Panama Covid-19 update – another 185 new cases reported today, and 6 new fatalities. Active cases are down to 3,573, with 55 in ICU and 226 in other wards.

Back in the office at home but (as you might be able to tell) still having “technical” problems, i.e. my favourite PC remains u/s and goes to some Chinese wizards tomorrow in the hope of a fix. Mind you, though not having to use the laptop now (I am not a laptop person), using a new or different computer, and trying to get everything working like before, is always a pain.

26 September 2021

On 25 September, the Economic Standard reported that the investigation involves a Chinese vessel that allegedly carried equipment for making rocket motors for missiles, a cylindrical shell Autoclave.  The Da Cui Yun was stopped in February 2020 after the dual use material was found during inspection.



On 7 September, the Bulletin of the Atomic Scientists published an article which comprises a comprehensive review of a new book, described as an impressive study of technological struggle and ultimate failure, and of plutonium’s journey from regard as a vital energy asset to an eternally troublesome waste.  At the end it points out that, even if all civil reprocessing ceased tomorrow, the experiment would have bequeathed the onerous task of guarding and disposing of over 300 tons of plutonium waste, and considerably more when US and Russia’s military excess is added in. Lacking ready solutions, most plutonium waste will probably remain in store above ground for decades to come, risking neglect. How to render this dangerous waste eternally safe and secure is now the question.



On 21 September, the Evening Standard reported that a karate teacher, Stephen Anthony Clarke Gostling, 56, has been jailed for 4 years after selling fake DVD and counterfeit foot care products. The court heard Gostling had used 22 eBay accounts, 28 PayPal accounts, and 31 bank accounts, which he set up using around 30 different names to run his business from home.



An article from Coda on 24 September consists of an interview with the author of a new book – “Information at War: Journalism, Disinformation, and Modern Warfare”.  He charts the role of information in conflicts, including WW2, Vietnam, and the war in Syria amid a rapidly shifting media ecosystem.  The discussion involves how digital tools have influenced the landscape of war and how the public could take the issue more seriously.



On 26 September, The Nation reported that a court had postponed the corruption trial of the younger brother of ousted President Abdelaziz Bouteflika, who died this month.  Said Bouteflika, 63, was detained in May 2019, a month after his brother quit office following mass protests.  He was sentenced to 15 years in prison for “plotting” against the army and the state, but a retrial in January cleared him of those charges – however, he remains in custody on corrution charges.


If you need car insurance, be wary of heavily discounted prices on the internet or cheap prices you are offered directly. They’re most likely fraudsters using a method known as ‘ghost broking’.


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


A paper from Daniel Salisbury dated 5 July is now freely available online and says that North Korea frequently uses diplomatic missions, diplomats and intelligence officers in its WMD proliferation and arms trafficking networks. The paper identifies a number of trends surrounding the use of North Korean missions – including the types and locations of missions featuring in specific types of proliferation and arms dealing activities, the prominence of larger missions and use of third country and regional hubs.  It argues that the persistence of these assets in the DPRK’s networks is largely a result of convenience and diplomatic immunity.  The paper concludes by recommending further action to counter these assets while arguing that the phenomenon will continue to be a challenging feature of North Korea’s proliferation and arms trading activities.



The GFIA has a number of useful and/or interesting papers on its website, including the following –

Position paper on the application of AML to general insurance

This Paper from 6 May concludes that there is no evidence to justify extending AML/CFT rules to general insurance.


Comments on the FATF public consultation on the draft Amendments to Recommendation 24

This paper from 24 August contains the GFIA response to possible changes to the Recommendation on transparency and beneficial ownership.


Response to IAIS consultation on draft revised Application Paper on Combatting Money Laundering and Terrorist Financing

This paper from 16 July contains the GFIA response to the draft from the International Association of Insurance Supervisors (IAIS) of 17 May on how money laundering and terrorist financing can occur within the insurance sector, and on measures to mitigate the associated risks. 




This non-binding Recommendation of 15 September provides a framework to help research organisations and researchers, research managers and compliance staff to identify, manage and mitigate risks associated with dual-use export controls and to facilitate compliance with the relevant EU and national laws and regulations. It also provides a framework to support Member States competent authorities in developing specific outreach programmes, as well as in their assessment of risks related to research activities, in the exercise of their responsibility for deciding on export authorisations for dual-use items.  It includes a section of helpful FAQ.


Conflict Arms Research has produced this report saying that, between February 2019 and July 2021, CAR investigators worked in Afghanistan to document illicit weapons in the country.  It says that very little attention has been paid to the group’s long-standing ability to exploit weaknesses in US and Afghan government controls over weapon supplies. Taliban access to weapons and ammunition intended for Afghan security forces is not new, but it has expanded significantly over time and was less reliant on external sources than might have been supposed.  It warns that recent events in Afghanistan highlight the need to address persistent challenges and weaknesses in the US supply of weapons, ammunition, and military equipment to other government-backed forces in other countries affected by armed conflict and terrorism.  This report is the first in a series that will draw out key findings from CAR’s Afghanistan data set. It explores the long-standing capacity of the Taliban and other armed actors in Afghanistan to access weapons that had been supplied by the US and NATO to Afghan forces, and considers the systemic challenges that have enabled weapon diversion from national custody in the past. It focuses on small arms and light weapons and does not delve into issues around the seizure of aircraft or other equipment.



