Panama Covid-19 update – problems continue in neighbouring Costa Rica, with a 196% increase in hospitalisations in the last 30 days – rising from 390 to 1,153, with 409 in ICU.
Meanwhile, in Panama, the first Indian variant was detected in a traveller at the airport and arriving from India. New cases numbers continued its gradual increase at 398 today, with 3 new fatalities. 3,984 active cases include 56 in ICU and 306 in other wards.
7 MAY 2021
GERMANY’S DOLPHIN TRUST WAS A PYRAMID SCHEME – DEVASTATION FOR INVESTORS
On 5 May, Deutsche Welle reported that a German property group has gone bust, with indications it was a seriously fraudulent enterprise. Although nowhere near as known as the Wirecard scandal, the case is arguably far more consequential for ordinary people. A property investment company based in Hanover, for years Dolphin Trust benefited from an image that presented it as both a safe and profitable choice for those looking for alternatives to banks as places to put their money. Little known in Germany, Dolphin Trust targeted customers in the UK, Ireland and several Asian countries including South Korea and Singapore. Dolphin Capital was founded as a merger of several companies in 2008 by a German-British man called Charles Smethurst. It changed its name to Dolphin Trust in 2014.
UK: HOW THE PROTECTED ONLINE FILING (PROOF) SCHEME CAN HELP YOU PREVENT FRAUDULENT CHANGES TO YOUR COMPANY
On 6 May, UK Companies House published updated information about the free service lets one protect a company from unauthorised changes to your records. It prevents the filing of certain paper forms.
FATF: WEBINAR ON RISK-BASED SUPERVISION
FATF had published a webinar saying that putting in place a risk-based supervision programme has its challenges. The webinar involves the authors of the FATF’s Risk-Based Supervision Guidance and provides information about assessing risks and applying that understanding to prioritise supervisors’ day-to-day work. It includes information from the private sector and the financial inclusion community on what effective supervision means to them. The webinar is also available on FATF’s YouTube channel.
DISCOVERIES AFTER A YEAR OF EXAMINING CAYMAN NATIONAL BANK DATA LEAK
On 5 May, an article from the Brookings Institute said that, after a year of going through the data, which at its peak covered about $200 million in offshore deposits, the author said that he made 3 discoveries –
· The rich will always be with us, but audit rates need to reflect that;
· Many offshore clients have connections to people with political power; and
· Shell companies are hurting the ability to understand how much wealth sits offshore.
The data leak involved a cache of internal files and emails from the Cayman National Bank and Trust — a bank based in the Isle of Man.
OVERVIEW OF THE CAYMAN ISLANDS FINANCIAL SANCTIONS REGIME
On 3 May, law firm Walkers published this guide which provides an overview of the Cayman Islands financial sanctions regime, which was updated following the UK exit from the EU, together with an outline of key practical steps to comply. It explains the changes to sanctions from Brexit and the effect of OFAC sanctions in the Cayman Islands.
OFAC ENFORCEMENT ACTIONS HIGHLIGHT RISKS TO SOFTWARE PROVIDERS & MSB
In a Client Alert dated 6 May, the firm says that recent settlements highlight many of those risks, such as the reliance on third-party resellers, the integration of newly acquired companies, and contracting with the US Government. It is said that companies should review these and other recent settlements to ensure that their compliance programmes address the root causes of penalised companies’ violations and adopt the types of internal controls recommended by OFAC. These enforcement actions highlight several important takeaways about the risks that software and payments companies face, as well as OFAC’s compliance expectations.
GERMAN REPORT REVEALS HOW IRAN SMUGGLES ILLEGAL GOODS
On 7 May, Arab News and others reported that an intelligence report from Germany has revealed details of how Iran uses proliferation techniques to smuggle illicit technology for deadly weapons. It says that proliferation-relevant countries such as Iran, North Korea and Syria, but also Pakistan, try to circumvent safety precautions and legal export regulations and to disguise illegal procurement activities. To do this, they turn to mostly conspiratorial means and methods. The report states that Iran creates state-controlled “neutral” companies to hide the true nature of the purchase from buyers and establishes “illegal procurement networks which belong to the front companies and middlemen”.
HOW RUSSIA USES ISRAELI DRONES TO BOMB CIVILIANS IN SYRIA
On 7 May, an article in Haaretz says that, despite its Israeli origin, Russia’s military openly boasts that the Forpost UAV is one of its most crucial pieces of technology, a constant presence in the skies above Syria, scoping out targets so human pilots don’t have to risk reconnaissance flights, and assessing bomb damage. The article asks why Russia uses Israeli drones. In 2010, IAI completed a $400 million deal to export and licence its Searcher II UAV to be flown and licence-built in Russia as “Forposts”, and Russian crews reportedly trained to operate the UAV system in Israel.
