OTHER THINGS YOU MAY HAVE MISSED – DECEMBER 15

Panama Covid-19 update – no word yet (that I have seen) on Omicron being here, but cases are still climbing, at a slow but steady rate, with axtive cases up another 124 today to 3,610. 386 new cases and 1 new fatality were reported today/ However, so far, hospital numbers remain relatively low – with 16 in ICU and 93 in other wards. The numbers of people in the so-called hospital-hotels has risen by 10 to 112. People in such include those unable to isolate at home (perhaps due to other vulnerable people being there) or travelling (e.g. having arrived from abroad and “failed” the testing at the airports).

15 DECEMBER 2021 

ASSESSING THE RENEWED EU ACTION PLAN AGAINST MIGRANT SMUGGLING

On 10 December, the Centre for European Policy Studies takes stock of key insights arising from recent and ongoing research on the facilitation of irregular migration.  It says that the Plan exacerbates the risks that refugees and other migrants face by penalising those who assist them.  Civil society actors, family members and communities that act out of compassion or provide basic services in transit and destination countries continue to be investigated and prosecuted as ‘migrant smugglers’.

https://www.ceps.eu/download/publication/?id=34850&pdf=CEPS-PB2021-01_Between-politics-and-inconvenient-evidence.pdf

HUMAN RIGHTS ACTIVISTS ARE LOBBYING MAJOR JEWELLERS TO STOP BUYING GEMS SOURCED IN MYANMAR 

On 15 December, AP reported that a report from Global Witness outlines how the army is involved in gemstone mining despite a moratorium on new licences put in place before the military seized power in February.  Legislation is pending in the US Congress which would prohibit all US imports of Myanmar gemstones.

https://apnews.com/article/business-lifestyle-myanmar-army-aung-san-suu-kyi-af4133c6a01e461e5971c4444e2f2dd5

GHANA HAS LOST AROUND 90% OF POTENTIAL GOLD PROCEEDS DUE TO SMUGGLING SINCE MAY 2020

On 15 December, Ghana Web reported that the MD of the Precious Metals Marketing Company (PMMC) has said that it costs half of much to smuggle gold out of the country than going through the PMMC. 

https://www.ghanaweb.com/GhanaHomePage/business/Gold-smuggling-Ghana-loses-90-of-foreign-capital-from-gold-sale-from-May-2020-to-now-PMMC-1424458

EU FACTSHEET ON ENVIRONMENTAL CRIME

On 15 December, the EU released this Factsheet

https://ec.europa.eu/commission/presscorner/detail/en/FS_21_6746

UK NATIONAL CYBER STRATEGY

On 15 December, the Home Office and others issued a news release saying that the Government has published its new National Cyber Strategy which sets out how the UK will solidify its position as a global cyber power.  This is said to be the first major milestone following the publication of the Government’s Integrated Review earlier this year.

https://www.gov.uk/government/news/new-blueprint-to-protect-uk-from-cyber-threats

https://rusi.org/explore-our-research/publications/commentary/uk-governments-new-cyber-strategy-whole-society-response

PANAMA LEGISLATES TIGHTER CONTROLS ON BENEFICIAL OWNERSHIP REPORTING

On 15 December, STEP reported that a new Law in Panama requires international legal entities to provide their resident agent with accounting records annually.  The Law adjusts existing legislation on AML and aims to meet international standards on tax transparency (as a review of its FATF status looms).

https://www.step.org/industry-news/panama-legislates-tighter-controls-beneficial-ownership-reporting

https://ariaslaw.com/boletines/NEWSLETTER%202021/NOVIEMBRE/PA%20NOVEMBER%202021%20ENG.pdf

ALLEGED ‘ORGANISER’ FOR £100 MILLION CASH MULE NETWORK ARRESTED BY THE NCA

On 14 December, a news release from NCA advised that an Emirati national, 46, suspected of being a key figure in an international money laundering network responsible for moving tens of millions of pounds out of the UK has been arrested by the NCA in London.  He is alleged to have organised travel arrangements for at least 26 couriers who between them have removed an estimated £100 million criminal cash from the UK to Dubai, and 2 of those couriers are already serving jail terms.

https://www.nationalcrimeagency.gov.uk/news/alleged-organiser-for-100m-cash-mule-network-arrested-by-the-nca

