THINGS YOU MAY HAVE MISSED – OCTOBER 31

Panama Covid-19 update – the effect of the pandemic on the economy of Panama are being revealed. Not surprisingly, the GDP fell sharply between 2019 and 2020, by 17.9%. The most affected activity was construction whose GDP fell no less than 51.8%. This was followed by real estate activities whose GDP fell 30.8%. The manufacturing industry GDP fell -22%.

On the other hand, this coming week is a week of holidays, beginning what is holiday month in Panama. The 2, 3, 4 and 5 November are holidays, but then we have to wait until 10 November for the next. However, 2 November, as “Day of the Dead” means alcohol sales and loud music is banned.

Meanwhile, after a couple of days without a fatality, 2 were reported today, alongside 130 new cases. There are now 2,172 active cases, with 34 in ICU and 124 in other wards.

31 OCTOBER 2021

PANAMA WARNS OF AN INCREASE IN DRUGS IN CONTAINERS TO EUROPE – 20 TONS SEIZED SO FAR THIS YEAR

On 31 October, an article in Deutsche Welle said that Panama has seized so far this year more than 20 tons of drugs hidden in containers destined for Europe, a figure that far exceeds what was seized in 2020.  So far in 2021, Panama has broken all its annual records in drug seizures, despite the pandemic and the fact that there are still 2 months to go before the end of the year.  This came as the authorities reported the seizure of another nearly 3½ tons of cocaine hidden in containers inside a vessel that had arrived from Chile and was heading to the Netherlands.

https://www.dw.com/es/panam%C3%A1-alerta-sobre-un-incremento-de-droga-en-contenedores-hacia-europa/a-59676464

https://es.euronews.com/2021/10/31/panama-decomisan-casi-3-5-toneladas-de-droga-con-destino-a-europa

US SENATORS INTRODUCE BILL TO CREATE SANCTIONS LOOPHOLE FOR INDIA

On 31 October, Taiwan News reported that Republican senators have introduced a Bill proposing to make India exempt from sanctions for purchasing weapons systems from Russia.  It would exempt 3 members of “the Quad” — Australia, Japan, and India — from US sanctions passed in 2017.  This comes as the Biden Administration deliberates on whether to impose sanctions over India’s 2018 purchase of Russian S-400 surface-to-air missile systems.

https://www.taiwannews.com.tw/en/news/4330858

CAYMAN ISLANDS – 6 FINANCIAL INSTITUTIONS UNDER INVESTIGATION FOR MONEY LAUNDERING

On 30 October, Loop reported that the Financial Investigations Division (FID) had said that at least 6 institutions were being looked at, as they are not in compliance with the law and their operations “may be used to facilitate money laundering”.  However, the FID principal director also said that said there was “generally” a high level of compliance among financial institutions to provisions of POCA.  He was addressing a FID press conference held in observance of National Anti-Money Laundering Day.  He also said that, of the 17 cases completed this far in 2021, 8 involved persons who were convicted for drug trafficking activities and 4 were for lottery scamming activities.  5 court orders were granted in 2021, amounting to over J$33 million in assets.

https://cayman.loopnews.com/content/6-financial-institutions-under-probe-money-laundering-fid

2 DIGITAL CURRENCY EXCHANGES UNDER PROBE IN SWEDEN OVER AML COMPLIANCE

On 31 October, Coingeek reported that the Financial Supervisory Authority (FI) said it had picked 2 leading exchanges – Safello and Goobit – to learn more about how firms were putting the law into practice when dealing with customers.

https://coingeek.com/2-digital-currency-exchanges-under-probe-in-sweden-over-aml-compliance

TRADE FINANCE FIRMS MUST STRENGTHEN AML CONTROLS TO MEET NEW FCA REQUIREMENTS

On 30 October, Finance Magnates reported that trade finance organisations in the UK should expect greater surveillance and monitoring from the FCA in the coming months and years ahead. It said that a “Dear CEO” letter from the FCA signalled a commitment to a more proactive approach to combating financial crime and money laundering within the trade finance space.  It is said that the FCA had found multiple areas of concern, including an insufficient focus on identifying and assessing financial crime risk factors. The FCA also noted inadequate evidence of migrating controls and felt that genericized assessments at the client risk level failed to cover the different risk exposures in the trade finance client relationship. The article says that transactions between parties must be appropriately monitored, even after the trade finance was approved.

https://www.financemagnates.com/institutional-forex/regulation/trade-finance-firms-must-strengthen-aml-controls-to-meet-new-fca-requirements/

AUSTRAC STATEMENT ON DE-BANKING

On 29 October, s a statement from AUSTRAC says that over the past decade, the range of businesses impacted by a loss or limitation of access to banking services has expanded.  Money transfer (remitters), digital currency exchanges, not-for-profit organisations (NPO) and financial technology (FinTech) businesses are disproportionally facing bank account closures.  However, AUSTRAC says that it expects businesses operating in non-banking sectors to understand and meet their AML/CFT financing and other regulatory obligations.   AUSTRAC also says that it considers that, with appropriate systems and processes in place, banks should be able to manage high risk customers, including those operating remittance services, digital currency exchanges, not-for-profit organisations (NPO) and financial technology (FinTech) businesses.

https://www.austrac.gov.au/news-and-media/media-release/austrac-statement-2021-de-banking

FinCEN RENEWS REAL ESTATE GEOGRAPHIC TARGETING ORDERS FOR 12 METROPOLITAN AREAS

On 29 October, a news release from FinCEN advised the renewal of its Geographic Targeting Orders (GTO) that require US title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.  The purchase amount threshold remains $300,000 for each covered metropolitan area.  The renewal runs to 29 April and cover certain counties within the following major US metropolitan areas:  Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle. 

https://www.fincen.gov/news/news-releases/fincen-renews-real-estate-geographic-targeting-orders-12-metropolitan-areas

3 COMMON BLOCKCHAIN ANALYSIS MISTAKES THAT IMPEDE CRYPTOCURRENCY INVESTIGATIONS

On 29 October, a post from Chainalysis said that as cryptocurrency addresses are pseudonymous, this means investigators need reliable data attributing those addresses to services and organisations in order to draw actionable insights from blockchains’ transaction records. It examines 3 of the most common mistakes investigators can make in cryptocurrency investigations when faulty or incomplete blockchain data leads them astray: failure to identify mixers; attempting to trace funds through a service; and failure to identify nested services and merchant services providers. 

https://blog.chainalysis.com/reports/common-blockchain-analysis-mistakes-cryptocurrency-investigations

