Panama Covid-19 update – on a small island in the Pacific, where there are no local (known) Covid cases, but nevertheless face masks are still required (by law). In the greater Panama, 324 new cases have been reported and 9 new fatalities (quite a rise on recent numbers); with 3,558 active cases, as this number continues to fall, wih 61 in ICU and 236 in other wards.

Note – as I am in this small island, albeit with better than expected wi-fi, one is still reliant on this ageing laptop (and remembering passwords); so service might not be as prompt or complete (e.g. nice photos and graphics) as usual. Hopefully, things will be better in due course, when we return home, but the desktop PC I normally use was refusing to fire up this morning, so who knows. I have another, plus the laptop(s), but one gets used to the orutine and usual, and any disruption is annoying and distracting…


Sanctioned tankers, cargo ships spotted at North Korean port of Nampho

On 23 September, NK Pro reported that at least 19 vessels have appeared in or around the key North Korean port of Nampho this month, including several UN-sanctioned oil tankers.  It says that their appearance suggests DPRK’s oil trade is ramping up, including by illicit means, amid low official imports.


Man convicted of terrorism financing led ‘unremarkable’ life in Ireland

On 16 September, the Irish Times reported on the conviction of an Algerian national, found after Ireland joined the EU-wide Schengen Information System database.  The man,  in his early 50s, fled to Ireland  in 2000, shortly after being prosecuted for facilitating Islamic terrorism in Marseille and sentenced in absentia.


UAE puts 6 Nigerians with ties to Boko Haram on terrorist list

On 14 September, the Nigerian Guardian reported that, in April 2019, the Abu Dhabi federal court of appeal sentenced the men for setting up a Boko Haram cell in the UAE to raise funds and material assistance for the insurgents in Nigeria.


Russia has renewed its import ban on agricultural products, raw materials and food from the US, EU, Canada etc

On 23 September, the EU Sanctions blog reported that the ban on agricultural products, raw materials and food, (including beef, pork, fruit, vegetables, fish and dairy products) from the US, EU, UK, Canada, Australia, Norway, Ukraine, Albania, Montenegro, Iceland and Lichtenstein had been renewed to 31 December 2022.  It had originally been imposed in response to foreign sanctions following the takeover of Crimea.


Kenya Removed From Piracy Red List

On 20 September, Dryad Global reported that Kenya maritime waters within the Indian Ocean had been removed from the piracy red list, 12 years after it was designated a high-risk area (HRA).  The announcement by the IMO will save Kenya and East Africa millions in insurance and other security expenses, and could open up Kenya’s ports for more business.



A Technical Brief from Conflict Arms Research reported on how a CAR field investigation team disassembled a recovered AM-50 anti-materiel rifle and comprehensively documented its component parts.  The resulting report provides a technical analysis of each of its components, highlighting key identifying features and yielding new insight into Iran’s weapon manufacturing practices.


Guernsey to introduce stricter compliance measures for CRS and FATCA reporting

On 23 September, STEP reported that all Guernsey financial institutions will soon have to register on the Revenue Service’s information gateway online reporter (IGOR) system, whether or not they have reporting obligations under the OECD Common Reporting Standard (CRS) or the US FATCA.  As well as registering, all FIs will be required to submit an annual validation either confirming that the information it provided remains complete and correct or providing amended information. The changes are amongst measures contained in a new law intended to demonstrate Guernsey’s commitment to a ‘robust and effective compliance framework underpinning its regime of automatic exchange of information for tax purposes’.


OECD publishes compilation of 2021 peer review reports

On 22 September, Accountancy Daily reported that the OECD had published Country-by-Country Reporting – Compilation of 2021 Peer Review Reports – Inclusive Framework on BEPS: Action 13.



On 22 September, a Policy Paper from the Home Office advised that an MoU between the governments of the UK and Moldova facilitates the return of funds in relation to Luca Filat, which were confiscated in November 2019. The MoU is said to ensure the return of £456,068.38 by the NCA to Moldova, which will be used to the benefit of the people of Moldova, in support of social assistance projects. There will be monitoring of the returned money by Keystone Moldova, a Civil Society Organisation, which is also a provision related to transparency and monitoring within the MoU.


