OTHER THINGS YOU MAY HAVE MISSED – JULY 6

Panama Covid-19 update – the Rt infection rate has risen, from 1.09 last week to 1.1, while 3 more people are in ICU, and 10 more in other wards, today. 1,276 new cases are reported (including 28 in our district…) and 7 new fatalities, 124 patients are in ICU and 620 in other wards, with a total of 13,501 active cases.

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

6 JULY 2021

AUSTRALIA: VICTORIA POLICE TO EXPLORE LINKS BETWEEN RACING AND ORGANISED CRIME

On 6 July, KYC 360 reported that Victoria Police have embedded an investigator and an analyst in the state’s racing industry to explore possible links with organised crime.  Seconded to the Office of the Racing Integrity Commissioner, their scope includes horse and harness, as well as greyhound racing.   Their work will focus on assessing on whether organised crime gangs are currently involved in the racing industry.

https://www.riskscreen.com/kyc360/news/australia-victoria-police-to-explore-links-between-racing-and-organised-crime/

CAYMAN ISLANDS INTRODUCES ECONOMIC SUBSTANCE REQUIREMENTS FOR PARTNERSHIPS

On 2 July, Carey Olsen published an article saying that the economic substance requirements in the Cayman Islands, introduced by the International Tax Co-operation (Economic Substance) Act have been extended to partnerships.  They will have to submit an annual economic substance notification indicating whether or not they are required to meet the economic substance test under the Act, but it is said that most partnerships that operate as investment funds will not be required to meet the test.  For existing partnerships, reporting begins from 1 January.

https://www.careyolsen.com/briefings/cayman-islands-introduces-economic-substance-requirements-partnerships

10 YEARS OF THE UK BRIBERY ACT – PART 2: SHIFTING THE FOCUS?

On 1 July, Paul Hastings LLP published the second of 3 articles marking 10 years of the Act.  This part looks at whether the Act has, so far, lived up to its expectations.  It also discusses what the Act has meant for enforcement activity and the impact of deferred prosecution agreements.

https://assets.ctfassets.net/t0ydv1wnf2mi/K1Fh1bXY7WnSCQugQksXu/a9b23f2617eeb1d4f907625e9449741a/Bribery-Act-Shifting_the_focus.pdf

RUSSIANS ACCUSED OF CENTRAL AFRICAN REPUBLIC ABUSES IN UN REPORT

On 29 June, Reuters reported that Russian military instructors and Central African Republic (CAR) troops targeted civilians with excessive force, indiscriminate killings, occupation of schools and large-scale looting, according to a UN report.  It also accuses groups linked to the Coalition of Patriots for Change (CPC) rebels of forced recruitment of children, attacks on peacekeepers, sexual violence and the looting of aid groups.

https://www.reuters.com/world/africa/russians-accused-central-african-republic-abuses-un-report-2021-06-29/

GUIDE: US EXPORT CONTROLS – SOME COMMON TYPES OF COMPANY CHANGES THAT REQUIRE NOTIFICATION AND THE ACTIONS THAT MUST BE TAKEN TO KEEP ITAR REGISTRATION CURRENT

On 3 July, an article from Torres Law explained that any US company that manufactures, exports, or temporarily imports items or performs defence services that are controlled under the International Traffic in Arms Regulations (ITAR) is required to register with the Department of State Directorate of Defense Trade Controls (DDTC) and keep that registration current. 

https://www.torrestradelaw.com/posts/ITAR-Material-Change-and-Registration-Renewal-Guide-And-Checklist/244

ZIMBABWE PLANS TO REGISTER GOLD MINERS TO CURB SMUGGLING

On 5 July, an article from Bloomberg Quint reported that Zimbabwe is drafting legislation which will compel small-scale gold miners to register their operations as it seeks to curb gold smuggling.

https://www.bloombergquint.com/business/zimbabwe-plans-to-register-gold-miners-to-curb-smuggling

SALFORD SMUGGLER WHO HELPED BRING MORE THAN 20 MILLION ILLEGAL CIGARETTES INTO THE UK

On 5 July, the Manchester Evening News reported that 3 men who smuggled more than 20 million illegal cigarettes into the UK have been jailed.  2 of them were arrested in May 2018 after HMRC investigators watched them load 2 million cigarettes onto a lorry at a Birmingham industrial estate.