AUSTRALIA: PANDEMIC-FUELLED WAVE OF ILLEGAL FISHING BOATS PROMPTS CALL TO DIVERT BORDER FORCE RESOURCES

On 27 October, ABC News reported that a defence expert says resources need to be bolstered to block an influx of illegal foreign fishing crews stripping marine life in Australian waters during the pandemic.  In 2018-19 just 5 boats were intercepted and 4 the following year, but that figure jumped up to 85 boats in 2020-21, and in the past 3 months alone more than 100 boats have been intercepted.

https://www.abc.net.au/news/2021-10-28/pandemic-fuels-wave-of-illegal-fishing-boats/100560412

https://www.cfr.org/in-brief/lava-jato-see-how-far-brazils-corruption-probe-reached

NUCLEAR WEAPONS PROLIFERATION IN THE EYES OF 3 INTELLIGENCE COMMUNITIES

An article dated 22 October in the Intelligence and National Security journal compares how intelligence agencies have performed in assessing the nuclear proliferation intentions of other countries.  It appraises the accuracy of American, British, and West German intelligence proliferation assessments of India and Argentina.

https://www.tandfonline.com/doi/full/10.1080/02684527.2021.1992153?src=&#.YXa-RkBA-zo.twitter

OECD: CARBON PRICING IN TIMES OF COVID-19

The OECD has produced on 27 October this report which says that carbon pricing is a powerful tool that can help countries meet climate objectives and support a green recovery.  This report takes stock of how carbon prices have evolved across G20 economies1 between 2018 and 2021. It estimates carbon prices resulting from carbon taxes, emissions trading systems, and fuel excise taxes.  It points out that G20 countries account for approximately 80% of global GHG emissions.

https://www.oecd.org/tax/tax-policy/carbon-pricing-in-times-of-covid-19-what-has-changed-in-g20-economies.htm

WHITE-COLLAR CRIME 2021 GUIDE FOR SWITZERLAND 

On 26 October, Mangeat in Switzerland made available the text of this Chambers Global Practice Guide. It covers the legal framework; enforcement; white-collar offences; defences and exceptions; and the burden of proof and assessment of penalties.

https://mangeat.ch/wp-content/uploads/2021/10/WhiteCollarCrime_Switzerland-2021_LP_MANGEAT.pdf

HISTORICAL DOCUMENT: THE FinCEN ARTIFICIAL INTELLIGENCE SYSTEM: IDENTIFYING POTENTIAL MONEY LAUNDERING FROM REPORTS OF LARGE CASH TRANSACTIONS

This 1995 paper produced for FinCEN in 1995 was concerned with the FinCEN Artificial Intelligence System (FAIS) which links and evaluated reports of large cash transactions to identify potential money laundering.  It had been in operation since March 1993.

https://www.aaai.org/Papers/IAAI/1995/IAAI95-015.pdf

https://www.ojp.gov/ncjrs/virtual-library/abstracts/fincen-artificial-intelligence-system-identifying-potential-money

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.buymea3coffee.com/KoIvM842y

OTHER THINGS YOU MAY HAVE MISSED – OCTOBER 30

Panama Covid-19 update – as yesterday’s figures appear to have gone missing from this site, here they are again – 201 new cases and 1 new fatality; 2,183 active cases, with 38 in ICU and 136 in other wards.

Today saw another day without a fatality, but with 136 new cases. Active cases total 2,174, with 35 patients in ICU and 135 in other wards. Another 89 people are in the so-called hospital hotel rooms.

30 OCTOBER 2021

PANAMA: MONITORING REPORT ON CORRUPTION

On 26 October, the Citizen Observatory of Corruption of the Americas (OCC), presented the results of the Monitoring Report on compliance with commitments made by Panama at the VIII Summit of the Americas in 2018.  This revealed that Panama has not effectively fulfilled the commitments established at the Lima Summit. It notes that one problem is that there is no public mechanism officially responsible for reviewing compliance with the commitments.  The OCC is a combined effort between the Citizen Forum of the Americas (FCA), the Latin American and Caribbean Network for Democracy (Redlad), national chapters of Transparency International (TI) in Latin America and more than 150 Civil Society Organizations, to promote citizen participation and monitor the progress of government actions and challenges, as well
as to systematically investigate, document and analyse evidence on the effectiveness of anti-corruption efforts in the region.

https://www.libertadciudadana.org/comunicado/occ-revela-retos-para-panama-en-la-lucha-anticorrupcion/

NEW DoJ CORPORATE CRIMINAL ENFORCEMENT POLICIES EQUIP PROSECUTORS WITH MORE TOOLS AND INFORMATION

On 29 October, a post in the Compliance and Enforcement blog from the New York University School of Law’s Program on Corporate Compliance and Enforcement was concerned with the stated commitments from the DoJ to equip prosecutors with more information and tools — including monitors — to root out corporate crime and ensure corporations comply with the law and the requirements of their agreements with the DoJ; proactively using data accumulated about past corporate resolutions, including taking into account corporations’ full criminal and regulatory histories; and standardising approaches to corporate enforcement across the DoJ and the US Attorneys’ Offices.

https://wp.nyu.edu/compliance_enforcement/2021/10/29/whats-old-is-new-again-dojs-new-corporate-criminal-enforcement-policies-equip-prosecutors-with-more-tools-and-information/

BLACK FRIDAY AND THE PROLIFERATION OF FAKE E-COMMERCE SITES

On 29 October, Market Screener said that a research report said that it found more and more scams, involving counterfeit websites that appear to be legitimate ecommerce sites, in the lead-up to Black Friday.  It says that fake ecommerce sites are quickly becoming the latest threat to consumers and they cover a wide range of products to lure potential buyers.

https://www.marketscreener.com/quote/stock/FORTINET-INC-60103137/news/Black-Friday-and-the-Proliferation-of-Fake-Ecommerce-Sites-36835781/

IRISHMAN DUE TO STAND TRIAL ON SPYING, MONEY LAUNDERING AND SMUGGLING CHARGES IN GREECE

On 30 October, Sunday World reported that an Irishman who spent 106 days in a Greek jail 3 years ago is due to travel back there in November to face spying, money laundering and smuggling charges.  He was arrested on the island of Lesbos when he was working with an NGO group rescuing African migrants from the Aegean Sea.  It is claimed that the Greek authorities are trying to deter illegal immigrants and are clamping down on groups who try to help them.

https://www.sundayworld.com/news/irish-news/irishman-due-to-stand-trial-on-spying-money-laundering-and-smuggling-charges-in-greece-40999128.html