Panama Covid-19 update – today saw 257 new cases reported and 4 fatalities taking the death total to date to over 7,200, at 7,201. However, there are 3,670 active cases, with now only 55 in ICU and 224 in other wards.

As you can probably guess, still working off one of the (slow) laptops…and though back in the office still without a working PC – haven’t fired up the other,older one to use as a back-up (can’t face the potential frustration if that too starts playing up!)…guess what I will be doing probably all day tomorrow (Sunday)?

25 September 2021

Cuba: GAESA: (is) Its Business Money Laundering, Not Managing Remittances

A critical article in the Havana Times on 24 September by Cuban economist Emilio Morales is said to provide an insider’s look at the operations of GAESA, the military organisation that controls the lion’s share of the Cuban economy. 


Jamaica: Real Estate Board Clamps Down On Dealers Non-Compliant With AML Survey

The Jamaica Information Service reports that the Real Estate Board (REB) is clamping down on dealers who fail to complete the risk assessment survey, which is part of its AML efforts.  13 real estate dealers’ licences were suspended earlier this month for failure to complete and submit the Board’s Anti-Money Laundering Risk Assessment Survey Questionnaire issued in 2020.  REB is a designated competent authority under the Proceeds of Crime Act, covering non-financial businesses and professions that are identified as being vulnerable to money laundering or terrorist-financing activity.


UK: plans to introduce a new economic crime levy will see smaller law firms exempted

On 24 September, Insider UK reported that pressure from Law Society Scotland is said to have resulted in law firms with a turnover of less than £10.2 million will be exempted – which is said to include some 97% of Scottish law firms.


Shipping: Limitation Conventions and Forum Non Conveniens

On 23 September, an article in Forwarder Law looked at this subject and how different countries treat maritime claims. It starts by explaining that, when a shipowner is sued for personal injury or damage to property in connection with the operation of their ship, the maximum amount that a claimant can be compensated is limited in many jurisdictions around the world by either international conventions or domestic laws.  The differences in maritime regimes across jurisdictions raise complex legal and commercial considerations that need to be strategically navigated by both shipowners and claimants.  Significantly, depending on which regime applies, and a nation’s own domestic laws, the maximum compensation amount that the shipowner can pay to the claimant can significantly differ.  It also considers a case involving litigation which involves the South Korean, Japanese and Hong Kong jurisdictions.



Law firm HFW has provided an update on its June 2020 article, which referred to the Government’s plans to require litigation funders to obtain an Australian Financial Services License (AFSL) and to be subject to the managed investment scheme regulatory regime.  This the author of the article supported as a means of increasing the transparency of litigation funding arrangements, which could potentially alleviate the distrust of funders by corporates and insurers in Australia.  A lot is said to have happened since then.


IMF says Australia should further strengthen its AML/CFT framework

On 23 September, the IMF published a Staff Concluding Statement of the 2021 Article IV Discussions containing agreed findings and recommendations.  It includes a recommendation that Australia’s AML/CFT framework should be further strengthened by expanding coverage to relevant non-financial and business professionals.


San Marino: IMF says more action needed on AML/CFT

On 24 September, the IMF published a Staff Concluding Statement of the 2021 Article IV Discussions containing agreed findings and recommendations.  These include saying that there has been significant progress in improving the AML/CFT framework, although further actions are needed. A second national risk assessment was completed in 2019 and mitigation measures are being implemented with the recent MONEYVAL assessment acknowledging progress in several areas. However, challenges remain on some issues related to preventive measures and customer due diligence, transparency of legal persons and legal arrangements, and money laundering investigations.


UK: Couple in charge of supplying power to 100,000 homes face trial for fraud and aggressive selling

On 25 September, the Mail on Sunday reported that a couple in charge of a firm supplying power to more than 100,000 homes are facing fraud charges.  Keith and Maria Bastian, who run energy supplier Outfox The Market, are awaiting trial on 11 charges of fraud and commercial malpractice linked to separate companies called Fischer Future Heat and Premier Radiators.  It is said that there are allegations of fraud and aggressive sales practices which involved ‘harassment, coercion or undue influence’ committed with ‘consent, connivance or was attributable to some neglect’.


Human trafficking, migrant smuggling, still significant threats in Asia

On 12 September, UN News published an article saying that human trafficking and the smuggling of migrants are going to remain significant threats to human security, according to a trafficking and migrant expert working in the Middle East and Asia region for the UN Office on Drugs and Crime.  The themes of the article include “trafficking is not smuggling” – and that that human trafficking and migrant smuggling are actually quite different, although they’re very often conflated, especially in the news media.  It also says that the understanding of the phenomenon of human trafficking has grown, and it is now recognised that trafficking is not just about sex but includes other ways that people can be exploited across all kinds of sectors of the economy – for example, in construction, agriculture, or inside factories, in fact, anywhere where you find a lot of low-skilled, low-paid manual labourers. 