https://www.manchestereveningnews.co.uk/news/greater-manchester-news/salford-smuggler-who-helped-bring-20976424

LANDMARK BORDERS BILL TO ENTER UK PARLIAMENT

On 6 July, the Home Office announced that those who enter the UK illegally will find it harder to stay under fundamental reforms in the Nationality and Borders Bill.  It describes the new immigration policy as a “fair but firm New Plan for Immigration”, which was first published in March 2021, and set out the most radical changes to the asylum system in decades.

https://www.gov.uk/government/news/landmark-borders-bill-to-enter-parliament

https://www.lawgazette.co.uk/news/borders-bill-risks-seriously-infringing-access-to-justice/5109100.article

DISMANTLING ZIMBABWE’S KLEPTOCRACY: OFFSHORE DEALINGS AND SANCTION-AVOIDING STRATEGIES

On 6 July, The Zimbabwean carried a item about a new report that zooms in on the burgeoning offshore business empire of Kudakwashe Tagwirei, Zimbabwe’s richest businessperson and a close adviser to President Emmerson Mnangagwa.  It says that, in August 2020 he was added to the US sanctions list of prominent Zanu-PF-connected businessmen.  It is said that the report seems to be based primarily on a trove of documents (including numerous emails) leaked by a whistleblower, and is said to be backed up by South African court documents as well as extensive research and interviews.  It is said that it is becoming clear that elite corruption in Zimbabwe overlaps South Africa’s borders and that South African businessmen are alleged to be active participants.  The also report documents Russian involvement in business deals, as well as the role of the Zimbabwean military. 

https://www.thezimbabwean.co/2021/07/dismantling-zimbabwes-kleptocracy-report-lifts-lid-on-kuda-tagwireis-offshore-dealings-and-sanction-avoiding-strategies/

CHINA STEPS UP SUPERVISION OF OVERSEAS-LISTED COMPANIES

On 6 July, Investing.com reported that China will step up supervision of Chinese companies listed offshore, this coming days after it launched a cybersecurity investigation into ride-hailing giant Didi Global Inc on the heels of its US stock market listing. China will also check sources of funding for securities investment and control leverage ratios. 

https://www.investing.com/news/economy/china-to-step-up-supervision-of-chinese-firms-listed-offshore–xinhua-2550487

https://www.rfa.org/english/news/china/listings-didi-07062021084718.html

JAPAN: PROSECUTORS DROP CASE AGAINST RECIPIENTS OF EX-MINISTER’S BRIBES

Pn 6 July, the Japan Times reported that prosecutors had dropped a bribery case against all 100 individuals including local assembly members who allegedly received cash from former Justice Minister Katsuyuki Kawai in a high-profile vote-buying scandal.  The suspected recipients are local assembly members and supporters in the constituency of Kawai’s wife Anri, a former Upper House lawmaker. Kawai had said in a court hearing he sought their support to get his wife elected from Hiroshima Prefecture in the 2019 Upper House election.

https://www.japantimes.co.jp/news/2021/07/06/national/crime-legal/bribery-recipients-case-dropped

AZERBAIJANI COUPLE, INCLUDING PRESIDENT’S COUSIN, OWNS PROPERTIES WORTH MILLIONS IN LONDON AND IBIZA

On 5 July, a report from OCCRP was concerned with Mikaela Jav, a well-known DJ, saying that she and her husband, Suleyman Javadov, have been under investigation by the NCA for receiving £13.9 million from opaque sources.  The couple settled the case rather than facing trial, agreeing to forfeit about £4 million of that amount held in Suleyman’s accounts.  The report reveals that Javadova and her husband own at least 4 UK apartments, and the couple also purchased 2 additional properties in Ibiza, where Javadova — as DJ Mikaela Jav — hosted her Saturday night parties.  The couple has claimed that the money they received came from legitimate rental income in Azerbaijan, and their lawyer described their system for receiving money as part of the ancient “hawala” system of moving money among a network of trusted brokers.

https://www.occrp.org/en/azerbaijanilaundromat/azerbaijani-couple-including-presidents-cousin-owns-properties-worth-millions-in-london-and-ibiza