US: CONVICTED MONEY LAUNDERER SENTENCED FOR SECOND BUSINESS EMAIL COMPROMISE (BEC) SCHEME

A news release from US DoJ on 29 October advised that Yannick A. Minang, aka “Africa”, 27, has been sentenced to 52 months in prison.  Previously, in September 2020, Minang had pleaded guilty to 5 counts of wire fraud, 1 count of unlawful monetary transactions and 1 count of money laundering conspiracy.  Minang conspired with co-conspirator Bintu Toure and others to open numerous bank accounts in Massachusetts in the name of sham companies, as part of an apparent business email compromise (BEC) scheme.  The news release notes that in September 2019, Minang had been sentenced to 46 months in prison after pleading guilty to his role in a separate BEC scheme.

https://www.justice.gov/usao-ma/pr/convicted-money-launderer-sentenced-second-business-email-compromise-scheme

RUSSIAN TYCOON PAYS $500 MILLION TO SETTLE US TAX BILL

On 29 October, IBT Times reported that Russian billionaire and banking and investment tycoon Oleg Tinkov has been required to pay nearly $509 million to settle US charges of tax evasion.  He had pleaded guilty to felony charges of concealing more than $1 billion in assets to avoid paying taxes on them as he gave up his US citizenship in 2013.

https://www.ibtimes.com/russian-tycoon-pays-500-million-settle-us-tax-bill-3327629

BANK CLIENT FRAUD IN BRAZIL UP 165% IN 2021

On 30 October, the Rio Times reported that scams against bank clients grew 165% in the first half of this year compared to the same period in 2020.  It notes that the growth occurs in a context in which cell phones account for over half of all banking transactions.

https://riotimesonline.com/brazil-news/rio-politics/bank-client-fraud-in-brazil-up-165-in-2021

https://portal.febraban.org.br/noticia/3704/pt-br/

IRELAND: NEW OBLIGATIONS ON TRUSTEES OF REAL ESTATE UNDER UPDATED AML REGULATIONS

On 22 October, a briefing from Irish law firm McCann Fitzgerald said that anyone dealing with express trusts, including trustees, beneficial owners and designated persons under AML legislation (which can include estate agents/surveyors, solicitors, accountants and other advisors) will need to familiarise themselves with the updated requirements of 2021 Regulations in order to be able to comply. The briefing considers the implications for trustees of real estate in particular.

https://www.mccannfitzgerald.com/knowledge/real-estate/new-obligations-on-trustees-of-real-estate-under-updated-aml-regulations

SAUDI ARABIA BANS IMPORTS FROM LEBANON IN DIPLOMATIC SPAT

On 30 October, Eurasia Review reported that Saudi Arabia recalled its ambassador to Lebanon and requested the departure of Lebanon’s envoy to Saudi Arabia.  Saudi Arabia banned all Lebanese imports into the country and reiterated a previous ban on citizens travelling to Lebanon in the interest of their safety considering the increasing instability in the country.  This followed Lebanon’s information minister saying that the Iran-aligned Houthis were defending themselves, calling the war in Yemen “futile” and having described the war as a Saudi “aggression”.  Saudi Arabia also referred to Lebanon’s failure to prevent drugs being smuggled to Saudi.

https://www.eurasiareview.com/30102021-saudi-arabia-orders-lebanon-envoy-to-leave-recalls-ambassador-to-country/

FinCEN FLEXES NEW EXPERTISE IN CLEAR WARNING TO COMPANIES BROADLY INVOLVED IN PROCESSING RANSOMWARE PAYMENTS

Clifford Chance has published a briefing saying that FinCEN is becoming increasingly sophisticated in its ability to identify and track unlawful activity related to cryptocurrency, and that its Ransomware Study identifies a number of “money laundering typologies” that FinCEN says signal that a transaction may involve ransomware payments.  Those identified must strengthen their detection and monitoring systems to make sure they can identify and prevent suspicious and unlawful transactions.

https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2021/10/FinCEN-flexes-new-expertise-in-clear-warning-to-companies-broadly-involved-in-processing-ransomware-payments.pdf

HONG KONG POLICE ARREST 32 FOR SELLING THEIR BANK ACCOUNTS TO SCAMMERS WHO USED THEM TO LAUNDER US$1.2 MILLION

On 29 October, the South China Morning Post reported that 12 domestic helpers were among the 5 men and 27 women arrested when police mounted an operation against cyber deception.  Investigations showed the suspects were paid up to a few thousand dollars for selling their bank accounts to scammers.

https://www.scmp.com/news/hong-kong/law-and-crime/article/3154188/hong-kong-police-arrest-32-selling-their-bank-accounts

AUSTRALIA: NAB DUMPED 40,000 CUSTOMERS OVER CRIME AND FRAUD CONCERNS

On 25 October, Mortgage Business reported that between May 2019 and September 2021, the bank estimated it had exited around 40,000 customers with active accounts, citing KYC identification requirement issues, or other financial crime or fraud reasons.  A number of fintechs, including a lender, had accused the banks of cutting off services due to anti-competitive motives.  The number of people dedicated to managing financial crime risks at NAB had grown from around 200 in 2018 to 1,000 in 2019, and 1,200 by the end of 2020.  As at 31 August this year, it is said that NAB had 1,500 personnel working in the division.

https://www.mortgagebusiness.com.au/breaking-news/16176-nab-dumped-40-000-customers-over-crime-fraud-concerns

VIRTUAL CURRENCY INDUSTRY POTENTAIAL OFAC SANCTIONS ISSUES

On 27 October, an article from Venable LLP says that those involved in cryptocurrencies – from Bitcoin to Dogecoin, and all points in between – should be aware that crypto exchanges appear to be the US Treasury’s next big target.  This, it says, includes not only virtual currency exchanges involved in laundering ransoms from ransomware attacks, but also US-based virtual currency service providers that fail to implement adequate sanctions compliance controls.

https://www.venable.com/insights/publications/2021/10/do-you-deal-with-the-virtual-currency-industry

THE AMERICAN CITIES WITH MOST MORTGAGE FRAUD RISK

On 30 October, 247 Wall Street reported that US house prices rose nearly 20% in August compared to last year and in 3 cities – Phoenix, San Diego, and Tampa – the number was up over 25%.  It warns that there is another factor to be considered, with a new mortgage fraud report saying that most fraud types showed increased risk, with about 1 out of 120 mortgage applications included fraudulent activity, with the highest-risk mortgages being for investment property.  The top city for fraud risk was Las Vegas, followed by another very large city –Miami, then a smaller and poorer, city – Poughkeepsie.

https://247wallst.com/housing/2021/10/30/the-american-city-with-most-mortgage-fraud-risk

