Panama Covid-19 update – 300 new cases and 3 new fatalities reported today; with 2,435 active cases – just 18 in ICU nationwide, with 117 in other wards.

16 MARCH 2022

Greetings from Boquete!    Still on tour, so still not quite normal service…

What documents and records must a BVI company keep?

On 15 March, Mourant published an article which examines the documents and records that must be kept by a BVI company limited by shares that does not carry on a regulated activity.

Court of Appeal draws distinction between claims for recovery of tax and restitution for tax paid out fraudulently

A Commentary from RPC was concerned with a case in which the English Court of Appeal considered the rule which provides that English courts do not have jurisdiction over actions for “the enforcement, either directly or indirectly, of a penal, revenue, or other public law of a foreign State”.  The Court decided that the Danish tax authority’s claim did not fall within this rule as it concerned the restitution of monies misappropriated by fraud rather than enforcement of tax.

Russian-Owned Super Yachts Going Dark to Avoid Sanction Seizure

On 11 March, USNI reported that the boats were turning off their automated identification systems (AIS) and running to safe harbours. Some are be sailing to remote Russian ports not normally associated with luxury yachts.

Russia: sanctions on President Biden, Secretary of State Antony Blinken, former Secretary of State Hillary Clinton, PM Trudeau and other US and Canadian officials

On 16 March, EU Sanctions blog reported that Russia had imposed a slew of its own sanctions on various officials in response to Western sanctions.  The measures block their entry into Russia and freeze assets held in Russia.


On 16 March, the Isle of Man confirmed changes that had taken place on the UK sanctions lists.

Switzerland: more sanctions on Russians in line with EU

On 16 March, Reuters reported that Switzerland has adopted more European Union sanctions against Russian individuals and entities published in response to Moscow’s invasion of Ukraine.  Switzerland’s list of sanctions now fully mirrors that of the EU.

Sanctions Against Russian Vessels May Become Burden for Fisheries Cooperation

On 16 March, High North News reported that an expert has said that the political debate should be clearer about the consequences of a potential ban against Russian vessels in Norwegian ports.  It refers to cooperation with Russia about fisheries in the Barents Sea nor have the fisheries protection zone around Svalbard.  Sanctions would prevent Russian vessels from docking at Norwegian ports.

Australia: Cocaine smuggling Sydney socialite appeals jail sentence

On 16 March, reported that a former Sydney socialite and property developer, who was jailed over an attempt to smuggle $85 million worth of cocaine into Australia, is continuing his appeal.  Matthew James Doyle was sentenced to a minimum of 5 years behind bars in 2020.

The Football Index collapse – a timeline

On 16 March, the House of Commons Library published a briefing paper about BetIndex Limited, trading as Football Index, a sports betting platform that launched in 2015.  In March 2021, BetIndex suspended operations and appointed administrators, and reportedly customers could lose more than £90 million.  The briefing gives a timeline of events and links to further sources.

Iran readies tanker fleet as pressure to lift sanctions builds

On 15 March, Lloyds List reported that tanker company NITC has sent 24 of its ageing fleet to repair yards as negotiations that could return Iranian oil to the market near completion and Iranian vessels start openly trading with AIS turned on for the first time in years.

Report should spur brands to develop an anti-counterfeiting strategy

On 16 March, Out-Law published an article saying that businesses need to develop and implement an effective anti-counterfeiting strategy, experts have said, after a new report from Europol and the EU Intellectual Property Office (EUIPO) highlighted increased counterfeiting risks.  The report contains a threat assessment.  Imports of counterfeit and pirated goods reached €119 billion in 2019, according to the data collected. This represented 5.8% of all goods entering the EU.

Argentina Cracks Down on Crypto With AML Rules

On 16 March, Decrypt reported that Argentina’s Unidad de Información Financiera (UIF) – its FIU – is now reportedly working on adding crypto firms to the list of entities subject to AML reporting requirements.  It is said that the plan is for new regulations to come into force this year.

Russian clients have up to CHF200 billion in Swiss banks

On 15 March, Swissinfo reported that the president of the Swiss Bankers Association made the estimate at the group’s annual news conference.

US: Russian Oligarch Andrey Muraviev Charged With Making Illegal Political Contributions

A news release from US DoJ on 14 March advised the unsealing of an indictment against ANDREY MURAVIEV (aka Andrey Muravyov), a Russian citizen, charging him with making illegal political contributions as a foreign national, and conspiring to make illegal political contributions as a foreign national in the names of straw donors.  He is charged with conspiring with Lev Parnas, Andrey Kukushkin, and Igor Fruman, and others, who were convicted at trial or have pleaded guilty to these crimes.