AN ALLEGED PROLIFIC CYBERCRIMINAL HAS BEEN APPREHENDED IN MOROCCO FOLLOWING A JOINT 2-YEAR INVESTIGATION

A news release from INTERPOL on 6 July advised that an alleged prolific cybercriminal (“Dr Hex”) has been apprehended in Morocco following a joint 2-year investigation by INTERPOL, the Moroccan police and Group-IB.  The suspect is believed to have targeted thousands of unsuspecting victims over several years through global phishing, fraud and carding activities involving credit card fraud.

https://www.interpol.int/News-and-Events/News/2021/Moroccan-police-arrest-suspected-cybercriminal-after-INTERPOL-probe

IRAN: PRESIDENT RAISI AND THE NUCLEAR DEAL – IMPLICATIONS FOR SANCTIONS AND FINANCIAL TRANSACTIONS

On 1 July, Control Risks published an article saying that the election is raising some concerns about the fate of the Joint Comprehensive Plan of Action (JCPOA – the 2015 nuclear deal).  The article considers the possible implications of the election result.

https://www.controlrisks.com/our-thinking/insights/raisi-and-the-nuclear-deal-implications-for-sanctions-and-financial-transactions

UNCLEAR CRITERIA UNDERMINE US CORRUPTION LIST IN CENTRAL AMERICA

On 5 July, Insight Crime reported that while the US has released a highly-anticipated report on corrupt actors in El Salvador, Guatemala, and Honduras, the lack of clear criteria for those placed on the list may undermine efforts to create a coherent strategy for rooting out high-level graft in Central America.

https://insightcrime.org/news/criteria-undermines-us-corruption-list-central-america/

BREXIT: UK COMPLIANCE PROFESSIONALS PREDICT MORE AML REGULATION IS ON THE WAY AS A DIRECT RESULT OF LEAVING THE EU

On 6 July, a release on Mondo Visione advised that UK businesses overwhelmingly support opting out of the Sixth EU AML Directive, but are taking it as a sign the UK plans to diverge and create its own AML regulatory framework.  The findings are based on a survey of over 875 compliance professionals across banks, lenders, wealth management, accounting, gambling, legal and real estate.

https://mondovisione.com/media-and-resources/news/uk-compliance-professionals-are-bracing-for-an-increase-in-aml-legislation-as-a/ 

DAYS BEFORE EU SANCTIONS, BELARUSIAN OLIGARCH’S FAMILY SELLS ITS FIRM AND BANK

On 6 July, OCCRP reported that Belarusian oligarch Aliaksei Aleksin and his family sold its Cyprus-based company along with a bank to a Lebanese businessman, saving both entities from the sanctions-related asset freeze.  The Aleksin family sold MTB Investments Holdings, whichheld “more than 99%” of MTBank on 16 June and the EU announced its sanctions 5 days later.

https://www.occrp.org/en/daily/14767-days-before-eu-sanctions-belarusian-oligarch-s-family-sells-its-firm-and-bank

SINGAPORE: 2 EX-SHELL EMPLOYEES JAILED OVER MARINE FUEL HEIST AT PULAU BUKOM REFINERY

On 5 July, Today Online reported that 2 former employees from Shell Eastern Petroleum were sentenced to jail over the largest heist of marine gas oil in Singapore to date, amounting to hundreds and millions of dollars.  More than 300,000 tons of gas oil worth at least S$200 million were removed and it led to the prosecution of about a dozen employees and foreign ship captains.  It was in 2015 that Shell first had suspicions about losses.

https://www.todayonline.com/singapore/2-ex-shell-employees-jailed-over-s200m-marine-fuel-heist-pulau-bukom-refinery

ITALIAN POLICE DISCOVER MONEY TRANSFERS TOTALLING €1 MILLION TO FUND TERROR

On 5 July, Arab News reported that Italian police have discovered that more than €1 million were sent over the course of 5 years from a money transfer office in Puglia, in southern Italy, to 42 foreign collectors based in different countries. Investigators believe that the sum was destined to finance terrorism.  The entire sum was divided into transfers worth less than €1,000 each in an attempt to avoid rousing the suspicion of financial authorities.