NIGERIA TO JOIN FATF

On 30 October, the Daily Post and others reported that Nigeria’s Attorney-General and Minister of Justice told the intergovernmental Action Group Against Money Laundering in West Africa (GIABA) – a FATF-style regional body – that the country was ready to join the membership of FATF on money laundering and terrorism financing.

https://dailypost.ng/2021/10/30/nigeria-to-join-financial-action-task-force-on-money-laundering-terrorism-financing/

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.buymea3coffee.com/KoIvM842y

OTHER THINGS YOU MAY HAVE MISSED – OCTOBER 29

The post for 29 October seems to have mysteriously vanised from the site…so here are all the entries reposted…

SWEDISH OPERATOR LeoVegas REPRIMANDED BY DENMARK’S GAMING REGULATOR FOR MONEY LAUNDERING VIOLATIONS

On 29 October, iGB reported that LeoVegas has been reprimanded by Spillemyndigheden for “violating the rules on customer due diligence procedures” relating to the country’s money laundering act.

https://igamingbusiness.com/leovegas-reprimanded-by-danish-regulator-over-money-laundering-violations

DoJ VOWS TOUGHER ACTION AGAINST WHITE-COLLAR CRIME

On 29 October, the Wall Street Journal reported that the Deputy Attorney General has said prosecutors would consider all prior wrongdoing by corporations when deciding how to resolve a new investigation. Previously, prosecutors were allowed to only review cases whose facts were similar to the claims in the latest probe.  Corporations also won’t qualify for leniency programmes unless they provide information on all employees or executives believed to have participated in crimes such as fraud or bribery. 

https://www.wsj.com/articles/corporate-repeat-offenders-may-face-tougher-sanctions-justice-department-says-11635430568

HOW DOES THE FCA CRYPTOASSET AML/CFT REGIME AFFECT UK CRYPTOASSET BUSINESSES?

An article from Charles Russell Speechlys on 27 October said that, with the exception of security tokens, the majority of cryptoassets remain unregulated in the UK.  However, the FCA has been acting as the AML/CFT supervisor of various types of UK cryptoasset business since 10 January 2020.  Since then new cryptoasset businesses wishing to carry out certain activities in the UK have been required to register with the FCA before commencing business.

https://www.charlesrussellspeechlys.com/en/news-and-insights/insights/commercial/2021/how-does-the-fca-cryptoasset-amlctf-regime-affect-uk-cryptoasset-businesses/

FREEZING INJUNCTIONS AND THE ENFORCEMENT PRINCIPLE IN ENGLISH LAW

On 25 October, an article from Fox Williams LLP said that in a recent BVI case the Privy Council, including the President and the Deputy President of the Supreme Court and the Master of the Rolls, set out a new juridical basis for freezing injunctions.  It provides a brief history of freezing injunctions, which date from the 1970s and, after a long survey of all the relevant cases, one of the judges said that such injunctions are based on an “enforcement principle”, i.e. to facilitate the enforcement of a future judgment rather than to support an existing cause of action (this had already been referred to in some earlier cases). 

https://www.foxwilliams.com/2021/10/25/freezing-injunctions-and-the-enforcement-principle-in-english-law/

WAIVING PRIVILEGE IN WITNESS EVIDENCE

On 27 October, an article from RPC said that the High Court has ordered disclosure of privileged notes of a conversation after a witness referred to the conversation in his witness statement.  It says that the decision serves as a valuable reminder of the risk of waiving privilege when relying upon privileged material in statements of case or witness statements.

https://www.rpc.co.uk/perspectives/commercial-disputes/choose-your-words-wisely-waiving-privilege-in-witness-evidence/#page=1

A NEW ROUTE FOR COMPANIES TO MIGRATE TO THE UK

On 27 October, an article from MacFarlanes LLP says that, as part of the Budget measures, the UK Government has published a consultation on changing UK law to allow for corporate redomiciliation. This is an existing feature of company law in some of the UK’s competitor jurisdictions.  A consultation has been launched, with responses by 7 January.

https://blog.macfarlanes.com/post/102h9eu/a-new-route-for-companies-to-migrate-to-the-uk

https://www.gov.uk/government/consultations/corporate-re-domiciliation

AML/CFT AND SECURITY IMPLICATIONS OF THE ART MARKET

On 27 October, a briefing from the EU Institute for Strategic Studies quotes the EU’s 2020 Security Union Strategy, which says that ‘trafficking in cultural goods has become one of the most lucrative criminal activities and a source of funding for terrorists as well as organised crime’.  It says that the wider ways in which the legitimate art market can be exploited for nefarious purposes such as sanctions evasion and money laundering are relatively understudied.  It says that a closer scrutiny of the art market is an important step in combating the major security threat that stems from the link between organised crime and terrorist groups.  The Brief examines 4 ways in which the art market serves illicit groups: money laundering; financial accumulation in safe havens like freeports; commercialisation through galleries and auction houses of cultural objects tainted by illegality; and use of cultural objects as collateral and/or payment for drugs or weapons. It assesses the structural factors that facilitate these processes, particularly the market’s commercial, valuation, authentication, transport and legitimation dynamics.

https://www.iss.europa.eu/content/compliant-or-complicit-security-implications-art-market

COLTAN CHILD MINERS: THE DARK SIDE OF THE DRC’S WEALTH

On 11 October, an article from ENACT Africa says that the circumvention of regulatory frameworks and weak law enforcement cast doubt on coltan certification in the country.  Coltan is one of the world’s most vital minerals. It is used in cellphones, laptops and other devices because of its ability to store and release electrical energy.  Children work as washers and diggers in dangerous working conditions. They also engage in petty smuggling and sell coltan for a pittance once they escape with it out of the DRC to towns along the borders with Burundi, Rwanda and Uganda.  It says that miners and extractive companies have also found a way to circumvent the mineral certification protocols; and a comprehensive approach and appropriate policies are urgently needed to address the prevalence of child labour in coltan mining and the associated health and developmental consequences. 

https://enactafrica.org/enact-observer/coltan-child-miners-the-dark-side-of-the-drcs-wealth

KENYA: BETTER BORDER SURVEILLANCE IS NEEDED IN ORDER TO STEM SUGAR SMUGGLING INTO THE COUNTRY

On 13 October, an article from ENACT Africa says that high production costs and the mismanagement of factories have led to a drop in sugar production in Kenya over the past 2 decades, opening the door for smugglers.  In 2020, sugar made up 48% of the goods smuggled into the country, according to the National Crime Research Centre.  The article says that tackling sugar smuggling into Kenya therefore calls for a multi-agency approach. This includes forming investigative and enforcement teams from the Kenya Revenue Authority, National Intelligence Service, the Directorate of Criminal Investigations, and the police to work together to stem the networks and actors that facilitate this crime.

