OTHER THINGS YOU MAY HAVE MISSED – JANUARY 26

Panama Covid-19 update – having avoided the rather large crocodile alongside the lake at the hotel entrance, back at home and back to what passes for normal.

In the media today, despite the massive rise in cases, it is reported that the new Albrook Hospital, which opened in June 2020 has reached 75% occupancy. Set up to deal with Covid patients, it is reported that, since its opening a total of 1,828 patients had been admitted , of which 78% have recovered and about 15% died, with the other 7% transferred to another facility.

Meanwhile, the section of the population aged between 60 and 79 years of age is the one that registered the highest incidence of new infections with Covid in Panama in the last 14 days, reported the Pan American Health Organization (PAHO).

For today, a new record of 17 fatalities reported, alongside 10,481 new cases; the number of currently active cases has risen by 2,931 to 81,848, with 78 in ICU and 730 in other wards.

26 JANUARY 2022

PANAMA: CORRUPTION IDEX – POSITION DESCRIBED AS “STAGNANT”

On 25 January, La Prensa reported on the results of the latest Corruption Perception Index from Transparency International, saying that Panama’s position is below the average of the American region, thus confirming that the levels of corruption in the public sector remain “stagnant” since 2012, when the country was first included in the Index.  Panama has a rating of 36, placing it 105th out of 180 countries.

https://www.prensa.com/politica/panama-gana-un-punto-en-el-indice-de-percepcion-de-la-corrupcion-2021-pero-sigue-debajo-del-promedio-regional/

SWITZERLAND: SANCTIONS ON 7 NICARAGUAN NATIONALS AND 3 NICARAGUAN ENTITIES WHO WERE LISTED BY THE EU ON 10 JANUARY

On 26 January, EU Sanctions blog reported that the Swiss had followed the EU in imposing these measures.

https://www.seco.admin.ch/seco/en/home/seco/nsb-news.msg-id-86865.html

https://www.europeansanctions.com/2022/01/switzerland-imposes-sanctions-on-nicaraguan-nationals-entities/

PODCAST: ALL ABOUT AUDITS

In the latest TRACE podcast, Ryan Murphy, a partner at PricewaterhouseCoopers’ Cyber, Risk & Regulatory Platform and lead on PwC’s US Investigations & Forensics Services Practice, joins the podcast to discuss audits: what the term means, what assurance they should and should not provide, and how they can be used for nefarious purposes.

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

COLLAS CRILL EXPLAINS… TERMINATION OF A TRUST

On 20 January, Collas Crill in Guernsey published an article in its series of guides in which we examine areas of law that frequently arise in practice.  It explains that there are a number of ways in which a trust might terminate.

https://www.mondaq.com/guernsey/trusts/1152748/collas-crill-explains-termination-of-a-trust

UK: CHANGES TO RIGHT TO WORK CHECKS

On 24 January, Shepherd and Wedderburn LLP explained changes to the Right to Works checks in the UK from 6 April.  It explains that virtual checks were only ever intended as a temporary concession because of the pandemic.  While they have been repeatedly extended throughout the pandemic, the Home Office is adamant that they will end once and for all, with 5 April being the final date on which they can be validly conducted.  From 6 April, they will cease to be acceptable.  Employers will have to revert to conducting manual checks where permissible, or online checks via the Home Office’s website 

https://www.mondaq.com/uk/operational-impacts-and-strategy/1153352/changes-to-right-to-work-checks

US: BEING A WHITE-HAT HACKER JUST GOT TOUGHER AS COMMERCE DEPARTMENT ISSUES NEW CYBERSECURITY EXPORT CONTROLS

On 21 January, an article from Fenwick & West LLP explained that the Department of Commerce’s Bureau of Industry and Security (BIS) has published new export controls on certain cybersecurity items that ban the export or resale of hacking tools to authoritarian regimes, and it created a new license exception for those items.  It says that network infrastructure manufacturers, cybersecurity software and service providers, IT forensics firms, bug bounty programs and those engaged in vulnerability testing and research may feel the impact of the rule.

https://www.mondaq.com/unitedstates/export-controls-trade-investment-sanctions/1152686/being-a-white-hat-hacker-just-got-tougher-us-commerce-department-issues-new-cybersecurity-export-controls-on-intrusion-and-surveillance-tools-updated