https://www.arabnews.com/node/1888841/world

NETHERLANDS AND US ON THE TRAIL OF GOLD SMUGGLED FROM VENEZUELA

On 5 July, the Curacao Chronicle reported that 3 money laundering cases expose the route of corruption followed to remove the precious metal from the Arco Minero in Venezuela. The cases of provide clues about the mechanisms currently applied by criminal networks to extract gold from the Mining Arco, and subsequently place it on international markets.  2 cases were heard in Florida, while the third trial began in Curaçao, and in June it reached a final decision in the Supreme Court of the Kingdom of the Netherlands.  All the cases have as common factors that the precious metal is extracted from mines located in Bolívar state in Venezuela. From there it is carried by air or by sea to Curaçao, where the destination in which it will be sold is defined, often using documents that conceal the true origin of the shipments. It is noted that, since June 2019, Curaçao has had a ban on trading Venezuelan gold. 

https://www.curacaochronicle.com/post/main/the-netherlands-and-the-united-states-on-the-trail-of-gold-smuggled-from-venezuela/

AUSTRALIA: 5 CASINO INSPECTORS SAID TO HAVE KNOWN ABOUT PROBLEMS AT CROWN RESORTS CASINOS BUT SAY THEY WERE STONEWALLED AND SILENCED

On 6 July, ABC reported that the inspectors detected or suspected illicit activity but what they tried to report (or did report) was not acted upon. 

https://www.abc.net.au/news/2021-07-06/crown-casino-gambling-regulator-inspectors-speak-out/100231722

LONG-TERM INVESTIGATION CULMINATES IN ARREST OF 38 ALBANIAN DRUG SMUGGLERS IN COOPERATION WITH ITALY

A news release from Eurojust on 5 July advised that 38 suspects belonging to a large-scale drugs smuggling network have been arrested by the authorities in Italy, Albania, Montenegro and Spain.  Amongst the arrested persons are representatives of the Albanian law enforcement and judiciary, suspected of corruption and money laundering. The operation involved an Italian-Albanian joint investigation team (JIT), which in 2018 had been set up and funded with the support of Eurojust. In June 2020, 37 arrests took place involving members of the same organised crime groups, and most of them have already received sentences in Italy of up to 20 years.

https://www.eurojust.europa.eu/long-term-investigation-eurojust-culminates-arrest-38-albanian-drug-smugglers-cooperation-italy

BITCOIN GANG HAS ITS LUXURY CARS SEIZED BY BRAZIL POLICE

On 5 July, U Today reported that Brazil’s Federal Police had seized luxury cars, jewellery, and bags of cash that belonged to a money-laundering gang.  It is said that the criminals managed to embezzle $295 million with the help of cryptocurrencies.

https://u.today/bitcoin-gang-has-its-luxury-cars-seized-by-brazil-police

PIRACY IN THE GULF OF GUINEA: ARE THE CURRENT EFFORTS WORKING? UPDATED THREAT ANALYSIS AND TRENDS

Risk Intelligence in Denmark has produced a report which says that piracy attacks continue to be a major threat in the Gulf of Guinea, even though the number of attacks has been relatively low in recent months.  The whitepaper looks at some aspects that ship operators must consider for operations in the Gulf of Guinea.  That includes the distance of potential kidnap-for-ransom attacks from the Nigerian coastline, as well as increasing concerns among seafarers, highlighted by reports about suspicious activities.  Current efforts to improve maritime security in the region, including the Deep Blue project in Nigeria, are unlikely to lead to short-term improvements.  Operators therefore have to consider additional security measures, taking into account several considerations.

https://f.hubspotusercontent40.net/hubfs/8059546/RiskIntelligence-Whitepaper-Gulf-of-Guinea-July-2021.pdf

https://www.riskintelligence.eu

THIRD COUNTRIES ALIGN WITH EU BELARUS SANCTIONS CHANGES

On 6 July, the EU Sanctions blog announced that North Macedonia, Montenegro, Serbia, Albania, Iceland, Liechtenstein and Norway have all aligned themselves with a number of recent EU sanctions regime changes involving Belarus: banning Belarusian aircraft carriers from using EU airports and airspace; designating the Belaeronavigatsia State-owned Enterprise; and designating 78 people and 7 entities in relation to the diversion of flight 4978 and wider human rights violations in Belarus.