DEPLETING FISH STOCKS FUELLING TRANSNATIONAL CRIME – FISHERIES CRIME LINKED TO OTHER SERIOUS CRIMES SUCH AS HUMAN TRAFFICKING AND THE SMUGGLING OF DRUGS AND EXPLOSIVES

On 15 December, a news release from Interpol said that a global operation coordinated by INTERPOL shows fisheries crime linked to other serious crimes such as human trafficking and the smuggling of drugs and explosives.  Interpol coordinated a 5-month intelligence-led operation (June- October 2021) spanning 34 countries, and concluded that the decrease in marine living resources are also driving a surge in fisheries-related crime.

https://www.interpol.int/News-and-Events/News/2021/Depleting-fish-stocks-fueling-transnational-crime

AUSTRALIAN SANCTIONS REGIME UPDATED TO ADDRESS MODERN SLAVERY CHALLENGES

On 15 December, an article from Out-Law says these new measures are separate to the sanctions applied under international obligations from the UN Security Council, and the amendments to the legislation are broad, applying in addition to country-specific sanctions.

https://www.pinsentmasons.com/out-law/news/australian-sanctions-regime-updated-to-address-modern-slavery-challenges

SPAM EMAIL & DDOS ATTACK: HOW EMAILS ARE PART OF DDOS ATTACK

On 15 December, this post from Sniffemail on Linkedin addresses the question: how are spam emails related to DDoS?  It says that attackers often send spam emails, including personalised messages, to manipulate recipients to download an attachment or click on a link; or send a personalised email promising to commit a DDoS attack on your website if you don’t pay a ransom.

https://www.linkedin.com/pulse/spam-email-ddos-attack-how-emails-part-sniffemail/?trackingId=FCyiA3cWRCgjh0%2FV%2BMfQYw%3D%3D

LAWYER WHO SPARKED CRIMINAL PROBE INTO GUY WILDENSTEIN TAX CASE FOUND GUILTY OF FRAUDULENTLY HIDING $5.1 MILLION

On 13 December, the Art Newspaper reported that French lawyer Claude Dumont-Beghi publicly berated Guy Wildenstein, heir of the famous Wildenstein art dealing dynasty family, and the campaign sparked a criminal trial in which Wildenstein was accused of stashing works of art worth more than $1 billion in offshore trusts in a bid to evade French tax authorities. It is said that Dumont-Beghi has now been convicted of aggravated tax fraud and money laundering for concealing $5.1 million she obtained from her client in the mid-2000s, in an undeclared account at HSBC Holdings in New York.

https://www.theartnewspaper.com/2021/12/13/lawyer-who-sparked-criminal-probe-into-guy-wildenstein-tax-case-found-guilty-of-fraudulently-hiding-dollar51m

EU LIFTS JOHN DALLI’S IMMUNITY, PAVING WAY FOR CRIMINAL CASE TO BEGIN

On 13 December, the Times of Malta reported that the EU has lifted former European health commissioner John Dalli’s immunity from prosecution, with a case against him finally set to begin a decade after he was first implicated in a major bribery scandal, over his role in an alleged €60 million bribe to influence EU tobacco legislation dating back to 2012.

https://timesofmalta.com/articles/view/brussels-lifts-john-dalli-immunity-case-to-begin-10-years-after.921031

AML/CFT: RISK ASSESSMENTOF A REMITTANCE CORRIDOR

In September, the World Bank and IMF released a draft framework re remittances which may pose money laundering and terrorist financing risks, depending on the context of the sender and/or recipient countries as well as the scale and the characteristics of criminal activities and terrorism in these transactions.  The report proposes a draft framework and methodology for the risk assessment in remittance corridors having the potential of being identified as safe remittance corridors (SRC).  It proposes an assessment framework that can be applied jointly or separately by the sender and the recipient corridor countries.

https://www.fsb.org/wp-content/uploads/P131221-1.pdf

HACKERS STEAL $140 MILLION FROM USERS OF CRYPTO GAMING COMPANY

On 13 December, Vice reported that hackers stole around $135 million from users of the blockchain gaming company VulcanForge. 

https://www.vice.com/en/article/4awxep/hackers-steal-dollar140-million-from-users-of-crypto-gaming-company

