Day: October 28, 2021

On 28 October, an article from the Iran Project from the US-based Wisconsin Project on Nuclear Arms Control said that, as Iran ramps up uranium enrichment, authorities in multiple countries have uncovered efforts by Iranian agents to procure mass spectrometers from abroad.  These dual-use machines, which can precisely measure the purity and molecular structure of radioactive material, are essential for uranium enrichment, although they also have a range of non-nuclear uses.

https://www.iranwatch.org/our-publications/international-enforcement-actions/mass-spectrometer-cases-illustrate-diversity-iranian-procurement-efforts

On 28 October, OFAC reported that 3 individuals had been added to the SDN List.  Jihad al-Arab, Dany Khoury, and Jamil Sayyed are members of Lebanon’s business and political elite, and are said to have each personally profited from the pervasive corruption and cronyism in Lebanon, enriching themselves at the expense of the Lebanese people and state institutions.  

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211028

https://home.treasury.gov/news/press-releases/jy0440

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On 28 October, The Sentry published a report compiled using open-source research. It focuses on areas that the FATF-style regional body ESAAMLG assessment team should consider during its preparation for the onsite visit, as well as areas that the government of Kenya may wish to assess as it finalises its national risk assessment (NRA) and prepares for the mutual evaluation report (MER).  The first part of the report discusses illicit finance risks and typologies — many linked to South Sudan — to be considered and addressed as the government seeks to establish Kenya as a financial hub in Africa through its Vision 2030 and the development of the Nairobi International Financial Centre (NIFC). The second part of the report provides a high-level assessment of Kenya’s AML/CFT regime, informed by the FATF 40 Recommendations. The third section provides recommendations to the MER team, the government of Kenya, and international partners, including an overview of steps that Kenya should prioritize to protect the banking sector, the real estate sector, and other areas at risk of abuse by illicit actors.

https://cdn.thesentry.org/wp-content/uploads/2021/10/KenyaIllicitFinance-TheSentry-Oct2021.pdf

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On 28 October, FATF published an updated version of its 2019 guidance which forms part of the FATF’s ongoing monitoring of the virtual assets and VASP sector.  The 2021 Guidance includes updates focusing on the following 6 key areas:

1. clarification of the definitions of virtual assets and VASP;
2. guidance on how the FATF Standards apply to stablecoins;
3. additional guidance on the risks and the tools available to countries to address the money laundering and terrorist financing risks for peer-to-peer (P2P) transactions;
4. updated guidance on the licensing and registration of VASP;
5. additional guidance for the public and private sectors on the implementation of the “travel rule”; and
6. Principles of information-sharing and co-operation amongst VASP Supervisors.

http://www.fatf-gafi.org/media/fatf/documents/recommendations/Updated-Guidance-VA-VASP.pdf

Also available is a quick guide to the guidance –

http://www.fatf-gafi.org/media/fatf/documents/recommendations/Quick-guide-RBA-VA-VASPS.pdf

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On 27 October, HMRC published a Policy Paper explaining how the Levy will work.  It will be imposed on entities that are regulated for AML purposes, and will first be charged on entities that are regulated during the financial year from 1 April 2022 to 31 March 2023, with the amount payable will be determined by reference to their size based on their UK revenue.  The Finance Bill 2021-2022 will establish the Economic Crime (Anti-Money Laundering) Levy in legislation, and will include proposed revisions to the original planned structure. For example, relevant entities with less than £10.2 million UK revenue will be exempt. Non-UK entities will be liable on the basis that its revenue is so much of the entity’s revenue as, on a just and reasonable apportionment, is attributable to activities of any permanent establishment of the entity in the UK.

https://www.gov.uk/government/publications/economic-crime-anti-money-laundering-levy/economic-crime-anti-money-laundering-levy

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On 28 October, YLE reported that Finnish Customs have seized several thousand kilos of snus oral tobacco during the course of a preliminary probe into a smuggling operation estimated to be worth millions of euros. Officers believe the contraband has originated in Sweden, travelled via Central Europe to the Baltics and eventually to Finland.  Along with the seizures of snus, several hundred kilograms of nicotine sachets, which are classified as prescription drugs, have also been seized by customs officials. Unlike snus, nicotine sachets do not contain tobacco.

https://yle.fi/uutiset/osasto/news/customs_reveal_extensive_snus_smuggling_network/12163645

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On 27 October, Dryad Global reported that the OCIMF had produced new guidance intended to help owners/operators with pre-selection considerations before using private maritime security services andprivate maritime security companies (PMSC).

https://channel16.dryadglobal.com/ocimf-issues-guidance-on-hiring-private-maritime-security-guards

On 27 October, RPC released 2 podcasts explaining the role of the two institutions in the fight against corruption.  Discussing themes ranging from the mechanisms for investigating and sanctioning corruption and fraud, to efforts to ensure due process and consistency, the podcasts provide a unique insight into multilateral development banks and international financial institutions like never before to help navigate the complex web of debarment regimes and ensure the best outcome.  They are 2 of a series of 9 on the various Multilateral Development Banks and international financial institutions.

https://www.rpc.co.uk/perspectives/unspoken-giants/the-inter-american-development-bank/

https://www.rpc.co.uk/perspectives/unspoken-giants/the-world-bank/#page=1