https://enactafrica.org/enact-observer/sweet-deals-for-smugglers-lead-to-bitter-losses-for-kenya

THE BRAGG REPORT ON CRYPTO REGULATION IN AUSTRALIA

On 28 October, an article from Clayton Utz says that the Select Committee on Australia as a Technology and Financial Centre chaired by Senator Andrew Bragg has made 12 recommendations in its final report, which, if adopted, would reflect a radical departure from the current regulatory environment for cryptocurrency and other digital assets.  The article details the 12 recommendations.  It notes that a  key theme of many of the recommendations is addressing the current absence of formal regulation of crypto-assets without stifling innovation and growth in this area 

https://www.claytonutz.com/knowledge/2021/october/the-bragg-report-the-future-of-crypto-regulation-in-australia

UKRAINE: AUTHORITIES HAVE IDENTIFIED AND PREVENTED ALMOST 59 ATTEMPTS TO VIOLATE THE PROCEDURE FOR INTERNATIONAL TRANSFERS OF CONTROLLED GOODS IN 2021

On 29 October, Interfax Ukraine reported that the Security Service of Ukraine (SBU) have identified and prevented almost 59 attempts worth more than $25 million.  In addition, since the beginning of the year, the courts have punished 26 organisers of schemes for the illegal transfer of military products and dual-use goods abroad.

https://en.interfax.com.ua/news/general/776326.html

US RETURNS 250 ANTIQUITIES TO INDIA AFTER PROBE INTO STOLEN ART

On 29 October, Al Jazeera reported that the items, worth an estimated $15 million, were handed over during a ceremony at the Indian consulate in New York.  This follows an investigation by the Manhattan DA office and US Immigration and Customs Enforcement, which focused on tens of thousands of antiquities allegedly smuggled into the US by dealer Subhash Kapoor, who has denied the allegations.

https://www.aljazeera.com/news/2021/10/29/us-india-smuggled-antiquities-stolen-art

12 TARGETED FOR INVOLVEMENT IN RANSOMWARE ATTACKS AGAINST CRITICAL INFRASTRUCTURE

A news release from Europol on 29 October said that 12 individuals wreaking havoc across the world with ransomware attacks against critical infrastructure have been targeted as the result of a law enforcement and judicial operation involving 8 countries, with action taken in Ukraine and Switzerland. These attacks are believed to have affected over 1,800 victims in 71 countries. 

https://www.europol.europa.eu/newsroom/news/12-targeted-for-involvement-in-ransomware-attacks-against-critical-infrastructure

EU EXTENDS SANCTIONS ON THE LEADERSHIP OF THE TRANSNISTRIAN REGION OF THE REPUBLIC OF MOLDOVA

EU Council Decision 2021/1893/CFSP has extended the current sanctions regime to 31 october 2022.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2021.384.01.0108.01.ENG&toc=OJ%3AL%3A2021%3A384%3ATOC

BANKRUPTCY: TRUSTEE IN BANKRUPTCY’S RIGHT OF INQUIRY

A briefing paper from the House of Commons Library on 29 October provides an outline of the right of inquiry of a trustee in bankruptcy. In the process, it also summarises the trustee’s statutory powers. The information contained in this paper applies only to England and Wales; Scotland has its own separate legal procedure for individual insolvency called “sequestration”.

https://researchbriefings.files.parliament.uk/documents/SN05819/SN05819.pdf

UK: TOP SPORTS LAWYER CLEARED OVER FOOTBALL TRANSFER PAYMENTS

On 29 October, the Law Society Gazette reported that one of the country’s top sports lawyers has been cleared by the Solicitors Disciplinary Tribunal of allegations that she was responsible for using a firm’s client account to pay third parties involved in football transfers.  She was alleged to have ‘caused or allowed’ Mishcon de Reya’s client account to be used as a banking facility for 5 transactions while she was at the firm between 2011 to 2015.

https://www.lawgazette.co.uk/news/top-sports-lawyer-cleared-over-football-transfer-payments/5110342.article

FCA DOES NOT NEED THE PERMISSION OF THE INSOLVENCY COURT TO TAKE REGULATORY ACTION AGAINST A COMPANY IN LIQUIDATION

On 29 October, the Law Society Gazette reported that the High Court has ruled in a case concerned with the collapse of construction giant Carillion.  The High Court was asked to determine whether regulatory action against a company in liquidation constitutes an ‘action or proceeding’ that requires the permission of the insolvency court.

https://www.lawgazette.co.uk/news/fca-wins-appeal-over-action-on-carillion-collapse/5110330.article

GANG SMUGGLED HUGE AMOUNTS OF ILLICIT ALCOHOL INTO THE UK AND STOLE MORE THAN £16 MILLION IN DUTY AND VAT

The Argus on 29 October reported tha gang members had been jailed for a total of 34 years.  Ringleader Shafqat Majeed, 52, was given 10 years in prison for spearheading the multimillion-pound VAT and duty fraud while living a life of luxury and driving flash cars.  The gang used a sophisticated network of fictitious businesses and created a trail of false paperwork on an industrial scale to cover up the conspiracy, and used a fake network of businesses and supply chains.

https://www.theargus.co.uk/news/19681632.gang-stole-16-million-taxes-jailed-34-years/

https://www.talkingretail.com/news/industry-news/criminal-gang-in-multi-million-alcohol-scam-jailed-for-more-than-34-years-29-10-2021

FOREIGN MILITARY SALES IN THE ERA OF GREAT POWER COMPETITION

On 28 October, a Commentary from RUSI says that there have been calls for the US to revise its foreign military sales (FMS) procedures because of competition with Russia and China – specifically said in relation to Chinese sales of UAV to states in the Middle East and North Africa.  It is said that the inventories of Iraq, the UAE, Saudi Arabia and Morocco suggest that these countries have pursued a procurement policy that emphasises a range of factors, including: support for domestic industry; systems that fit the country’s military needs; and geopolitical considerations – so acting for more pragmatic than geo-political reasons.

https://rusi.org/explore-our-research/publications/commentary/foreign-military-sales-era-great-power-competition

THE DUTCH TAX OFFICE PRACTICE OF BLACKLISTING PEOPLE FOR ALLEGED TAX FRAUD RULED A MAJOR CONTRAVENTION OF EU PRIVACY LAWS

On 29 October, Dutch News reported that the Fraud Sign Prevention (FSV) was in use from 2013 until 2020, and a precursor of that system had been in place since 2001.  The lists contained the names of 270,000 alleged perpetrators of income tax fraud, including minors and the parents innocently caught up in the childcare benefit scandal.

https://www.dutchnews.nl/news/2021/10/tax-office-black-list-flouted-privacy-rules-for-seven-years-says-watchdog

https://abcnews.go.com/International/wireStory/dutch-watchdog-slams-tax-office-fraud-list-privacy-80853422

WHERE IS BOSNIA-HERZEGOVINA RE CORRUPTION AND ABUSE OF POWER?