On 21 January, an article from Stephenson Harwood LLP reported that the High Court was recently asked to consider the legality and constitutionality of the letter of no consent regime and, in particular, whether as currently operated its protection of the community from money laundering had left them under-protected in terms of their fundamental rights to use their own property, which in this case was the funds held in a number of bank accounts.  It was described as a very significant judgment for Hong Kong’s banks and financial institutions, and the Court found that the way in which the Commissioner of Police has been triggering extensive use of the LNC process under OSCO is unlawful.

https://www.shlegal.com/insights/hong-kong’s-letter-of-no-consent-regime-declared-to-be-ultra-vires-the-organized-serious-crimes-ordinance-(-osco-)

CHINA’S EXPORT CONTROL WHITE PAPER AND ITS ATTITUDE TOWARD FOREIGN SANCTIONS COMPLIANCE

On 7 January, a post from Baker McKenzie was concerned with the Ministry of Commerce of China having released its first Export Control White Paper on 29 December, and simultaneously, it launched a dedicated “China Export Control Information” website, where it publishes export control related FAQ, case studies and training videos. 

https://sanctionsnews.bakermckenzie.com/chinas-export-control-white-paper-and-its-attitude-toward-foreign-sanctions-compliance/

SOMALIA’S DANGEROUS AUTHORITARIAN TURN

On 26 January, an article in Foreign Affairs starts by saying that, until recently, Somalia was on an upward trajectory and, although it continued to struggle with piracy, famine, and terrorism, the country was turning the corner after decades of bloody civil war.  It had rebuilt its security forces, judiciary, and other vital state institutions, and it had revived a dormant democratic tradition dating back to the 1960s.  However, last year President Mohamed Abdullahi Mohamed illegally extended his mandate by 2 years, triggering some of the worst violence in years and imperilling Somalia’s hard-won democratic gains.

https://www.foreignaffairs.com/articles/somalia/2022-01-26/somalias-dangerous-authoritarian-turn

UK: DORMANT ASSETS BILL 2021-22 

On 26 January, a briefing paper from the House of Commons Library about this Bill which was introduced in the House of Lords on 12 May 2021.  It passed Lords Third Reading on 23 November and was introduced in the Commons the following day.  The Bill would significantly expand the scope of the existing scheme to cover a range of financial products, being long-term insurance products, certain pension assets, collective investment scheme assets, client money, and proceeds or distributions from shares in traded public companies.  The Government defines a dormant asset as a financial product (such as a bank account) that hasn’t been used for many years and which the provider hasn’t been able to reunite with its owner despite efforts aligned with industry best practice.

https://commonslibrary.parliament.uk/research-briefings/cbp-9390/

URUGUAY AND CHILE, THE LEAST CORRUPT “IN A CORRUPT CONTINENT”

On 26 January, MercoPress reported on the Transparency Corruption Index, saying that corruption in Latin America is one of the most notorious problems on the region’s agenda after a decade of major judicial operations that exposed corruption schemes involving governments and companies alike.  According to Transparency International (TI), corruption has been entrenched in Latin America for more than a decade with little progress and many setbacks in terms of democracy and human rights.  It reports that Uruguay and Chile top this Index for the region, with 73 and 67 points respectively out of a maximum of 100, while Venezuela (14) and Nicaragua (20) remain the most corrupt countries in the region.

https://en.mercopress.com/2022/01/26/uruguay-and-chile-the-least-corrupt-in-a-corrupt-continent

THIRD LIBYA MINISTER DETAINED IN CORRUPTION INVESTIGATION

On 26 January, the New Arab reported that the Health Minister Ali Zenati and his deputy were held for questioning in the third detention of a cabinet member in recent weeks.  They were reportedly questioned over suspected “imports of oxygen concentrators at 10 times the market value”.

https://english.alaraby.co.uk/news/third-libya-minister-detained-corruption-probe

GAO PUBLISHES REPORT ON NEXUS BETWEEN VIRTUAL CURRENCIES AND HUMAN AND DRUG TRAFFICKING FINANCING

On 26 January, an article from Ballard Spahr LLP said that the Government Accountability Office recently issued a public version of a more detailed and confidential report previously sent to Congress summarising the GAO review of the use of virtual currencies to facilitate human and drug trafficking.  The GAO examined 2 issues:  US agencies’ collection of data on the use of virtual currencies for human and drug trafficking; and the steps taken and challenges faced by US agencies to counter human and drug trafficking facilitated by virtual currencies. 