PODCAST: THE OECD ANTI-BRIBERY RECOMMENDATION AND THE CIVIL LAW-COMMON LAW DILEMMA

In the latest TRACE podcast, Nicola Bonucci, former Legal Director at the OECD and now a partner at Paul Hastings in Paris, joins the podcast to discuss the 2021 OECD Anti-Bribery Recommendation announced in November.  There is also a discussion about the challenge of advancing an international consensus on anti-corruption enforcement amongst Working Group on Bribery members hailing from different legal systems.

https://www.traceinternational.org/resources-podcast

4 CHARGED IN $35 MILLION COVID-19 RELIEF FRAUD SCHEME

A news release on 15 December from US DoJ advised that a federal grand jury in has charged 4 additional individuals for fraudulently obtaining and laundering millions of dollars in forgivable Paycheck Protection Program (PPP) loans guaranteed by the Small Business Administration (SBA) under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.  To date, in total, 15 individuals across 2 states have now been charged in the conspiracy. 

https://www.justice.gov/opa/pr/four-charged-35-million-covid-19-relief-fraud-scheme

A news release from US DoJ on 15 December advised that a federal court in Florida has permanently enjoined 3 residents of Vietnam from operating a pandemic-related scam that targeted American consumers.  The defendants operated more than 300 websites that fraudulently purported to sell products in the US that became scarce during the pandemic, including hand sanitizer and disinfectant wipes.  Thousands of victims in all 50 states paid for items marketed through the websites, but received nothing. 

https://www.justice.gov/opa/pr/court-permanently-enjoins-three-vietnamese-residents-continuing-operate-pandemic-related-0

ANOTHER BUSINESS JET ON ILLEGAL FLIGHT CAUGHT

On 15 December, the Latin American Aviation Historical Society reported that a Gulfstream G400 (aka G-II) twin-jet business aircraft conducting an illegal flight was tracked by the Guatemalan Air Force on 14 December.  When she landed near a village, troops were deployed and secured the aircraft.

https://twitter.com/The_LAAHS

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OFAC SANCTIONS ON THOSE INVOLVED IN DRUGS TRADE

On 15 December, OFAC announced a new Executive Order imposing sanctions on foreign persons involved in the drugs trade.  It designates a Chinese national, Chuen Fat YIP (aka Chuan Fa YE), a Mexican and 4 Chinese entities and a Brazilian entity.  Many detail changes have been made to existing entries.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20211215

https://home.treasury.gov/news/press-releases/jy0535

https://www.state.gov/combating-transnational-crime-and-imposing-sanctions-on-persons-involved-in-the-global-illicit-drug-trade/

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SERBIA: AML/CFT FOLLOW-UP REPORT – IMPROVEMENTS HAVE LED TO UPGRADED RATING BUT MINOR DEFICIENCIES REMAIN

On 13 December, MONEYVAL released the 4th follow-up report following the original mutual evaluation report (MER) of 2016.  Serbia has made progress to address the technical compliance deficiencies identified in the MER and applicable subsequent follow-up reports.  As a result of this progress, Serbia has been re-rated on FATF Recommendations R.22, 23, 28 and 40.  However, Serbia will remain in enhanced follow-up and will continue to report back to MONEYVAL on progress to strengthen its implementation of AML/CFT measures, and is expected to report back in 2 years’ time. 

https://search.coe.int/directorate_of_communications/Pages/result_details.aspx?ObjectId=0900001680a4db7a

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OTHER THINGS YOU MAY HAVE MISSED – DECEMBER 14

Panama Covid-19 update – apparently there are 127 vaccination points across the country. Mind you, I passed a drive-in testing centre downtown today, which was busy the last time I passed it several months ago, but just one car in the testing tent today.

Today saw 382 new cases reported (the highest daily figure since 11 September) and 2 new fatalities (the health ministry reports that the lethality of the virus continues to be 1.54%). The number of active cases has shown another rise, by 216 to 3,486 (also the highest its been since September). However, to date, the numbers in ICU continue to only be low (and a fraction of what they were even as late as September), with 16 currently in ICU nationwide, and with 105 in other wards (the sort of level that has been maintained for about the last month or so).