On 29 October, the Sarajevo Times reported on the country’s position in the Index of the Rule of Law of the World Justice Project (WJP). Bosnia and Herzegovina (BiH) dropped to 72nd place out of 139 countries in the world and received the worst marks in the parameters that measure the absence of corruption.

https://www.sarajevotimes.com/where-is-bih-on-the-list-of-countries-with-corruption-and-abuse-of-power/

UN: MONITORING SDG 16 KEY FIGURES AND TRENDS – INTENTIONAL HOMICIDE; HUMAN TRAFFICKING; UNSENTENCED DETENTION; ARMS TRAFFICKING; CORRUPTION; WILDLIFE TRAFFICKING

The UN Office on Drugs & Crime has published an update on Sustainable Development Goal (SDG) 16 targets.  Some show some progress, but others show little improvement.  Among its findings is that oly one third of firearms collected between 2016 and 2019 could be successfully traced to the point of diversion into the illicit market.  It finds that bribery is 5 times higher in low-income countries than in high-income countries, and it affects citizens interacting with essential public services and the COVID-19 pandemic may further exacerbate the problem.  Some progress is visible in the reduction of ivory trafficking, but traffickers are shifting away from ivory to more lucrative products like pangolin scales.

https://www.unodc.org/documents/data-and-analysis/statistics/DataMatters2_sdg16.pdf

APPLICATION OF THE NEW DATA PROTECTION ACT IN BVI

On 28 October, an article from Appleby is concerned with the BVI Data Protection Act, which is based on the GDPR and came into effect on 1 July. 

https://www.applebyglobal.com/publications/bvi-protecting-personal-data-are-you-prepared/

NIGERIAN MAFIA USE VENEZUELAN DRUG MULES TO REACH EUROPE

On 28 October, Insight Crime reported that a Nigerian trafficking network is now using “mules” to move drugs from South America to Europe, exemplifying how this growing drug consumer market is drawing mafias from around the world to the Americas.  The Nigerian mafias have become a small, yet growing player in South America’s drug trafficking scene and use Venezuelans as drug mules to carry cocaine to France, leaving from Brazil, Suriname and French Guiana.

https://insightcrime.org/uncategorized/nigeria-mafia-venezuela-drug-mules-reach-europe/

LAOS SEIZES TONS OF METH IN ASIA’S LARGEST-EVER DRUG BUST

On 28 October, RFA reported that authorities in north-eastern Laos’ have made the largest-ever drug bust in Asian history, seizing 55 million methamphetamine pills and 1.5 tons of crystal meth.  The seizure took place in Bokeo province, in the centre of the Golden Triangle, a region of Laos, Myanmar and Thailand notorious for the production and distribution of narcotics.

https://www.rfa.org/english/news/laos/drugs-10282021192259.html

UPDATING THE EUROPEAN DIGITAL IDENTITY FRAMEWORK

On 29 October, a briefing from the EU Parliament Research Service said that the 2014 EU Regulation on electronic identification and trust services for electronic transactions in the internal market (eIDAS Regulation or eIDAS) was the first digital identity legislation to provide the basis for cross-border electronic identification, authentication and website certification throughout the EU.  While application has been mixed the pandemic increased the need for such solutions to be put in place to access public and private services.  In June, the Commission put forward a proposal building on the eIDAS framework.

https://www.europarl.europa.eu/RegData/etudes/BRIE/2021/698772/EPRS_BRI(2021)698772_EN.pdf

SANCTIONS REFRESHER: VENEZUELA AND CUBA

On 29 October, Hellenic Shipping News provided an update on the position re sanctions as they affect the maritime sector.

https://www.hellenicshippingnews.com/sanctions-refresher-venezuela-and-cuba/

ART TRADE IN ‘CONSTRUCTIVE DIALOGUE’ OVER UK GOVERNMENT AS ECONOMIC CRIME LEVY

On 29 October, the Art Newspaper reported that the Levy threatened to disproportionately affect galleries, which measure turnover differently to auction houses; and the Government has published its policy paper on the new economic crime levy after several months consultation with members of the art trade.

https://www.theartnewspaper.com/2021/10/29/art-trade-in-constructive-dialogue-with-uk-government-as-economic-crime-levy-policy-paper-is-published

UK: MODERN SLAVERY AND MONEY LAUNDERING – THE DUTY MOST COMPANIES DON’T KNOW THEY HAVE

An article from BCL Solicitors asks: do UK companies have a duty to prevent, or report, forced labour or human trafficking?  The answer, for now, is ‘not quite’, it says – but duties in this area are strengthening in practice, thanks to laws on modern slavery and money laundering.

https://www.bcl.com/modern-slavery-and-money-laundering-the-duty-most-companies-dont-know-they-have/

SEARCH AND SEIZURE: THE POTENTIAL OF ASSET FORFEITURE FOR COUNTERING EXTORTION IN CENTRAL AMERICA

On 28 October, the Global Initiative Against Transnational Organised Crime published a report saying that extortion has become an endemic problem in Central America. To provide a comprehensive response to this crime, the countries of the region have begun to make use of asset forfeiture, a tool that reduces the financial assets available to organised crime.  It describes how this legal procedure has evolved and been applied in the region, sets out the advantages it offers in the fight against organised crime and proposes strategies for better implementation.

https://globalinitiative.net/wp-content/uploads/2021/10/GITOC-Search-and-Seizure-The-potential-of-asset-forfeiture-for-coutering-extortion-in-Central-America.pdf

CHILE TO DUBAI, A THRIVING ROUTE FOR GOLD TRAFFICKERS

On 28 October, an article from Insight Crime says that Chile has become a convenient exit point for illegal gold from the Amazon, with Dubai emerging as a consistent destination for such shipments.  Leaders from 3 groups, part of a so-called “Gold Cartel were recently arrested for smuggling over 500 kg of gold from Chile to Dubai in UAE.

https://insightcrime.org/news/chile-dubai-thriving-route-gold-traffickers/

INTERNATIONAL MARITIME OPERATION FINDS TERRORISTS AMONG TOURISTS

On 29 October, Homeland Security Today reported that an international operation aimed at strengthening passenger controls at a number of seaports and airports linking North Africa to Southern Europe has yielded 29 arrests for a variety of offenses, including 1 on terrorism charges.  Operation Neptune III involved law enforcement in 5 countries – Algeria, France, Italy, Spain and Tunisia – and was carried out during the summer 2021 tourist season.