US DoJ RESOLVES FIRST ACTION UNDER EXPORT CONTROL AND SANCTIONS ENFORCEMENT POLICY – THE TOP 5 LESSONS LEARNED
On 6 May, Sidley Austin published an article about which is said to mark the first application of DoJ December 2019 Export Control and Sanctions Enforcement Policy, which emphasises the importance of voluntary self-disclosure.
ONCE A STOP ON THE SMUGGLING ROUTE, KENYA BECOMES HEROIN HUB
On 7 May, Africa News published an article saying that, after disruption to the smuggling route through Syria and the Balkans, heroin was put on ships and sailed across the Indian Ocean to the porous eastern coast of Africa, and carried northward to Europe. Mombasa became the main port of arrival. Kenya, a beacon of security in a volatile region, but rife with corruption and lacking oversight, offered smugglers a reliable place to offload their product. It says that the bulk of the heroin hauled ashore – estimated by UNODC at 42 tonnes annually – was earmarked for distant markets; but in time, local interest steadily grew. It is now the second-most consumed drug in the country of nearly 50 million behind cannabis.
CRIME GANGS IN GEORGIA AND ALBANIA RUNNING PEOPLE-SMUGGLING OPERATION THROUGH IRELAND INTO THE UK
On 7 May, the Irish News reported that organised crime groups from Georgia and Albania are running a major people-smuggling operation through Ireland into the UK. Crime gangs from Georgia and Albania are providing forged Italian and Slovakian identity documents as well as fake British passports to exploit the Common Travel Area between Ireland and Britain.
US: MAN PLEADS GUILTY TO SMUGGLING HUNDREDS OF TURTLES
On 6 May, Fox 12 News reported that a Chinese man has pleaded guilty to smuggling hundreds of endangered and vulnerable turtles from the US to China. 30-year-old Yuan Xie pleaded guilty to one count of conspiring to smuggle goods from the US. Between at least May 2017 and continuing until October 2018, he conspired with another Chinese national, 35-year-old Xiao Dong Qin, to purchase more than 769 live turtles from reptile dealers in Alabama, California, Florida, Kentucky, Michigan, New Jersey, Nevada, North Carolina, and South Carolina. All of the turtles purchased and smuggled by Xie are protected by CITES.
IRELAND: FORMER MILLIONAIRE PROPERTY DEVELOPER TO BE CHARGED OVER THEFT AND MONEY LAUNDERING OFFENCES
On 7 May, the Sunday World reported that a former millionaire property developer is expected to be brought to court later charged today with a number of serious offences linked to a property re-registration fraud. It is understood that he had spent many months living in the US after his original arrest but has returned to Ireland in recent days. The offences are alleged to have occurred in 2017 and the following year and allegedly involved 2 properties in the capital.
TRADE BODY SAYS THAT AML RULES SHOULD NOT BE APPLICABLE TO GENERAL INSURANCE
On 7 May, Insurance Business reported that the Global Federation of Insurance Associations (GFIA) believes that general insurance poses almost non-existent risk of money laundering or the financing of terrorism. It has published a position paper arguing that policymakers should follow the risk-based approach promoted by FATF when developing any new AML/CFT.
PREVIOUSLY THE GFIA HAD ISSUED A REPORT ON INSURERS’ CYBER RISK AWARENESS INITIATIVES
ISO 37301 VS 37001: HOW WILL THE NEW GENERAL COMPLIANCE STANDARD WORK WITH OTHER ISO COMPLIANCE STANDARDS?
The ISO37301 standard serves as a guideline for organisations that wish to implement a compliance management system (CMS), or those who seek to benchmark their existing system against international best practices. ISO 37001, on the other hand, is concerned only with anti-bribery management. Ethic Intelligence has produced a document to explain the purpose of each Standard, where they differ and how they may be unified.
ISRAEL SAYS EU DUPED INTO FUNDING TERRORIST GROUP
On 7 May, EU Observer reported that Israel’s foreign ministry has urged EU states to “immediately cease funding for Palestinian organisations that work on behalf of the PFLP terrorist group”. This follows the indictment of a Spanish national living in the West Bank, accused of duping EU donors to divert large sums to PFLP, which is on an EU terrorism blacklist.
UK: BRADFORD PAIR ARRESTED ON SUSPICION OF £3.4 MILLION FURLOUGH FRAUD
On 7 May, the Telegraph & Argus reported that a man and a woman from Bradford have been arrested as part of an HMRC investigation into a suspected £3.4 million Coronavirus Job Retention Scheme (CJRS) fraud. More than £6 million held in bank accounts controlled by the pair have been frozen by HMRC.