https://www.moneylaunderingnews.com/2022/01/gao-publishes-report-on-nexus-between-virtual-currencies-and-human-and-drug-trafficking-financing/

US: PHARMACIST SENTENCED FOR $180 MILLION HEALTH CARE FRAUD SCHEME

A news release from US DoJ on 26 January advised that David “Jason” Rutland, 42, a Mississippi pharmacist had been sentenced to 5 years in prison in the Southern District of Mississippi for a multimillion-dollar scheme to defraud TRICARE and private insurance companies by paying kickbacks to distributors for the referral of medically unnecessary prescriptions.  The conduct resulted in more than $180 million in fraudulent billings, including more than $50 million paid by federal health care programs. 

https://www.justice.gov/opa/pr/pharmacist-sentenced-180-million-health-care-fraud-scheme

SCARY FRAUD ENSUES WHEN ID THEFT & USURY COLLIDE

On 25 January, a post from Krebs on Security reported on a case – asking what’s worse than finding out that identity thieves took out a 546% interest payday loan in your name?  How about a 900% interest loan?  Or how about not learning of the fraudulent loan until it gets handed off to collection agents?  The post relates one reader’s “nightmare” experience and spotlights what can happen when ID thieves and hackers start targeting online payday lenders.

https://krebsonsecurity.com/2022/01/scary-fraud-ensues-when-id-theft-usury-collide/

EU COMMISSION LAUNCHES SURVEY ON EU CUSTOMS AND TAX RULES GOVERNING E-COMMERCE TRANSACTIONS FROM THIRD COUNTRIES

On 26 January, a post from Baker McKenzie reported that the Commission had launched a survey on the overhaul of EU rules governing e-commerce transactions from third countries from a customs and taxation perspective.  The survey address issues related to both customs, VAT and excise duties, and states that whilst digitalisation of the economy and the increasing role of e-commerce offers a great potential for consumers and traders, it also presents challenges. 

https://www.internationaltradecomplianceupdate.com/2022/01/26/eu-commission-launches-survey-on-eu-customs-and-tax-rules-governing-e-commerce-transactions-from-third-countries/

https://www.visualcapitalist.com/mapped-corruption-in-countries-around-the-world/

GERMANY: REGULATION TO IMPLEMENT ANTI-TAX HAVEN LEGISLATION

On 26 January, KPMG reported that the regulation to apply the Act to Combat Tax Avoidance and Unfair Tax Competition was promulgated in the German Federal Law Gazette in December and has thus entered into force in principle.  It provides administrative and legislative measures that apply in relation to those states and territories that are non-cooperative tax jurisdictions.

https://home.kpmg/us/en/home/insights/2022/01/tnf-germany-regulation-implement-anti-tax-haven-legislation.html

ISLE OF MAN CONFIRMS KHALIL BEN AHMED BEN MOHAMED JARRAYA REMOVED FROM ISIL/AL-QAIDA SANCTIONS LIST

On 26 January, a news release confirmed that 1 name has been removed from the ISIL/Al-Qaida sanctions lists.

https://www.gov.im/news/2022/jan/26/financial-sanctions-isil-daesh-and-al-qaida/

HOME SECRETARY PONDERS EXTRADITION DECISION AFTER TYCOON MIKE LYNCH LOSES HIGH COURT FIGHT

On 26 January, LBC reported that Home Secretary Priti Patel is set to decide before the end of the week whether a British technology tycoon should be extradited to the US after being accused of fraud.  US authorities have accused Lynch of being involved in a multibillion-dollar fraud in the US over the sale of his software company, Autonomy, to Hewlett-Packard in 2011 for $11 billion dollars, which resulted in “colossal financial losses” for the US firm.  They claim that he deliberately overstated the value of his business, which specialised in software to sort through large data sets.

https://www.lbc.co.uk/business/dc6e29f1f1b942e39d39cb10859a0e78

https://www.aol.co.uk/money/home-secretary-ponders-extradition-decision-183818433.html

US NAVY COMMANDER PLEADS GUILTY IN THE RUN UP TO THE SEVENTH FLEET NAVY BRIBERY “FAT LEONARD” TRIAL

A news release from the US DoJ on 26 January advised that Commander Stephen Shedd had pleaded guilty in federal court to bribery charges, admitting that he and 8 other indicted leaders of the Seventh Fleet received more than $250,000 in meals, entertainment, travel and hotel expenses, gifts, cash and the services of prostitutes from foreign defence contractor Leonard Glenn Francis (aka “Fat Leonard”).