https://www.consilium.europa.eu/en/press/press-releases/2021/06/21/declaration-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-belarus/

https://www.consilium.europa.eu/en/press/press-releases/2021/07/06/declaration-by-the-high-representative-on-behalf-of-the-european-union-on-the-alignment-of-certain-third-countries-concerning-restrictive-measures-in-view-of-the-situation-in-belarus/

https://www.consilium.europa.eu/en/press/press-releases/2021/07/06/declaration-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-belarus/

ISIS: ‘GRAVE CONCERN’ ABOUT TERROR GROUP IN AFRICA

On 29 June, Homeland Security Today reported that the Global Coalition to Defeat Daesh/ISIS has said that they have “grave concern” about the growth and threat posed by ISIS affiliates and networks in Africa’s Sahel region and in East Africa, particularly Mozambique. The Central African Republic, Democratic Republic of the Congo, Mauritania, and Yemen were also welcomed as new members of the coalition, bringing the total of partners to 78 nations and 5 institutions: the Arab League, CEN-SAD, EU, INTERPOL, and NATO.

https://www.hstoday.us/subject-matter-areas/counterterrorism/global-coalition-to-defeat-isis-stresses-grave-concern-about-terror-group-in-africa/

US: OPERATION FLASHPOINT TO RAISE AWARENESS ABOUT HOW TO PREVENT BOMB MAKING

The FBI and the Cybersecurity and Infrastructure Security Agency (CISA) have announced a new pilot programme to build awareness in communities across the US about how to prevent bomb attacks. CISA and FBI officials have highlighted the threat posed by domestic violent extremists and others who can build improvised explosive devices (IED) from common household items found at retail stores across the US.  Approximately 250,000 businesses sell, use or distribute materials that can be used to build bombs.   In 2020, there were 2,061 bomb threat, suspicious package and device-related incidents. 

https://www.cisa.gov/news/2021/06/30/cisa-and-fbi-launch-operation-flashpoint-raise-awareness-about-how-prevent-bomb

AL-QAEDA URGES ACQUISITION OF “GHOST GUNS” IN REVIEW OF BOULDER MASS SHOOTING

On 5 July, Homeland Security Today reported that Al-Qaeda in the Arabian Peninsula said the Boulder supermarket mass shooting in the US underscored the ease with which potential shooters can acquire guns and told would-be jihadists to not start with simpler knife or vehicle attacks “until you search for these weapons and use them in your operation”.  It advises fighters look for ways to obtain stealth weapons by purchasing ready-made weapon parts and then assembling and installing them manually.  It advises obtaining parts through the black market.

https://www.hstoday.us/subject-matter-areas/counterterrorism/al-qaeda-urges-acquisition-of-ghost-guns-in-review-of-boulder-mass-shooting/

US: BILLIONAIRE DEEMED COMPETENT FOR TRIAL IN RECORD TAX-FRAUD CASE

On 6 July, BNN Bloomberg reported that 3 court-appointed experts determined that billionaire Robert Brockman is competent to stand trial in the largest tax-evasion case in US history, despite his claims of dementia, prosecutors said in a court filing.  The 80-year-old former CEO of software maker Reynolds & Reynolds would be tried on charges that he evaded taxes on $2 billion in income and laundered money.

https://www.bnnbloomberg.ca/billionaire-deemed-competent-for-trial-in-record-tax-fraud-case-1.1625859

FinCEN RULINGS ON DIGITAL ASSETS

On 6 July, Cole Schotz produced a table of FinCEN rulings, described as a non-exhaustive overview of some of the FinCen rulings concerned with digital assets and the cryptocurrency space.

https://www.jdsupra.com/legalnews/digital-assets-and-financial-crimes-3083689

ALBANIA: MAYOR AND 10 OTHERS ARRESTED OVER CORRUPTION AND ABUSE OF OFFICE

On 6 July, DTT-net reported that the Mayor of Lushnja district, 8 employees and 2 businessmen are arrested by police on charges of abuse of office and corruption related to tenders.

https://www.dtt-net.com/en/news/3428/39/Mayor-in-Albania-and-10-others-arrested-over-corruption-abuse-of-office