US CUSTOMS CONTINUES CRACKDOWN ON FORCED LABOUR IMPORTS
On 7 May, Sandler Travis Rosenberg reported that a recent seizure of rubber gloves from Malaysia confirms that a recent seizure authorisation is broader than the original withhold release order (WRO) and that US Customs & Border Protection is in fact acting under that authorisation. In March, CBP authorised port directors to seize, and commence forfeiture proceedings against, certain disposable gloves mined, produced, or manufactured in Malaysia by Top Glove Corporation Bhd with the use of convict, forced, or indentured labour. CBP has noted that the shipment was seized after an inspection revealed that the gloves were produced by a Top Glove subsidiary not named in the WRO, indicating that seizures may affect shipments from any of the company’s subsidiaries.
CUBA – NEW CHANGES, SAME CHALLENGES
On 7 May, an article from Control Risks examines the situation in Cuba after the former President of Cuba Raúl Castro stepped down as first secretary of the ruling Communist Party of Cuba (PCC). President Miguel Díaz-Canel is said to face a herculean task as a series of economic and political changes take place and challenges will deepen throughout the remainder of the year. It says that, despite recent changes both in the Cuban leadership and in the US, a radical change in the bilateral relationship is unlikely over the next year and most US sanctions will remain in place.
CHINA ISSUED EXPORT COMPLIANCE GUIDELINES FOR DUAL-USE ITEMS
On 6 May, an article from Dentons said that on 28 April guidance was issued for the new Export Control Law that came into effect in December. It replaces the previous 2007 opinions and provides specific guidelines and suggestions for exporters to establish export compliance programmes. It notes the similarity of the Compliance Guideline to the US Export Control Compliance Guidelines, which it says reflects the Chinese legislators’ intention not only to align with the international rules, but also to provide additional countermeasures to protect the Chinese companies.
HOW HEZBOLLAH BUILT A DRUG EMPIRE VIA ITS ‘NARCOTERRORIST STRATEGY’
A feature in Arab News on 7 May says that in Syria drug production exploded during the war in areas under Assad regime control. It is said that that Hezbollah, by virtue of its authority over both “legal and illegal” border checkpoints between Syria and Lebanon, has unchecked control over all drug-related operations. Illegal drug production is believed to have exploded in Syria during the civil war, emerging as a source of much-needed income for the Assad regime. The ruling clique and its foreign allies have used the proceeds from drug trafficking to evade sanctions imposed by the West.
INVESTMENT SCAMMER JOHN DAVIES REINVENTS HIMSELF?
On 7 May, a post on the Krebs on Security blog relates the (ongoing) story, saying that John Bernard, a pseudonym used by a convicted thief and con artist named John Clifton Davies who has fleeced dozens of technology start-ups out of an estimated $30 million, appears to have reinvented himself again after being exposed in a recent investigative series published by the blog. It is said that sources have claimed that Davies/Bernard is now posing as John Cavendish and head of a new “private office” called Hempton Business Management LLP.
PODCAST: UNEXPLAINED WEALTH ORDERS (UWO)
In this podcast from RUSI, it is said that 2020 was a roller coaster for UWO in the UK. It takes stock of the setbacks and the triumphs with guests, barristers Anita Clifford and James Mather and Alun Milford, former General Counsel at the SFO. Together they explore what the future may hold for UWO.
UK CBD MARKET SAID TO BE SECOND BEHIND ONLY THE US
On 6 May, Food Navigator repeated this claim by the head of a trade body, the Association for the Cannabinoid Industry (ACI), with estimates for sales in the UK put at £690 million in 2021. It refers to a new report from the ACI – “Green Shoots: Sowing the seeds of the new UK cannabinoid market”.
The report is at –
UN ISSUES CHECKLIST TO PROTECT STRANDED SEAFARERS’ HUMAN RIGHTS
On 6 May, Seatrade Maritime News says that the joint initiative between the UN Global Compact, the UN Human Rights Office, the ILO and the IMO aims to assist businesses in upholding their responsibilities as new COVID variants and outbreaks threaten to cause further delays in crew change and repatriation.
The toolkit is at –
CFIUS HAS CROSSED THE ATLANTIC, BUT IS YET TO COMPLETE ITS UK LANDING
A post from US law firm Crowell Moring is concerned with the National Security and Investment Act 2021, saying that over the coming months the UK Government is to enact secondary legislation and provide further detail and guidance on the framework created by the Act, including guidance on the regime’s extraterritorial scope and finalised definitions of 17 sensitive sectors. The post considers the regime to be created by the new Act.