https://www.justice.gov/usao-sdca/pr/us-navy-commander-pleads-guilty-run-seventh-fleet-navy-bribery-trial

ANGOLA: MONEY LAUNDERING TRIAL OF FORMER TYCOON CARLOS MANUEL DE SAO VICENTE HAS BEEN POSTPONED 

On 26 January All Africa reported that the trial of the businessman linked to former Angolan president José Eduardo dos Santos at which he is accused of corruption, has been postponed until 11 February at the request of his lawyers.

https://www.africanews.com/2022/01/26/angola-money-laundering-trial-of-tycoon-carlos-manuel-de-sao-vicente-postponed

US: FEDERAL INVESTIGATORS PLAN TO SEIZE MORE THAN $6 MILLION IN REVENUE FROM THE SALE OF COMMERCIAL REAL ESTATE IN DALLAS ALLEGEDLY LINKED TO UKRAINE EMBEZZLEMENT

On 26 January The Real Deal reported that federal investigators plan to seize more than $6 million in revenue from the sale of commercial real estate in Dallas that the US DoJ says was embezzled by the owners of a Ukrainian bank, PrivatBank.

https://therealdeal.com/miami/2022/01/26/dallas-office-towers-tied-to-ukrainian-money-laundering-case-doj-says/

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

THE DIGITAL GOLD RUSH? DEBUNKING COMMON MYTHS ON THE CRIMINAL USE OF CRYPTOCURRENCIES

A news release from Europol on 26 January was concerned with a new report which offers insights into how criminals are using cryptocurrencies today. Based on the latest operational information contributed to Europol, data collected for the EU Serious Organised Crime Threat Assessment (SOCTA) 2021 and open sources, this report is said to debunk the following myths:

Cryptocurrencies have become the payment method of choice for criminals;

The criminal use of cryptocurrency is limited to cybercrime;

Illicit funds flow straight from wallet to wallet; and

Cryptocurrencies provide anonymity. 

https://www.europol.europa.eu/media-press/newsroom/news/digital-gold-rush-debunking-common-myths-criminal-use-of-cryptocurrencies

UK MINISTER QUITS OVER COVID LOAN FRAUD: WHAT WE KNOW SO FAR ABOUT THE UNFOLDING SCANDAL

On 26 January, an article in The Conversation looks at the background to, and implications of, the resignation of Treasury minister and Cabinet Office minister Lord Agnew, with his scathing rebuke to his government colleagues over COVID business loan fraud.  Lord Agnew’s resignation stems from his dissatisfaction with how the Bounce Back Loan Scheme has been handled by government, and called the government’s oversight of the scheme “desperately inadequate … and nothing less than woeful”.

https://theconversation.com/treasury-minister-quits-over-covid-loan-fraud-what-we-know-so-far-about-the-unfolding-scandal-175698

US: BUSINESS ADVISORY ON HEIGHTENED RISKS ASSOCIATED WITH DOING BUSINESS IN BURMA

On 26 January, FinCEN, the US Treasury and others published a Business Advisory on the risks and considerations for businesses and individuals with exposure to entities responsible for undermining democratic processes, facilitating corruption, and committing human rights abuses in Burma (Myanmar).

https://home.treasury.gov/system/files/126/20220126_burma_advisory.pdf

THINGS YOU MAY HAVE MISSED – JANUARY 25

Panama Covid-19 update – the Omicron wave continues, with reports in the media about the adverse effects on the tourism industry – this being the “Summer” time here. That said, where I am seems reasonably busy, with many foreigners – Dutch, German, French, American, as well as a scattering of locals.

However, there were another 9,241 new cases reported today and another 15 fatalities. There are now said to be 78,917 active cases, with 88 in ICU and 745 in other wards. Testing still returns a high positive result, with 25,555 tests showing a 36.2% positive result.

