5 electric power substations in Afghanistan by submitting a false work history and phony supporting documents indicating the firm met requirements for the contract.
MALTA: TUMAS GAMING GETS €233,000 MONEY LAUNDERING FINE
On 29 April, Lobin Malta reported that Tumas Gaming has been hit with a €233,156 fine for breaching money laundering regulations, with the FIAU uncovering players splashing hundreds of thousands in cash with little oversight. Tumas Gaming is owned by Tumas Group, which was led by Yorgen Fenech until his arrest in connection with the assassination of journalist Daphne Caruana Galiza. Its COO Patrick Demanuele is currently under investigation as part of a money laundering and trading-in-influence investigation.
POPE ISSUES TOUGH NEW RULES AGAINST VATICAN FINANCIAL CORRUPTION
On 29 April, Catholic Culture reported a new bid to address persistent concerns about financial improprieties, and that Pope Francis has issued a motu proprio that sets tough standards for all Vatican officials. The new policies affect all Vatican officials who exercises “administrative or control and supervisory functions”. Vatican employees may not accept gifts of a value greater than €40 ($48).
UK: NATIONAL SECURITY AND INVESTMENT BILL RECEIVES ROYAL ASSENT
On 29 April, a Home Office news release advised that the landmark Act will modernise government’s powers to investigate and intervene in potentially hostile foreign direct investment, while protecting the UK’s reputation as an attractive place to invest. Like CFIUS in the US, the new Act strengthen the government’s ability to investigate and intervene in mergers, acquisitions and other deals that could threaten UK national security.
UK: AIR TRAFFIC MANAGEMENT AND UNMANNED AIRCRAFT BILL RECEIVES ROYAL ASSENT
A news release from the Department for Transport on 29 April advised that, among other things, the new Act provides the police powers to ensure skies remain safe and secure from disruption and illegal use of drone technology. The Act will support the safe practice of drone technology by giving police officers the necessary powers to tackle illegal misuse. This will include issuing fixed penalty notices, mandating a person to land an unmanned aircraft and introducing stop and search powers where offences involving an unmanned aircraft have been committed.
UK: INDEPENDENT HUMAN RIGHTS ACT REVIEW
On 29 April, news releases from the MoJ about a review which will consider how the Human Rights Act is working in practice and whether any change is needed. One involves the Government response to recommendations made by the independent review. The Independent Review of Administrative Law made 2 recommendations for change in the substantive law, as well as various recommendations for changes in procedure.
The UN Toolkit on Synthetic Drugs is now also available in Spanish
Toolkit modules help identify practical solutions to address international threats posed by the non-medical use of synthetic drugs.
GIBRALTAR REGULATORY AGENCIES TRIAL AML PLATFORM FOR CRYPTO ASSET INVESTIGATIONS
On 29 April, a Gibraltar Government news release advised that the Government of Gibraltar has entered into an agreement with Coinfirm Ltd., a leading RegTech firm, to trial a new AML risk management platform for crypto and blockchain assets. This is intended to benefit regulatory and law enforcement agencies in the jurisdiction with the use of advanced blockchain-native anti-money laundering and countering terrorist financing analytics. This is said to be the first time this innovative technology is being used to support Gibraltar’s work in the international fight against money laundering. The AML Platform is said to be able to monitor high-risk transactions and trace misappropriated funds through visualisers amongst other proprietary investigative tools. The smart, data-led automatic analytics can overcome highly-complex criminal enterprise schemes through deploying various methodologies including the destination and source of funds, fingerprints of activity, ownership analysis, e-discovery and clustering algorithms.
ITALIAN POLICE TACKLES GANG THAT ALLEGEDLY TRAFFICKED COCAINE FROM PERU
On 29 April, OCCRP reported that Italian authorities have ordered the preventive detention of 15 suspected members of an international gang believed to have imported cocaine from South America in cooperation with the ‘Ndrangheta, one of Italy’s 4 major mafia groups. 8 Peruvian and 7 Italian citizens in the northern region of Pavia are involved, while 5 gang members are believed to have left the country. To avoid customs controls, the gang used chemical procedures to hide the drug in book and magazine covers and in the coatings of suitcases. Once in Italy, the cocaine would be later refined in clandestine laboratories.
3 ARRESTED IN SPAIN FOR ENCOURAGING TERRORIST ATTACKS AGAINST FRANCE AND ITS INTERESTS ABROAD
A news release from Europol on 29 April announced that the Policia Nacional swooped on the members of a terrorist cell in the city of Granada, and 3 individuals were arrested on suspicion of encouraging terrorist attacks against France. The Spanish National Police used its specialist capabilities to identify the individuals behind these social media profiles with totalled almost 19 000 followers, in the wake of the French magazine Charlie Hebdo having republished caricatures of the Prophet Muhammad.