WHO report on novel and emerging tobacco products

On 23 September, TJI reported that the new report that looks at a range of issues, from the harm caused by toxic ingredients and nicotine exposure to how new nicotine and tobacco products are aggressively marketed to potential users.  Such products include electronic nicotine delivery systems (ENDS), electronic non-nicotine delivery systems (ENNDS) and heated tobacco products (HTP).


Russian Foreign Minister says the military junta in Mali has turned to “private Russian companies” to fight against Islamist insurgents

On 25 September, Rferl reported that Russian Foreign Minister Sergei Lavrov says the military junta in Mali has turned to “private Russian companies” for help in its fight against Islamist insurgents in the Western African country.  The move comes despite warnings to Mali’s military junta by the EU, France, and Germany against hiring the Russian private security firm Vagner (which itself would technically be illegal in Russia itself).


Interview with Former Brazilian President Luiz Inácio Lula da Silva

On 25 September, CGTN America released what it described as a “wide-ranging” interview with the former President.  In March, the Brazilian Supreme Court annulled the corruption convictions and another court ruled the 75-year-old is now free to run in next year’s presidential election.  In the interview Lula talked about his likely candidacy, addressed climate change, relations with China and the handling of the COVID-19 pandemic by his rival, current President Jair Bolsonaro.


Mexican Government Seeks Arrest of Top Scientists in Funding Dispute

On 25 September, the Wall Street Journal reported that prosecutors have asked a federal judge to jail 31 scientists on charges of organised crime and money laundering.  This is said to be partof a growing dispute between the leftist government and the country’s leading academics and universities.  A judge has twice rejected the petition to jail the scientists, saying the attorney general’s office hasn’t presented enough evidence of wrongdoing. However, the government said it would resubmit its request for arrests.



How much compliance training is enough?

A post on the always interesting FCPA Blog posed this question on 23 September.  It says that training, and appropriate training, is obviously required, but what we don’t know, however, is how much training is enough.  The poster suggests the Kaufman 20-hour rule, and says that he hopes someone using it now, or willing to give it a try, will let the rest of us know how it’s going.


Container ships now piling up at anchorages off China’s ports

On 24 September, American Shipper reported that there are over 60 container ships full of import cargo stuck offshore of Los Angeles and Long Beach, but there are more than double that — 154 as of 24 September — waiting to load export cargo off Shanghai and Ningbo in China, and there are now 242 container ships waiting for berths countrywide.  It suggests that congestion in Chinese ports that slows the flow of exports is bad news for US importers but it could temporarily alleviate pressure on the ports of Los Angeles and Long Beach.


Trade and customs in the UK beyond Brexit

On 23 September, Clifford Chance published a briefing saying that, for the first time in 48 years, importers and exporters must grapple with a UK trade and customs administration entirely independent from the EU, including new domestic regulations, international trade agreements and, in some cases, government agencies.  The briefing considers the legal framework and the international one, trade defence investigations, customs duties, trade barriers, export controls, financial and other sanctions measures and trade embargoes; plus what it describes as “current trends”.


North Korean Sanctions Evasion Techniques

The RAND Corporation has published this report saying that the UN imposed increasingly restrictive sanctions on North Korea after each of the six nuclear weapons tests that it conducted between 2009 and 2016.  However, enforcement of those sanctions has been mixed.  It describes the multilateral arms control mechanisms available and sanctions regimes imposed on North Korea to contain its proliferation activities and bring that country back into compliance with international law.  It details the various entities involved in North Korean sanctions evasion activities and proceeds to use case studies to illustrate North Korea’s principal sanctions evasion techniques in 4 general areas of sanctions evasion activity: hard-currency generation, restricted and dual-use technology acquisition, covert transport, and covert finance. It says that 4 types of entities are involved in North Korea’s sanctions evasion: North Korean government officials accredited to North Korea’s embassies, North Korean overseas workers, front and shell companies, and trusted third-party intermediaries.  North Korea is said to “active” in 38 African countries, and has aided or fuelled ballistic missile programmes in the Middle East.


Preventing North Korean Proliferation Activities

On 23 September, the RAND Corporation published an article saying that the UN has raised concerns about the widespread presence of North Korean nationals in Africa and their involvement in prohibited activities. For example, it says, North Korea engages in proliferation related activities in 38 of 54 African countries, and North Korea proliferates weapons to 13 African countries. RAND’s National Security Research Division assisted the US Department of State in producing guides, other supporting materials that explain why North Korean proliferation activities matter, and steps that can be taken to mitigate those activities. The project’s first 2 reports are available for download now. A third report on strategic trade controls is forthcoming.

North Korea sanctions: Countering DPRK Proliferation Activities


How does North Korea Evade Sanctions?


UK Government report says that North Korean diplomats engaging in illicit financing activities

On 25 September, Yonhap News reported that the recent UK National Risk Assessment of proliferation financing says that North Korean Embassies and diplomatic personnel are engaging in illicit financing activities to fund the country’s nuclear and other destructive weapons activities.  It is also said that the North Korean Embassy in London “may pose an inherent” risk, as not all banks in the country may be attuned to UN sanctions that restrict such activities.