25 JANUARY 2022

INDONESIA’S DRIVE TO LIFT RESOURCE CURSE SHAKES GLOBAL PRODUCERS

Nikkei Asia reports that Indonesia is set to essentially ban exports of unprocessed minerals – including tin, bauxite, gold and copper, crucial materials for global industries – in the middle of 2023. Should the policy take force, its impact will be immeasurable: Some of the minerals are critical to electric vehicles, advanced semiconductors and other leading industries of the 21st century.

https://asia.nikkei.com/Spotlight/Asia-Insight/Indonesia-s-drive-to-lift-resource-curse-shakes-global-producers

BURKINA FASO MILITARY SAYS IT HAS SEIZED POWER

On 24 January, the BBC and others reported the coup in Burkina Faso.

https://www.bbc.com/news/world-africa-60118993

LANDLOCKED MALI TURNS TO NEIGHBOURS TO SIDESTEP TRADE SANCTIONS

On 19 January, Bloomberg reported that Mali says it’s secured support from Guinea and Mauritania to sidestep sanctions.

https://www.bloomberg.com/news/articles/2022-01-19/landlocked-mali-turns-to-neighbors-to-sidestep-trade-sanctions

UK REMOVES 1 NAME FROM ISIL/AL-QAIDA SANCTIONS LIST

On 25 January, a Notice from HM Treasury advised that Khalil Ben Ahmed Ben Mohamed JARRAYA had been removed from its sanctions lists.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1049829/Notice_ISIL__Da_esh__and_Al-Qaida_250122.pdf

https://www.statista.com/chart/26668/main-import-countries-sources-africa/

MONEYVAL PUBLISHES TYPOLOGIES REPORT ON AML/CFT SUPERVISION IN TIMES OF CRISIS

On 25 January, MONEYVAL published a new guide which aims to help authorities conduct effective AML/CFT supervision in times of crisis or difficult external factors. It is based on information collected from supervisors across MONEYVAL jurisdictions and other international actors on the measures they have taken to overcome the difficulties caused by the COVID-19 pandemic, including operational limitations, notably the physical movement restrictions impeding the execution of on-site visits, limited human resources and technical complications. MONEYVAL member States and territories will be invited to provide feed-back on the use of its findings in one year.

https://rm.coe.int/typologies-report/1680a54995

UK MINISTER RESIGNS OVER “WOEFUL” HANDLING OF COVID-RELATED FRAUDS

On 25 January, the Insurance Times reported that Lord Theodore Agnew had resigned in protest at the handling of Covid-related fraud in support schemes.

https://www.insurancetimes.co.uk/news/uk-anti-fraud-minister-resigns-over-governments-woeful-handling-of-covid-business-loan-fraud/1440103.article

3 REASONS JAMAICA SLIPPED IN 2021 CORRUPTION RANKING

On 25 January, The Gleaner carried an article dealing with the comments of the principal director of the National Integrity Action (NIA) Professor Trevor Munroe has asserted that Jamaica’s score and rank on the 2021 Corruption Perception Index (CPI).  Jamaica fell to 70th in 2021 from 69th out of 180 countries in 2020.

https://jamaica-gleaner.com/article/news/20220125/three-reasons-jamaica-slipped-2021-corruption-ranking

FUGITIVE GUATEMALA MINISTER SURRENDERS AMID ATTACKS ON JUSTICE SYSTEM

On 25 January, Insight Crime reported that fugitive former minister, José Luis Benito Ruiz, linked to a multi-million dollar cash seizure has turned himself over to Guatemalan authorities at an opportune time – after the anti-impunity unit investigating his case has been gutted.

https://insightcrime.org/news/fugitive-guatemala-minister-turns-opportune-time

AFTER A RECORD 2021 – ANTWERP PORT STARTS 2022 WITH 657 KG SEIZURE OF COCAINE

On 24 January, the Brussels Times reported the latest large seizure of cocaine in a metal shipment from Brazil.

https://www.brusselstimes.com/203066/657-kg-of-cocaine-seized-at-antwerp-port

EUROPEAN COMMISSION’S ANNUAL RULE OF LAW REPORTS: A NEW MONITORING TOOL

On 25 January, the EU Parliament Research Service said that the annual rule of law reports, launched by the Commission in September 2020, are a new addition to the European institutions’ rule of law toolbox. The exercise can be described as a monitoring tool, as it collects data on the state of the rule of law in each of the 27 EU Member States but without drawing legal conclusions or giving specific recommendations.  They cover 4 subject areas in all 27 Member States: (i) justice systems; (ii) the anti-corruption framework; (iii) media pluralism; and (iv) other institutional issues related to checks and balances.

https://www.europarl.europa.eu/RegData/etudes/BRIE/2022/698891/EPRS_BRI(2022)698891_EN.pdf