UK: man ordered to pay £213,000 after selling students places at fake Bath college

On 23 September, ITV News reported that Sanketkumar Patel, 38, a convicted money launderer has been ordered to pay back more than £200,000 after he sold foreign students places at a non-existent college in Bath.  He was part of a 2015 scam which saw a number of foreign nationals pay money to criminals advertising a fake college purporting to be Prior Park College. The fake college’s business course enabled foreign nationals to apply for visas to study in the UK.


US Allows Ukrainian Tycoon To Sell Texas Property It Froze

On 23 September, Rferl reported that the US is permitting a company owned by Ukrainian tycoon Ihor Kolomoyskiy to sell a Texas building the government froze as part of a civil money-laundering case so that it can pay down the property’s back taxes and other debts.  He faces accusations related to Kyiv-based Privatbank and the DoJ sued to seize 3 buildings, 1 each in Ohio, Kentucky, and Texas. Kolomoyskiy denies the accusations and has filed for arbitration.


Regulator SRA launches investigations into 10% of firms checked for AML compliance

In its 24 September edition, Legal Futures reported that more than 10% of law firms whose compliance with AML rules was checked by the Solicitors Regulation Authority in the last year have been referred for investigation.  8 of 69 firms visited virtually by the SRA in the year to April 2021 were not compliant with the AML regulations and referred for investigation.  Only 16 were fully compliant and the rest partially compliant.  The regulator also conducted 168 desk-based reviews in the year – the majority were partially compliant, but 19 were referred for investigation.


Mastermind of Zimbabwean Bitcoin Pyramid Scheme Vanishes With $6 Million

On 3 September, Bitcoin.com reported that an individual by the name of Martin Mhlanga, who is said to be the mastermind behind the Cryptoshares bitcoin pyramid scheme, has disappeared along with over $6 million in investor funds. In addition to Mhlanga’s disappearance, the individuals thought to be managing Cryptoshares’ social media channels have similarly vanished.



The Global Initiative Against Transnational Organised Crime has produced a Black Market Brief about the trade in live cheetahs, mainly traded to serve as pets for royal and wealthy families in the Middle East.  It notes that a few countries allow the legal export of cheetahs, mainly in southern Africa, but there are irregularities in the system.  Approximately 300 are smuggled out of East Africa and the Horn of Africa each year.


Investigating Antiquities Trafficking

On 20 September, the Global Investigative Journalism Network published an article saying that the illicit trade in antiquities is a form of transnational crime that connects the theft at heritage sites to the elite world of the global art market, often via a web of organised crime.  There is a strong demand for antiquities within North American, European, and Asian markets, and these markets inspire the removal of cultural objects from lower income countries.  There is also a grey market, said to be infiltrated by organised crime.  It goes on to say that, unlike antiquities trafficking, art theft from institutions is rarer and riskier, with fewer opportunities for profit. 


Albania: former top prosecutor jailed on corruption charges

On 22 September, Euronews reported that the former chief prosecutor of Albania has been sentenced to 2 years in prison for hiding money involved in illegally owned properties.  Adriatik Llalla, who served as Albania’s prosecutor general during 2012-2017, also had his own property confiscated by judges and is barred from holding any public post for 5 years.


Florida Businessman and CFO of Russian Natural Gas Company Arrested on Tax Charges Related to $93 Million Hidden in Offshore Accounts

A news release from US DoJ on 23 September advised that a court had returned an indictment against a businessman accused of not disclosing his substantial offshore assets, failing to report substantial income on his tax returns, failing to pay millions of dollars of taxes and submitting a false offshore compliance filing with the IRS in an attempt to avoid substantial penalties and criminal prosecution.  A certified public accountant (CPA) in the US and Russia, Gyetvay allegedly became the chief financial officer of a large Russian gas company, and from 2005 allegedly used Swiss bank accounts to hide assets.


JPMorgan faces oil bribery probe in Brazil

On 22 September, Yahoo Finance claimed an exclusive, reporting that Brazilian authorities are investigating whether JPMorgan Chase & Co played a role in an alleged bribery and money laundering scheme that dated back to 2011 and involved state-run oil company Petrobras.


Isle of Man confirms removal of the Baghdad Stock Exchange from Iraq sanctions lists

On 23 September, the Isle of Man confirmed that, following action by the UN and UK, the BAGHDAD STOCK EXCHANGE had been removed from sanctions concerning Iraq.


US: Corporate Transparency Act Expands AML Burden Beyond Banks to Business Customers

On 23 September, the National Law Review published Part 2 of a feature on the CTA, considering the background and history of the AML “burden” on banks in the US, and looking at how the new legislation will shift some of the collection burden from banks to reporting companies.  It notes that regulations are due by 1 January.


