On 10 November, the UK formally listed the 3 Houthi designated by the UN on 9 November.
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On 10 November, FATF published addition guidance, saying that in October 2021, it adopted minor amendments to Recommendation 23 and the FATF Glossary to clarify how the existing requirements in Recommendation 18 (Internal controls and foreign branches and subsidiaries) to implement group-wide programmes against money laundering and terrorist financing apply to DNFBP under Recommendation 23. These Explanatory Materials in the guidance give more clarity as to the FATF intentions in this area and how they fit with its overall objective of improving the effectiveness of AML/CFT measures. They explain the basic concepts, and answer questions such as ‘What does the FATF mean by common ownership, management or compliance control?’ and ‘How should DNFBP groups and other structures implement group-wide programmes?’
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On 10 November, the FCPA Blog reported that the Africa Development Professional Group Ltd. (ADP) is ineligible to participate in projects and operations financed by the World Bank Group during the 21-month debarment, following investigations linked to a project in Somalia. This debarment qualifies for cross-debarment by the Asian Development Bank, the European Bank for Reconstruction and Development, the Inter-American Development Bank, and the African Development Bank.
http://www.worldbank.org/en/projects-operations/procurement/debarred-firms
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On 9 November, the UN announced that 3 names had been added to the sanctions regime under UN Security Council Resolution 2140. One is the Houthi ‘Assistant Minister of Defence for Logistics’, another is the Houthi Military Chief of General Staff, and the third is a prominent leader of Houthi forces and commander of forces.
https://www.un.org/press/en/2021/sc14695.doc.htm
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On 10 November, OFAC advised that 2 individuals. These Cambodian government officials are designated pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world. The individuals are also being made subject to Department of State visa restrictions so that they, and their eligible immediate family members, are barred from entry into the US. The individuals designated are members of the Cambodian Ministry of National Defense. One is the Director-General of the Defense Ministry’s Material and Technical Services Department, and the other is the Royal Cambodian Navy Commander.
https://home.treasury.gov/news/press-releases/jy0475
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211110
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On 10 November, an Occasional paper from RUSI draws on FATF mutual evaluation data to analyse the FATF’s progress on including counterproliferation finance in its standards.
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On 10 November, FATF published an updated guide to the FATF 40 Recommendations.
http://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Recommendations%202012.pdf
A list of the amendments made to the recommendations (and their Interpretative Notes) is available at –
http://www.fatf-gafi.org/publications/fatfrecommendations/documents/fatf-recommendations.html
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EU Regulation 2021/1932/EU has seen Baghdadi AL-MAHMOUDI removed from its Libyan sanctions lists following a review.
On 10 November, Bird & Bird said that the ECSPR had effect from 10 November. The firm has provided a small series of articles on the regulations of the ECSPR. An overview of our reports from the series on the start of the applicability of the ECSPR can be found at –
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The ICC Academy has produced the latest of its comprehensive guides, this takes one through the core aspects of commodity trade finance. Commodities can be defined as being typically mass-produced goods which are sold and delivered in bulk (exceptions may be precious or rare metals). They include raw materials, agricultural products. Commodity trade finance may be defined as providing the financing to bridge the purchase of the commodity, e.g. by a trader, until the sale of the underlying commodity by the trader to, for example, a processor. It should be noted that this does not necessarily involve actual funding, but can be structured in the form of a contingent instrument, the most common of which are letters of credit.
https://icc.academy/commodity-trade-finance-guide
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