https://www.hstoday.us/subject-matter-areas/transportation/international-maritime-operation-finds-terrorists-among-tourists/

MARITIME SECURITY EXPERTS MEET TO DISCUSS ROOT CAUSES OF PIRACY AND COUNTERMEASURES

On 22 October, an article from Homeland Security Today reported that 45 officers from 17 Regional Cooperation Agreement on Combating Piracy and Armed Robbery against Ships in Asia (ReCAAP) Member States participated virtually in a capacity building virtual lecture on 19 October. 

https://www.hstoday.us/subject-matter-areas/maritime-security/maritime-security-experts-meet-to-discuss-root-causes-of-piracy-and-countermeasures/

https://www.recaap.org/resources/ck/files/news/2021/Press%20release%20for%20CBVL(191021).pdf

OFAC SANCTIONS NETWORK AND INDIVIDUALS IN CONNECTION WITH IRAN’S UAV PROGRAMME

On 29 October, OFAC announced that it had designated members of a network of companies and individuals that have provided critical support to the UAV programmes of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its expeditionary unit, the IRGC Qods Force (IRGC-QF).  OFAC is also designating Saeed Aghajani, the commander of the IRGC Aerospace Force (IRGC ASF) UAV Command.  The IRGC-QF is said to have used and proliferated lethal UAV for use by Iran-supported groups, including Hizballah, HAMAS, Kata’ib Hizballah, and the Houthis, and to Ethiopia, where the escalating crisis threatens to destabilise the broader region.  Lethal UAV have been used in attacks on international shipping and on US forces.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211029

https://home.treasury.gov/news/press-releases/jy0443

US CONFIRMS DEPARTURE OF RWANDAN GENOCIDE SUSPECT AFTER DENATURALISATION

On 29 October, US Immigration & Customs Enforcement confirmed in a news release the departure of a Rwandan man suspected of human rights abuses in his home country, who had been residing in Buffalo, New York.  Peter Kalimu (aka Pierre Kalimu or Fidele Twizere) was denaturalised and ordered removed from the US following charges alleging his involvement in the 1994 Rwandan genocide. He departed the US on 21 October.

https://www.ice.gov/news/releases/ice-confirms-departure-rwandan-genocide-suspect-after-denaturalization

UKRAINE HOLDS FIRST-EVER ILLEGAL ASSET CONFISCATION

On 29 October, Euromaiden Press reported that, on 27 October, an appeal court upheld a decision to confiscate $46,000 from MP Illia Kyva.

http://euromaidanpress.com/2021/10/29/ukraine-holds-first-ever-confiscation-of-illegal-assets

MALTA HAS DEFENDED ITS SPENDING AFTER THE EU CHIEF PROSECUTOR COMPLAINED ON MALTA’S LACK OF REPORTING ON EU FUNDING FRAUD

On 29 October, Malta Today reported that European Chief Prosecutor Laura Kovesi had complained that the level of crime-detection in Malta related to the EU budget is “practically zero”.

https://www.maltatoday.com.mt/news/national/112987/government_defends_eu_funds_spending_after_chief_prosecutor_flags_concerns

CHINESE-AMERICAN MONEY LAUNDERING KINGPIN SENTENCED TO 15 YEARS

On 29 October, OCCRP reported that a US court has sentenced the kingpin of an international money laundering network to 15 years in prison for his role in laundering at least $30 million in illicit drug proceeds on behalf of transnational drug trafficking organisations.  Xizhi Li, 48, a Chinese national and a naturalised US citizen, who previously resided in Mexico, led a network of conspirators in laundering millions for multiple criminal enterprises dating back to 2008.

https://www.occrp.org/en/daily/15390-chinese-american-money-laundering-kingpin-sentenced-to-15-years

EX-AIDE TO GABON’S PRESIDENT BONGO JAILED FOR 5 YEARS FOR CORRUPTION

On 29 October, The South African reported that Brice Laccruche Alihanga, 41, a once-powerful chief of staff under Gabonese President Ali Bongo Ondimba, has been sentenced to 5 years in prison after a high-profile trial sparked by an anti-corruption crackdown.  He had become a powerbroker in the oil-rich state after Bongo suffered a stroke in October 2018 and spent months convalescing abroad.

https://www.thesouthafrican.com/news/africa/ex-aide-to-gabons-bongo-jailed-for-5-years

US: DUTCH NATIONAL FACES CHARGES FOR PARTICIPATION IN TERROR FINANCING RING

A news release from US DoJ on 29 October advised that, after 7 years of extradition hearings, Farhia Hassan, 38, had been extradited to the US to face charges stemming from her alleged participation in a terrorist financing ring in support of the Somalia-based terrorist group al-Shabaab.  It is alleged that she was involved with a group of women from more than a dozen countries around the world who ran a fundraising ring to provide financial support to al-Shabaab from in or about February 2011 through in or about July 2014.

https://www.justice.gov/opa/pr/dutch-national-faces-charges-participation-terror-financing-ring

INDIA: SUGAR EXPORT FRAUD – MUMBAI WOMAN ‘KINGPIN’

On 29 October, New Indian Express reported that police had accused Archana Bahulekar, 46, of being the alleged kingpin of the massive fraud.  The accused allegedly forged a bill to convince him that a quantity of sugar was shipped to Ghana and they also fabricated fake bank records of the transaction. 

https://www.newindianexpress.com/cities/kochi/2021/oct/30/sugar-export-fraud-mumbai-woman-kingpin-says-kerala-police-2377456.html

SEC ANNOUNCED THAT IT HAS CHARGED A CALIFORNIA COMPANY AND ITS CO-FOUNDERS AND CO-MANAGERS FOR FRAUDULENTLY RAISING $13.5 MILLION FROM MORE THAN 100 RETAIL INVESTORS

On 29 October, a release on Mondo Visione advised that the SEC had announced that it has charged BNZ, a Newport Beach, California-based company, and its co-founders and co-managers Brett Barber and Louis Zimmerle, for fraudulently raising $13.5 million from more than 100 retail investors.

https://mondovisione.com/media-and-resources/news/sec-charges-newport-beach-company-and-its-principals-with-operating-a-135-mill/

INDIA: AUTHORITIES SEIZES HELICOPTER IN ON REQUEST OF US AUTHORITIES OVER ITS ALLEGED END-USE IN A PROHIBITED COUNTRY

On 29 October, India Today reported that the Enforcement Directorate in Chennai has seized the helicopter of a Bangkok-based company, Marilog Avion Services Co Ltd, under the Prevention of Money Laundering Act (PMLA) at the request of US authorities in the Free Trade Warehouse Zone in Chennai.