NEW ZEALAND: MEXICAN COCAINE “CARTEL” AND “FILTHY FEW” GANG MEMBERS
On 29 April, the New Zealand Herald reported that 8 people have been arrested after a joint police and Customs operation allegedly disrupted plans to import hundreds of kilograms of cocaine into the country via a Mexican “cartel”. Those arrested in the police raids include 2 patched Filthy Few biker gang members.
BRAZIL’S CHEAPER EXOTIC FISH STILL TARGETED BY TRAFFICKERS
On 29 April, Insight Crime reported that international animal trafficking rings often cash in on global demand for smaller, lesser-known species, as shown by the dismantling of a global smuggling ring that poached killifish from Brazil and other countries. In April, the US Fish and Wildlife Service and Brazilian police seized hundreds of endangered live killifish after carrying out searches in Maryland – with some 200 tanks of killifish along with hundreds of eggs inside a Maryland home.
PLANNED LITIGATION NO EXCUSE FOR EMPLOYEES ‘STEALING’ CONFIDENTIAL INFORMATION
A webcast 9with transcript) from Out-Law on 29 April involves a recent High Court case and says that employees who leave and take confidential information with them sometimes use the excuse that they needed for the purposes of litigation – litigation they are planning to bring against you, such as a whistleblowing claim. Is that a good reason for taking your most valuable assets? Is there anything you can do to protect the business from that happening?
FIGHTING BRIBERY AND CORRUPTION IN SAUDI ARABIA
An article from Eversheds Sutherland on 29 April reviews the powers and recent efforts of the Saudi Oversight and Anti-Corruption Authority (“Nazaha”), and the anti-bribery laws. Nazaha is an independent body enjoying independent administrative and financial juridical personality. It reports directly to the King, bypassing the Council of Ministers, which gives it autonomy and independence to monitor and investigate. The anti-bribery law has an extremely wide scope of application, particularly when compared to the FCPA. The law does not specifically identify the failure to prevent bribery as an offence, but it does incorporate an enhanced version of the US vicarious liability principle as it presumes corporate liability when the manager of the corporate entity or any of its employees are convicted of a bribery offence, when the relevant act was committed in favour of the corporate entity.
SWITZERLAND: IMPROPER DECLARATION OF IMPORTED TIMBER PROSECUTED FOR THE FIRST TIME
On 27 April, Swissinfo reported that the Federal Consumer Affairs Bureau (FCAB) carried out 121 checks in 2020 to ensure that wood and wood products were declared. Overall, almost a third of companies (32%) checked did not fully comply with the obligation to declare the species and origin of the wood they use. This is slightly lower than in 2019 (35%). The majority of wrongly declared products (62%) were related to the origin of the wood and concerned mainly small companies that have never been audited before. Authorities opened 2 legal proceedings against importers of exotic wood for repeatedly failing to correctly declare their origin.
WEST AFRICA’S COCAINE CORRIDOR
On 28 April, the Global Initiative Against Transnational Organised Crime published a report saying that record-breaking cocaine seizures between 2019 and January 2021 in West Africa have drawn international attention to cocaine trafficking in the region. These incidents also position Guinea-Bissau, and its neighbouring vulnerable littoral states, at the heart of the region’s drug-trafficking activities. It says that the coastal countries stretching from Senegal, through Gambia and Guinea-Bissau to Guinea are once again operating as a major corridor for Latin American cocaine flowing through West Africa en route to end markets in Europe. Traffickers import cocaine into West Africa through multiple maritime entry points, both in the coastline stretching between Senegal and Guinea, and further south, with Cote D’Ivoire playing a prominent role since 2019. The report focusses on the corridor between Senegal and Guinea, and the geopolitical characteristics underpinning cocaine trafficking in this sub-region.
NUCLEAR BELT AND ROAD: CHINA’S AMBITION FOR NUCLEAR EXPORTS AND ITS GLOBAL IMPLICATIONS
The Wilson Center in the US has published this report which says that nuclear exports are an important and understudied part of the Belt and Road Initiative (BRI). Beijing plans to build and finance approximately 30 nuclear reactors in BRI countries in Asia, the Middle East and Africa over the next decade. It argues that China’s nuclear exports will increase recipient countries’ reliance on China for decades at the expense of the US, thereby threatening a shift in the balance of power in the international system. It is also said to poses environmental concerns because many recipient countries lack rigorous regulations and necessary technologies, know-how and personnel to handle the technology safely. Making recommendations for the US, the report argues that the US should act to thwart China’s nuclear export. In particular, it says the US should shed light on China’s chronic corruption problem, lack of transparency and shady business practices, such as the# of intellectual property, and poor safety standards.