14 DECEMBER 2021

PORTUGAL – BRIBERY OFFENCES GUIDE

On 13 December, an article from DLA Piper outlined what is bribery and the legal framework.

https://www.dlapiper.com/en/us/insights/publications/2019/09/bribery-offenses-guide/portugal/

UK: NATWEST FINED $351 MILLION FOR OVERLOOKING MONEY LAUNDERING RISKS POSED BY CLIENT

On 14 December, the Wall Street Journal and others reported that some of the cash deposits made by gold dealer Fowler Oldfield arrived in black garbage bags bursting from the weight.  The case is the first FCA criminal prosecution of a bank for money laundering breaches.

https://www.wsj.com/articles/natwest-fined-351-million-for-overlooking-money-laundering-risks-posed-by-jewelry-client-11639421806

https://www.legalfutures.co.uk/latest-news/fraudsters-lied-about-retaining-manchester-solicitors-to-fool-natwest

https://www.eversheds-sutherland.com/global/en/what/articles/index.page?ArticleID=en/Fraud_and_financial_crime/FCA_concludes_first_AML_prosecution_of_a_bank

A SIMPLE GUIDE TO THE LAW ON CIVIL RECOVERY UNDER THE PROCEEDS OF CRIME ACT 2002

On 8 December, an article from BCL Solicitors LLP explains the way civil recovery works under the Proceeds of Crime Act 2002 (POCA).

https://www.mondaq.com/uk/crime/1139920/a-simple-guide-to-the-law-on-civil-recovery-under-the-proceeds-of-crime-act-2002-poca

4 BANKS HAVE HAD FINES IMPOSED IN HONG KONG FOR MONEY LAUNDERING FAILINGS

The Hong Kong Monetary Authority (HKMA) has announced it has issued fines totalling HK$44.2 million to 4 banks for historic AML breaches – Swiss bank UBS, the Industrial and Commercial Bank of China (ICBC), China Construction Bank and the Taiwanese bank CTBC.

https://www.mondaq.com/hongkong/white-collar-crime-anti-corruption-fraud/1140188/four-banks-have-had-fines-imposed-in-hong-kong-for-money-laundering-failings

CANADA DESIGNATES 4 MYANMAR MILITARY ENTITIES

On 14 December, EU Sanctions reported that, in coordination with the US and UK, Canada has designated 4 entities from Myanmar for human rights abuses.

https://www.europeansanctions.com/2021/12/canada-designates-4-myanmar-military-entities/

STRUCTURE AND THE FORMAT OF THE UK SANCTIONS LIST IS CHANGING IN FEBRUARY 2022

On 13 December, HM Treasury released guidance is to help one understand and prepare for the change – but saying that there will be no material updates to listings when it occurs. 

https://www.gov.uk/government/publications/uk-sanctions-list-change-in-format

AUSTRALIA: ACMA ORDERS BLOCKING OF MORE OFFSHORE AND AFFILIATE SITES

On 14 December, iGB reported that the Australian Communications and Media Authority (ACMA) has ordered the blocking of a number of offshore gambling and affiliate websites it said were operating in the country illegally.  Since November 2019, ACMA has blocked 375 websites it said were operating in Australia illegally.

https://igamingbusiness.com/acma-orders-blocking-of-more-offshore-and-affiliate-sites

NIRAV MODI FILES APPEAL AGAINST EXTRADITION FROM UK

On 14 December, Times Now News reported that the fugitive diamond merchant has filed an appeal against the decision to extradite him to India over the $2 billion PNB Bank scam.

https://www.timesnownews.com/videos/times-now/india/nirav-modi-files-appeal-in-british-court-accused-charged-in-pnb-scam-for-fraud-and-money-laundering/115941

UK: SOLICITORS REGULATION AUTHORITY HAS PAID £228,000 TO COVER THE LEGAL COSTS OF A SOLICITOR FOLLOWING A PROSECUTION ABANDONED A MONTH BEFORE TRIAL

On 14 December, the Law Society Gazette reported that  the Solicitors Disciplinary Tribunal to have made a series of errors in bringing allegations against Jamil Ahmud.

https://www.lawgazette.co.uk/news/sra-to-pay-record-228000-to-cover-costs-of-regrettable-prosecution/5110935.article

FORMER ALBANIAN ENVIRONMENT MINISTER ARRESTED

On 14 December, Exit News reported that the former Minister of the Environment Lefter Koka has been arrested by the Special Court For Organised Crime and Corruption (SPAK).  He held the environmental portfolio for Socialist Movement for Integration (LSI) between 2013 and 2017 before becoming a deputy for the Socialist Party between 2017-2021.

https://exit.al/en/2021/12/14/former-albanian-environment-minister-arrested/?src=ilaw

