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.