US: CHINESE NATIONAL PLEADS GUILTY TO ILLEGAL EXPORTS WITH UNDERWATER AND MARINE APPLICATIONS
A news release from US DoJ on 28 April advised that Shuren Qin, 44, a Chinese national residing in Massachusetts had pleaded guilty in federal court in Boston in connection with illegally procuring and causing the illegal export of $100,000 worth of US-origin goods to Northwestern Polytechnical University (NWPU), a Chinese military university that is heavily involved in military research and works closely with the People’s Liberation Army on the advancement of its military capabilities. He had established LinkOcean Technologies, LTD., which he used to import goods and technology with underwater and marine applications into the PRC from the US, Canada and Europe.
GERMAN GOVERNMENT ESCALATES ITS FIGHT AGAINST MONEY LAUNDERING
On 29 April, a post on the Compliance & Enforcement Blog from the Program on Corporate Compliance and Enforcement at the New York University School of Law says that while Germany’s AML framework has already been described as insufficient by FATF in the past, the collapse of payment service provider Wirecard has seen the prevention of money laundering placed even higher on the German government’s agenda. The post says that implementation of the Fifth EU Money Laundering Directive on 1 January 2020 had already exceeded EU requirements, but a “National Strategy Package” and — in addition and as a direct reaction to the Wirecard collapse — the German government adopted a “16-Points Action Plan” at the beginning and in the middle of last year. The post goes on to describe the legal and control and administration changes being adopted.
FRANCE BEGINS SANCTIONING LEBANESE IMPLICATED IN CRISIS
On 29 April, L’Orient Today reported that France has begun imposing entry restrictions on certain Lebanese figures as a sanction for their role in Lebanon’s political crisis or corruption, and over their failure to reform the country in the wake of the deadly August 2020 Beirut port explosion. President Emmanuel Macron called for radical reform in Lebanon after the deadly Beirut port blast and has expressed exasperation at the lack of change.
INDIA: INTERPOL AGAIN REFUSES RED NOTICE AGAINST FUGITIVE TV EVANGELIST ZAKIR NAIK
On 29 April, the Hindustan Times reported that Interpol, for the third time, has rejected a request for a Red Notice to provisionally arrest controversial TV evangelist Zakir Naik on money laundering and hate speech charges. The fact that he raised money from his religious teachings and spent it is “irrelevant” and cannot amount to money laundering, Interpol’s adjudicating panel noted.
US RECOVERS $8.4 MILLION IN FRAUDULENT COVID RELIEF FUNDS FROM FAMILY
A news release from US DoJ on 29 April announced that the US has obtained a final civil judgment ordering the forfeiture of $8,417,261.38 in proceeds from bank fraud and money laundering offences related to COVID Relief Fraud. It is alleged that in April 2020, Joshua Edwards, Joy Edwards, Evan Edwards, and Mary Jane Edwards defrauded the Small Business Administration out of millions of dollars in coronavirus relief funds. Specifically, Joshua Edwards, on behalf of ASLAN International Ministry Inc., submitted a false and fraudulent loan application seeking funds.
NAMIBIAN MINISTRY OF FINANCE HAS ACCUSED 84 DOCTORS OF STEALING MILLIONS OF DOLLARS THROUGH THE GOVERNMENT’S MEDICAL AID SCHEME
On 29 April, Africa News reported that the doctors are accused of fraud and abuse of the Public Service Employee Medical Aid Scheme (Psemas). The ministry has launched a civil action against the doctors and has threatened to institute criminal charges against others.
HEATHROW URGES GOVERNMENT TO “GET A GRIP” OF IMMIGRATION AND CUSTOMS CONTROL AND SIMPLIFY THE MEASURES NEEDED FOR INTERNATIONAL ARRIVALS TO RESTART MASS TRAVEL FROM 17 MAY
On 29 April, the Guardian reported that despite a 90% drop in passengers in the first 3 months of 2021 there had been “horrendous queues” due to a lack of staff in immigration halls, which are operated by the government. The airport’s CEO says that it had to turn away flights because of congestion in immigration. However, Border Force suggested airlines should shoulder blame for queues as passengers were not completing paperwork correctly, with the additional Covid paperwork meaning the automatic gates cannot be used.
FBI RELEASES INTERNET CRIME REPORT SHOWING RECORD INCREASE IN CYBERCRIME
On 29 April, Alston & Bird published an article saying that the FBI’s Internet Crime Complaint Center (IC3) recently released its annual report, the 2020 Internet Crime Report, which gathers statistics from nearly 800,000 complaints of suspected cybercrimes that the department received in 2020. This is a record number of complaints — a 69% increase from 2019 — with reported losses exceeding $4.2 billion. The 3 most reported crimes in 2020 were phishing scams, non-payment/non-delivery scams, and extortion/ransomware. It identified the costliest scams as business email compromise scams, romance and confidence schemes, and investment fraud.
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