UN DELETES 1 NAME FROMISIL/AL-QAIDA SANCTIONSLIST

On 25 January, the UN reported that the relevant Sanctions Committee had deleted Khalil Ben Ahmed Ben Mohamed JARRAYA from its sanctions lists.

https://www.un.org/press/en/2022/sc14773.doc.htm

NIGERIA: COURT ORDERS ARREST OF EX-PETROLEUM MINISTER

On 24 January, the Vanguard reported that a Federal High Court sitting in Abuja has issued a warrant for the arrest of former Minister of Petroleum Resources, Diezani Alison-Madueke, in the UK.

https://www.vanguardngr.com/2022/01/breaking-money-laundering-court-orders-arrest-of-ex-petroleum-minister-diezani/

ARMS SALES RISK INDEX

On 18 January, the Cato Institute published the 2021 edition of this report which measures the factors linked to negative outcomes of arms sales, such as dispersion, diversion, and the misuse of weapons by recipients, the index provides a way to assess the risk involved with selling arms to another nation.  It is said that the report includes a special section focused on the risks associated with the sale and transfer of small arms and light weapons (SALW).  It says that though major conventional weapons like fighter jets, anti‐​aircraft missile systems, and tanks comprise most US arms sales from a financial perspective, SALW are far more likely to wind up in the wrong hands and to be used in ways that the US does not intend.  The US remains the world’s dominant exporter of weapons, and its share of the global arms market in 2020 was 41%.  It concludes that, to date, the Biden administration has continued Trump administration policies that increase the risks from arms sales in general and from SALW in particular.

https://www.cato.org/study/2021-arms-sales-risk-index#conclusion

CHILE’S DRUGS MICROTRAFFICKING ZERO PROGRAMME: SUCCESS OR FAILURE?

On 24 January, Insight Crime reported that, after 7 years in action, Chile’s hardline strategy to rid the country of low-level drug peddling has been lauded as a success and even replicated abroad. But is the tough stance really working?

https://insightcrime.org/news/chiles-microtrafficking-zero-program-success-or-failure/

TRANSPARENCY INTERNATIONAL CORRUPTION PERCEPTION INDEX

On 25 January, Transparency International released its latest edition of the Index, saying that the latest analysis shows that unchecked transnational corruption also enables human rights violations around the world.  It says that results over the past decade demonstrate that top-scoring countries have little to show for their efforts to protect the integrity of their own public sectors.  Their backsliding offers a cautionary tale about complacency, which is detrimental not only to global anti-corruption efforts but also to top-scoring countries’ own affairs, and government leaders in several countries got caught bending the rules.

https://www.transparency.org/en/news/cpi-2021-trouble-at-the-top

https://www.transparency.org/en/cpi/2021

SWITZERLAND HAS MANDATED HUMAN RIGHTS DUE DILIGENCE

A post on the FCPA Blog on 25 January advised that, from 1 January, new rules have now become a reality for certain Swiss companies.  The post contains an overview of key provisions and concepts that are now applicable.

https://fcpablog.com/2022/01/25/switzerland-now-has-mandated-human-rights-due-diligence/

MIAMI GOLD HAULER CUTS PLEA DEAL IN HUGE SOUTH AMERICAN-CARIBBEAN MONEY -LAUNDERING CASE

On 25 January, the Miami Herald reported on a trucking company owner charged with playing a supporting role in a gold smuggling scheme spanning South America, the Caribbean and South Florida that had pleaded guilty to submitting false customs documents that concealed the true origins of the gold being imported through Miami International Airport.  He admitted as part of his plea agreement that he helped import thousands of kilos of gold valued at $140 million into the US from Curaçao, knowing that the customs paperwork falsely represented its origins.

https://www.miamiherald.com/news/local/article257691638.html#storylink=cpy

TRANSPARENCY INTERNATIONAL CORRUPTION PERCEPTION INDEX

On 25 January, Transparency International released its latest edition of the Index, saying that the latest analysis shows that unchecked transnational corruption also enables human rights violations around the world.  It says that results over the past decade demonstrate that top-scoring countries have little to show for their efforts to protect the integrity of their own public sectors.  Their backsliding offers a cautionary tale about complacency, which is detrimental not only to global anti-corruption efforts but also to top-scoring countries’ own affairs, and government leaders in several countries got caught bending the rules.

https://www.transparency.org/en/news/cpi-2021-trouble-at-the-top

https://www.transparency.org/en/cpi/2021