UK: PLAN TO REFORM HUMAN RIGHTS ACT

On 14 December, the MoJ issued a consultation explaining how proposed new legislation aims to strike a proper balance between individuals’ rights, personal responsibility and the wider public interest. This would be achieved while retaining the UK commitment to the European Convention on Human Rights (ECHR).  The consultation closes on 3 March.

https://www.gov.uk/government/news/plan-to-reform-human-rights-act

https://www.gov.uk/guidance/independent-human-rights-act-review

https://www.gov.uk/government/consultations/human-rights-act-reform-a-modern-bill-of-rights

EU: 544 ARRESTS AND €63 MILLION OF FAKE PHARMACEUTICALS AND ILLEGAL DOPING SUBSTANCES SEIZED

A news release from Europol on 14 December announced that it had coordinated Operation Shield II, a global effort to target trafficking of counterfeit and misused medicines and doping substances.

https://www.europol.europa.eu/media-press/newsroom/news/544-arrests-and-%E2%82%AC63-million-of-fake-pharmaceuticals-and-illegal-doping-substances-seized

HOW MEXICAN CARTELS SETTLED IN CANADA

On 13 December, an article from Insight Crime says that the story of the Mexican cartels and their influence abroad has mostly focused on the US.  But a number of Mexican groups have headed farther north, embedding themselves in the Canadian underworld, where they are displacing traditional mafias.

https://insightcrime.org/news/how-mexican-cartels-settled-canada/

UBS FAILS TO OVERTURN GUILTY VERDICT IN FRENCH TAX EVASION CASE

On 13 December, Swissinfo reported that an appeal court has confirmed that Swiss bank UBS is guilty of having assisted French tax evaders – but reduced the penalty to €1.8 billion.

https://www.swissinfo.ch/eng/ubs-fails-to-overturn-french-tax-evasion-guilty-verdict/47187104

ILLEGAL ORGAN TRANSPLANT NETWORK BUSTED IN ISTANBUL

On 12 December, Arab News reported that organ trade network was being led by Jordanian and Palestinian nationals in Istanbul has been busted.  10 people, 4 ringleaders and 6 individuals who were about to sell their organs or get transplants, were caught.

https://www.arabnews.com/node/1985316/middle-east

HOW “INTELLIGENT” NFT RAISE SOME RED FLAGS

On 10 December, Coindesk published an article which provides 5 Red Flags to watch.

https://www.coindesk.com/policy/2021/12/10/how-intelligent-nfts-raise-some-red-flags/

INSIDE IRELAND’S PUBLIC HEALTHCARE RANSOMWARE SCARE

On 13 December, the Krebs on Security blog posted this article, saying that PWC recently published lessons learned from the disruptive and costly ransomware attack in May 2021 on Ireland’s public health system.  That “unusually candid post-mortem” found that nearly 2 months elapsed between the initial intrusion and the launching of the ransomware.  Another point highlighted was that the attack also affected hospitals had tens of thousands of outdated Windows 7 systems, and that the health system’s IT administrators failed to respond to multiple warning signs that a massive attack was imminent.  The article concludes that in all likelihood, the Irish HSE will get the money it needs to implement the programs recommended by PWC, however long that takes – but ends by wondering how many US-based healthcare organisations could say the same.

https://krebsonsecurity.com/2021/12/inside-irelands-public-healthcare-ransomware-scare/

ITALIAN POLICE SWOOP ON AGENTS OVER ALLEGED LAUNDERING OF TRANSFER FEES

On 14 December, Inside World Football reported that Italian prosecutors are reported to be investigating football agents over alleged tax evasion and money laundering, and have asked 11 clubs, including Juventus, Inter Milan and AC Milan, to provide documents.

http://www.insideworldfootball.com/2021/12/14/italian-police-swoop-agents-alleged-laundering-transfer-fees/

BREXIT: REGISTERED TRADE MARKS AND REGISTERED DESIGNS ETC – ANOTHER DEADLINE

On 14 December, an article from Field Fisher reminded those affected of a further, and less well known deadline for any licences and/or security interests that were registered against EU trade marks and registered designs which were not automatically recorded on the UK Register in respect of the comparable rights that were created post-Brexit. The UKIPO has issued guidance and has provided until 31 December for parties to record an existing licence and/or security interest against comparable UK registrations or comparable trade mark applications filed.  It says that although it is not mandatory for such transactions to be recorded, there are benefits in recording licences and security interests, particularly as against potential infringers or third parties acquiring competing rights in a mark.