BELGIUM GOVERNMENT NETWORK DOWN AFTER MASSIVE DDOS ATTACK
On 4 May, The Record reported that most of the Belgium government’s IT network had been down after a massive DDoS attack knocked offline both internal systems and public-facing websites.
DEEPFAKES: FRAUD’S NEXT FRONTIER
A report from recorded Future on 29 April says that threat actors have begun to use dark web sources to offer customized services and tutorials that incorporate visual and audio deepfake technologies designed to bypass and defeat security measures. It says that it is believed that they will continue to develop these products, as the demand is likely to increase due to corporations incorporating visual and audio recognition technologies into their security measures. Within the next few years, both criminal and nation-state threat actors involved in disinformation and influence operations will likely gravitate towards deepfakes, as online media consumption shifts more into “seeing is believing” and the bet that a proportion of the online community will continue to be susceptible to false or misleading information. It explains that deepfakes are digitally altered images that use machine learning algorithms and frameworks, specifically generative adversarial networks (GAN), and artificial intelligence to replace authentic images with fake ones. After considering the situation and threat, the report considers the outlook and offers mitigation strategies.
PAPERWORK IS THE NEW TRADE IN POST-BREXIT BRITAIN
On 4 May, Loadstar reported on a new white paper which is said to reveals the depth and length of the challenges faced by businesses in the UK as they adapt to the new trading environment. The white paper contains research which shows that 99% of respondents are currently facing Brexit-related challenges – and worryingly, nearly 70% expect their operations to be negatively affected for more than 12 months. It describes an industry overwhelmed with paperwork and staff changes, while costs have risen – and customer satisfaction has fallen.
See also –
and these commentary from 30 April –
and the white paper is available at –
THE PERILS OF GIVING VIDEO EVIDENCE
On 7 May, an article from Allen & Overy warns that, if evidence is to be given remotely via video link from another country, be sure to check that this is permitted by the laws of that country. While generally becoming more common, a crucial and little-known technicality which arises when the witness is located outside the UK is that, in some jurisdictions, it is illegal to give evidence via video link from that territory to a Court in another jurisdiction.
US: IRANIAN NATIONAL CONVICTED FOR ILLEGALLY EXPORTING MILITARY SENSITIVE ITEMS
A news release from the US DoJ on 7 May advised that a federal jury convicted Mehrdad Ansari, 39, an Iranian citizen and a resident of the UAE and Germany, for scheming to obtain military sensitive parts for Iran in violation of the Iranian trade embargo. The parts had dual-use military and civilian capability and could be used in systems such as nuclear weapons, missile guidance and development, secure tactical radio communications, offensive electronic warfare, military electronic countermeasures (radio jamming), and radar warning and surveillance systems.
US: 4 EASTERN EUROPEAN NATIONALS HAVE PLEADED GUILTY TO RICO CHARGES ARISING FROM THEIR PROVIDING “SERVICES WHICH WERE USED BY CYBERCRIMINALS TO DISTRIBUTE MALWARE AND ATTACK FINANCIAL INSTITUTIONS AND VICTIMS
A news release from US DoJ on 7 May advised that 4 persons had pleaded guilty to conspiring to engage in a Racketeer Influenced Corrupt Organization (RICO) offence arising from their providing “bulletproof hosting” services between 2008 and 2015, which were used by cybercriminals to distribute malware and attack financial institutions and victims throughout the US. Aleksandr Grichishkin, 34, and Andrei Skvortsov, 34, of Russia; Aleksandr Skorodumov, 33, of Lithuania; and Pavel Stassi, 30, of Estonia, were founders and/or members of a “bulletproof hosting” organisation. They rented Internet Protocol (IP) addresses, servers, and domains to cybercriminal clients, who used this technical infrastructure to disseminate malware used to gain access to victims’ computers, form botnets, and steal banking credentials for use in frauds.
REPORT EXAMINING CONNECTIVITY AT UK’S ECONOMIC GATEWAYS
On 7 May, Hellenic Shipping News reported that the British Ports Association has published research into mobile coverage and deployments in ports, undertaken alongside experts in digital connectivity, Telint. The report provides case studies of 3 European ports and provides an overall assessment of the mobile data coverage at over 30 UK ports. The article says that 5G is certainly coming to ports, and more quickly than previously thought; and that change is fast approaching and in many cases is largely being driven by ports themselves.
The report is at –
CYBER SECURITY: SMALL BUSINESS GUIDE
The National Cyber Security Centre in the UK offers this publication on how to improve a businesses’ cyber security, with affordable, practical advice. It is said that following the advice in this guide will significantly increase your protection from the most common types of cybercrime.
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