MADURO FINANCIER ALEX SAAB SEEKS IMMUNITY FROM EXTRADITION TO US

On 6 July, BNN Bloomberg reported that a Colombian businessman close to Venezuelan President Nicolas Maduro is appealing a US court decision to disregard his diplomatic immunity in a last-ditch effort to block his extradition to the US over corruption charges.  A Venezuelan envoy to Iran, he was arrested in Cape Verde, where his private plane stopped to refuel.

https://www.bnnbloomberg.ca/maduro-financier-saab-seeks-immunity-from-extradition-to-u-s-1.1625970

US: PHARMACEUTICAL SALES REPRESENTATIVE ADMITS HEALTH CARE FRAUD CONSPIRACY AND CONSPIRACY FOR MONEY LAUNDERING AND OBSTRUCTION OF JUSTICE

On 6 July, a news release from US DoJ advised that a pharmaceutical sales representative, Paul Camarda, 39, of New Jersey, has admitted he conspired to defraud New Jersey county health benefits programmes and conspired to engage in money laundering and obstruct justice.  He was a sales representative for a pharmaceutical company, but he created a side business called Dynasty Capital LLC to independently market medical products and services.  Camarda and his recruits caused more than $3.4 million in fraudulent claims.

https://www.justice.gov/usao-nj/pr/pharmaceutical-sales-representative-admits-health-care-fraud-conspiracy-and-conspiring

RULES ON CROSS-BORDER DATA TRANSFERS BECOME (A LITTLE) CLEARER

On 6 July, an article from White & Case LLP said that there had been a series of important developments affecting cross-border data transfers – on 21 June, the European Data Protection Board (EDPB) published its final, much-anticipated Recommendations on supplementary measures to ensure compliance with EU data protection laws; on 27 June, the European Commission’s new SCC came into effect; and finally, on 28 June, the European Commission adopted 2 adequacy decisions in respect of the UK.

https://www.whitecase.com/publications/alert/rules-cross-border-data-transfers-become-little-clearer

EXPANDING ISRAELI COURTS’ JURISDICTION OVER FOREIGN DEFENDANTS

An article from Barnea Jaffa Lando & Co on 6 July reported that the Tel Aviv-Yafo District Court had handed down an important precedential ruling which expands the identity of an authorised agent, i.e. the entity to whom a statement of claim may be served and that thus subjects a foreign defendant to the jurisdiction of the Israeli court.  The ruling was in a class action case relating to claims that updates to iPhone devices were causing the devices to slow down.

https://barlaw.co.il/client-updates/warning-border-ahead-expanding-israeli-courts-jurisdiction-over-foreign-defendants

BREXIT’S EFFECT ON JUDICIAL COOPERATION BETWEEN THE UK AND EU

On 6 July, an article from McDermott Will and Emery was concerned with questions as to the nature and extent of future judicial cooperation between the UK and the EU.  It notes that, on 23 June, 23 June 2021, the European Commission confirmed that the EU was “not in a position to consent” to the UK accession to the Lugano Convention.  It points out that the alternative for enforcement of cross-border court judgments, the Hague Convention, is not as comprehensive as the Lugano Convention, and where the Hague Convention does not apply, courts will apply local law to determine questions of jurisdiction and enforcement. 

https://www.mwe.com/insights/brexits-effect-on-judicial-cooperation-between-the-united-kingdom-and-european-union/

FINANCIAL CRIME IN THE MIDDLE EAST AND NORTH AFRICA (MENA)

Refinitiv has produced this report, detailing the results of a survey undertaken and involving risk and compliance professionals and business leaders across several sectors and in more than 13 countries in MENA.  It reveals, for example, that more than half of organisations in MENA are dealing with new risk challenges in the wake of the Covid-19 pandemic.  It is also noted that the shift to online has led to a surge in digital and contactless payments, and forced financial institutions to hasten the implementation of their digital transformation plans.  The notable trends identified include organisations in the region struggling with the pace of regulatory change; a lack of awareness of the expansion of third-party risk; and progress made in updating risk and compliance policies is under threat due to the accelerated pace of change.

https://media-exp3.licdn.com/dms/document/C4D1FAQG_IhYKYxCyNg/feedshare-document-pdf-analyzed/0/1625588632603?e=1625706000&v=beta&t=t1Rag4C5x1-KSBv_3QtVUMPZVKmLm8Uw0nHkDjbCH8Y

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and 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

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