https://www.fieldfisher.com/en/services/intellectual-property/intellectual-property-blog/forthcoming-deadline-of-31-december-2021-to-record

https://www.visualcapitalist.com/top-10-semiconductor-companies-by-market-share/

See also –

VISUALISING THE GLOBAL SEMICONDUCTOR SUPPLY CHAIN

https://www.visualcapitalist.com/visualizing-the-global-semiconductor-supply-chain/

UP TO 9 CREW ON A CONTAINERSHIP IN THE GULF OF GUINEA ARE THOUGHT TO HAVE BEEN KIDNAPPED AND 1 SHOT

On 14 December, Loadstar reported that the CMA CGM-chartered Tonsberg was attacked by pirates some 48 nautical miles south-west of Luba, while it headed for Cotonou, Benin, after departing from Cameroon’s Port Autonome de Kribi.  While up to 9 crew m are thought to have been kidnapped, another is being treated for a bullet wound in the leg.

https://theloadstar.com/crew-kidnapped-from-cma-cgm-vessel-in-gulf-of-guinea/

REPORT OUTLINING A NEW VISION FOR THE GLOBAL TRADE FINANCE ECOSYSTEM

On 18 November, the International Chamber of Commerce, in collaboration with Fung Business Intelligence and supported by McKinsey & Company, had launched a report outlining a new vision for the global trade finance ecosystem.   It is said thattoday’s trade finance system is characterised by a complex web of decades-old manual processes, and more recent, isolated “digital islands” — closed systems of trading partners formed to address specific pain points.  The report therefore sets out a road map for digitally connecting and facilitating interoperation among existing networks through sets of shared standards, processes, protocols and guiding principles.  It is also said that key is a drive access for SME to emerging digital processes by scaling innovations such as digital identity, paperless trade, and transaction-based credit assessment in addition to traditional balance sheet credit scoring.

https://iccwbo.org/publication/reconceiving-the-global-trade-finance-ecosystem

Incoterms® 2020 – FCA AND DAP

On 1 December, an article from the International Chamber of Commerce concentrated on the 2 most popular Incoterms® 2020 Rules – FCA and DAP.  These rules can throw up some tricky questions regarding how they interface between the contract of carriage and issues surrounding transport documents, customs clearance and logistics.

https://icc.academy/incoterms-fca-dap-transport

CANADA: 13 BRITISH COLUMBIANS NOW FACING CHARGES IN ALLEGED $1 BILLION STOCK FRAUD SCHEME

On 14 December, Pique Newsmagazine reported that the US SEC has added 3 more Vancouver-area stock promoters to a growing list of defendants involved in an alleged $1 billion pump-and-dump scheme.  Allegedly using a web of overseas shell companies created by Fred Sharp, a former Vancouver lawyer-turned-businessman for Panama investment firm, Mossack Fonseca.

https://www.piquenewsmagazine.com/bc-news/13-british-columbians-facing-charges-in-alleged-1b-stock-fraud-scheme-4860972

MAN ARRESTED FOR SMUGGLING MILLIONS FROM LONDON TO DUBAI

On 14 December, BNN Bloomberg reported that police in the UK have arrested a key figure in a £100 million money laundering scheme, a 46-year-old Emirati, at a flat in London’s upmarket Mayfair district, alleging that he organised a “mule network” of couriers carrying suitcases packed with cash from the UK to Dubai.

https://www.bnnbloomberg.ca/mayfair-man-arrested-for-smuggling-millions-from-london-to-dubai-1.1695824

HOW COLLECTIVE ACTION INITIATIVES CAN BENEFIT FROM STUDYING INFORMAL CORRUPT NETWORKS

On 14 December, the Basel Institute on Governance published a Policy Brief into how informal networks link private and public sector actors to pursue common illicit goals, such as gaining an unfair business advantage or decreasing taxes owed.  Held together by corruption, such networks are highly resilient and effective.  The Policy Brief distils lessons for anti-corruption practitioners seeking to engage with the private sector through collective action.  It also explains why anti-corruption initiatives that focus purely on adding formal controls to high-risk processes, like audits and sanctions, can backfire.

https://baselgovernance.org/publications/policy-brief-8-it-takes-network-defeat-network-what-collective-action-practitioners

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