https://www.indiatoday.in/india/story/ed-seizes-helicopter-in-chennai-on-us-request-1871223-2021-10-29

UK UPDATED ADVISORY NOTICE – MONEY LAUNDERING AND TERRORIST FINANCING CONTROLS IN OVERSEAS JURISDICTIONS

On 28 October, HM treasury released an updated Advisory Notice which contains advice about risks posed by unsatisfactory money laundering and terrorist financing controls and following the most recent FATF Plenary.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1029530/Annex_C_-_FATF_update_advisory_notice_October__2021.pdf

CREDIT SUISSE DEFERRED PROSECUTION AGREEMENT (DPA)

The 65-page DPA between Credit Suisse Group AG and the US is available online.

https://media-exp1.licdn.com/dms/document/C4E1FAQEGGCZhgj8fCg/feedshare-document-pdf-analyzed/0/1635498527769?e=1635634800&v=beta&t=KGPv6wiK4Su1Cwns0LgJs_BuDxs4wjI-xUwVXOBTajo

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.buymea3coffee.com/KoIvM842y

CYPRUS FOREX SHAKEN BY TRADING FRAUD

On 30 October, the Financial Mirror reported that Cyprus’ forex industry has been rattled by €15 million trading fraud, forcing 2 Limassol-based firms out of business, while more than 2,000 people have lost their jobs in recent weeks.  This came after the companies were linked to a multi-million forex trading scam from Ukraine to South Africa.

https://www.financialmirror.com/2021/10/30/cyprus-forex-shaken-by-trading-fraud

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.buymea3coffee.com/KoIvM842y

US: DUTCH NATIONAL FACES CHARGES FOR PARTICIPATION IN TERROR FINANCING RING

A news release from US DoJ on 29 October advised that, after 7 years of extradition hearings, Farhia Hassan, 38, had been extradited to the US to face charges stemming from her alleged participation in a terrorist financing ring in support of the Somalia-based terrorist group al-Shabaab.  It is alleged that she was involved with a group of women from more than a dozen countries around the world who ran a fundraising ring to provide financial support to al-Shabaab from in or about February 2011 through in or about July 2014.

https://www.justice.gov/opa/pr/dutch-national-faces-charges-participation-terror-financing-ring

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.buymea3coffee.com/KoIvM842y

EX-AIDE TO GABON’S PRESIDENT BONGO JAILED FOR 5 YEARS FOR CORRUPTION

On 29 October, The South African reported that Brice Laccruche Alihanga, 41, a once-powerful chief of staff under Gabonese President Ali Bongo Ondimba, has been sentenced to 5 years in prison after a high-profile trial sparked by an anti-corruption crackdown.  He had become a powerbroker in the oil-rich state after Bongo suffered a stroke in October 2018 and spent months convalescing abroad.

https://www.thesouthafrican.com/news/africa/ex-aide-to-gabons-bongo-jailed-for-5-years

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.buymea3coffee.com/KoIvM842y

OFAC SANCTIONS NETWORK AND INDIVIDUALS IN CONNECTION WITH IRAN’S UAV PROGRAMME

On 29 October, OFAC announced that it had designated members of a network of companies and individuals that have provided critical support to the UAV programmes of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its expeditionary unit, the IRGC Qods Force (IRGC-QF).  OFAC is also designating Saeed Aghajani, the commander of the IRGC Aerospace Force (IRGC ASF) UAV Command.  The IRGC-QF is said to have used and proliferated lethal UAV for use by Iran-supported groups, including Hizballah, HAMAS, Kata’ib Hizballah, and the Houthis, and to Ethiopia, where the escalating crisis threatens to destabilise the broader region.  Lethal UAV have been used in attacks on international shipping and on US forces.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211029

https://home.treasury.gov/news/press-releases/jy0443

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.buymea3coffee.com/KoIvM842y

CHILE TO DUBAI, A THRIVING ROUTE FOR GOLD TRAFFICKERS

On 28 October, an article from Insight Crime says that Chile has become a convenient exit point for illegal gold from the Amazon, with Dubai emerging as a consistent destination for such shipments.  Leaders from 3 groups, part of a so-called “Gold Cartel were recently arrested for smuggling over 500 kg of gold from Chile to Dubai in UAE.

https://insightcrime.org/news/chile-dubai-thriving-route-gold-traffickers/

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.buymea3coffee.com/KoIvM842y

UN: MONITORING SDG 16 KEY FIGURES AND TRENDS – INTENTIONAL HOMICIDE; HUMAN TRAFFICKING; UNSENTENCED DETENTION; ARMS TRAFFICKING; CORRUPTION; WILDLIFE TRAFFICKING

The UN Office on Drugs & Crime has published an update on Sustainable Development Goal (SDG) 16 targets.  Some show some progress, but others show little improvement.  Among its findings is that oly one third of firearms collected between 2016 and 2019 could be successfully traced to the point of diversion into the illicit market.  It finds that bribery is 5 times higher in low-income countries than in high-income countries, and it affects citizens interacting with essential public services and the COVID-19 pandemic may further exacerbate the problem.  Some progress is visible in the reduction of ivory trafficking, but traffickers are shifting away from ivory to more lucrative products like pangolin scales.

https://www.unodc.org/documents/data-and-analysis/statistics/DataMatters2_sdg16.pdf

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.buymea3coffee.com/KoIvM842y

AML/CFT AND SECURITY IMPLICATIONS OF THE ART MARKET

On 27 October, a briefing from the EU Institute for Strategic Studies quotes the EU’s 2020 Security Union Strategy, which says that ‘trafficking in cultural goods has become one of the most lucrative criminal activities and a source of funding for terrorists as well as organised crime’.  It says that the wider ways in which the legitimate art market can be exploited for nefarious purposes such as sanctions evasion and money laundering are relatively understudied.  It says that a closer scrutiny of the art market is an important step in combating the major security threat that stems from the link between organised crime and terrorist groups.  The Brief examines 4 ways in which the art market serves illicit groups: money laundering; financial accumulation in safe havens like freeports; commercialisation through galleries and auction houses of cultural objects tainted by illegality; and use of cultural objects as collateral and/or payment for drugs or weapons. It assesses the structural factors that facilitate these processes, particularly the market’s commercial, valuation, authentication, transport and legitimation dynamics.

https://www.iss.europa.eu/content/compliant-or-complicit-security-implications-art-market

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.buymea3coffee.com/KoIvM842y