Kenya: Sudanese Minister of Cabinet Affairs Cleared of Money Laundering Charges 

On 22 September, kahawatungu.com reported that Sudanese Minister of Cabinet Affairs Martin Elia Lomuro has been cleared of money laundering charges by a Nairobi court.  A case was filed by the Kenya Assets Recovery Agent (ARA) claiming that a Co-operative Bank account had made several suspicious transactions.



On 23 September, a news release from FinCEN advised that it had launched a public consultation on a range of questions related to the implementation of amendments to the Bank Secrecy Act (BSA) regarding the trade in antiquities. It says that it strongly encourages members of the antiquities industry, law enforcement, civil society groups, and the broader public to submit written comments.  The consultation runs to 25 October.


Top El Salvador Officials Embroiled in Food Aid Theft Investigation

On 21 September, Insight Crime claimed that an abandoned investigation into alleged food aid theft by officials in the administration of El Salvador President Nayib Bukele has provided the first clear evidence that the government has systematically abandoned corruption probes involving its functionaries.  Involved was an incomplete Attorney General’s investigation into the theft of some $1.6 million of food products destined for poor people during the coronavirus pandemic.  It claims that a minister diverted food from the Public Health Emergency Program (Programa de Emergencia Sanitaria – PES) and then later sold it to a businessman previously accused of smuggling.  Other officials in the administration were also under investigation for possible involvement in the scheme.


Malta: Landmark Money Laundering Judgment As Freezing Order Request For Former Pilatus Bank Official Denied

On 23 September, Lovin Malta reported that Pilatus Bank’s former head of compliance and legal Claude-Ann Sant Fournier was charged with money laundering along with the bank itself.  The prosecution, as it typically does in these cases, asked the court to freeze her assets, as well as those of the bank.  She argued that the only funds found her account were deposits from her salary, and therefore the request to freeze her money amounted to a “vexatious” request.  The Magistrate ruled in favour of the defence and the Attorney General’s Office promptly filed an appeal in front of the Court of Criminal Appeal, and the Court of Appeal has now upheld the decision. This is said to be the first time a Maltese court has declined a freezing order against someone charged in their personal capacity and the decision confirmed on appeal. 


Mexican Ex-Security Minister Accused of Stealing $250 Million After Leaving Government

On 23 September, US News reported that a former Mexican security minister implicated in a money laundering scheme is accused of stealing $250 million in public funds after leaving his government job.  He allegedly hid the money stolen from the treasury in bank accounts in Barbados and the US between 2012 and 2018.  Mexico’s FIU has launched its first lawsuit in the US, in Miami against former security chief Garcia Luna and a network of 39 companies and trusts run by him and his associates to hide assets.


UK: National risk assessment of proliferation financing

On 23 September, HM Treasury published the first comprehensive assessment of proliferation financing risk in the UK. Using evidence from government and non-government partners, sets out the key proliferation financing risks and vulnerabilities in the UK.



A Commentary from War on the Rocks on 23 September was concerned with Chinese business activities in Mozambique, saying that frequently local elites find it in their interest to enable these firms’ engagement in illegal business practices.  It gives as an example how local officials in the Cabo Delgado district of Montepuez described how Chinese timber traders flouted local laws with impunity.  It says that illegal Chinese business practices in Cabo Delgado are making the province less safe, with Cabo Delgado home to an Islamist insurgency.  It argues that Cabo Delgado is an acute and instructive example of the nexus among insecurity, corruption, and corporate malfeasance that may arise again unless Chinese officials take greater action.


ISO releases its first framework for how companies can establish good governance practices

On 22 September, the Wall Street Journal reported that the international standards setter has thrown its weight behind a push for companies to go beyond the traditional ideas of good governance to include more environmentally and socially conscious models.  The standard, which is meant to provide a common language that will transcend national borders, arrives amid growing concerns about climate change and an investor focus on sustainability.


US Lifts Sanctions On Mexican Soccer Star Rafa Marquez

On 22 September, Kharon reported that OFAC had removed its sanctions on Mexican soccer star Rafa Marquez, as well as his companies and foundations.  He was designated in August 2017 over what was then called his “longstanding” relationship with Mexican national Raul Flores Hernandez, saying he’d acted as a front person for Flores’s drug trafficking organisation and held assets on his behalf.