ISLE OF MAN STATEMENT: Registries have cancelled the registrations of a number of aircraft and yachts that have links with individuals or organisations that have appeared on any of the global lists, including UK and EU

On 16 March, a news release from the Isle of Man announced the “proactive” steps its aircraft and ship registries had taken.


The US Treasury said that Congress established the Kleptocracy Asset Recovery Rewards Program to further the US Government’s commitment to combating foreign government corruption and serve United States efforts to identify and recover stolen assets, forfeit proceeds of corruption, and, where appropriate and feasible, return those stolen assets or proceeds to the country harmed by the acts of corruption.  The Program may pay rewards to qualified individuals who provide information leading to the restraint or seizure, forfeiture, or repatriation of “stolen assets”, as defined by the law, linked to foreign government corruption.

The US Treasury has publicly released 28 names of individuals from the list who have been sanctioned by multiple jurisdictions, including the United States

Mexican authorities have extended the grace period for its CCP anti-smuggling requirement for all shipments within, to and from Mexico

On 16 March, Loadstar reported that the new Complemente carta porte (CCP) regime came into effect on 1 January, with a grace period for compliance until 31 March.  This has been pushed back until the end of September.  CCP is an annex to digitalised tax receipts that complements bills of lading with which Mexican owners of shipped goods, forwarders and carriers must comply.  CCP applies to all shipments and covers all modes of transport.

Cryptocurrency’s Role in the Russia-Ukraine Crisis

On 15 March, an article from CSIS says that finance typically plays a major role in wars, but the Russia-Ukraine war is the first major conflict with a prominent role for cryptocurrencies.  Questions have been raised over whether cryptocurrencies can be used by Russian actors to bypass sanctions. The prominence of crypto in this conflict could influence global perceptions of the technology, including among governments considering new regulations.

Podcast: The Latest from the DOJ on Extortion

In the latest TRACE podcast, Bill Steinman of Steinman & Rodgers joins the podcast to discuss the recent Opinion Procedure Release addressing extortionate demands.  He also reviews the substantial grey area of emergencies involving the detention of personnel and confiscation of property that are arguably legal under local law.

FinCEN Announces Actions to Support REPO Multilateral Task Force and Ongoing US Government Efforts to Combat Foreign Government Corruption

On 16 March, a news release from FinCEN announced its efforts to support the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force, announced by the US Treasury and DoJ.  A separate Alert highlights the importance of financial institutions identifying and quickly reporting suspicious transactions by sanctioned Russian elites and their proxies that involve real estate, luxury goods, and high-value assets.  FinCEN has joined the FIU of Australia, Canada, France, Germany, Italy, Japan, New Zealand, the United Kingdom, and the Netherlands in issuing a statement of intent to form an FIU Working Group on Russia-Related Illicit Finance and Sanctions.   FinCEN is continuing robust engagement with financial institutions to explore typologies and share best practices to enable the private sector to better identify corrupted gains by elites, oligarchs, and their proxies and provide FinCEN and law enforcement with critical information to track, freeze, and seize the assets of Russian elites and their proxies.

UK: Ivory Prohibition (Civil Sanctions) Regulations 2022

These Regulations make provision in relation to enforcement of the prohibition on dealing in ivory imposed by section 1 of the Ivory Act 2018.  It makes detailed provision for the civil sanctions and enforcement regime which underpins the Ivory Act 2018.  The Act will prohibit dealing in ivory and items made of, or containing, ivory, unless they meet one of the narrowly defined exemptions to the ban.  The Act establishes a number of civil sanctions that may be made use of in response to breaches of the Act, namely the imposition of monetary penalties or stop notices, the entering into of enforcement undertakings and enforcement cost recovery notices. This instrument makes detailed provision in relation to these, other than for enforcement cost recovery notices.

New Restrictions on Exports to Russia: US Technology Embedded in Products Made Overseas

On 16 March, Sunstein LLP published an article saying that the foreign direct product (FDP) rule represents an ambitious attempt by the United States to expand its export controls to goods manufactured in foreign countries.  This rule was promulgated by the Commerce Department’s Bureau of Industry and Security (BIS).  BIS regulates the export of sensitive items that are not munitions, the export of which is subject to State Department control under the International Traffic in Arms (ITAR) regulations.  The FDP rule subjects to US export regulations products made overseas that are the direct product of technology or software of US origin; or that are the direct product of a plant, or major component of a plant, that is itself a direct product of US-origin technology or software.

UK: Charities Act 2022 receives Royal Assent

On 11March, the Law Commission reported on the Royal Assent of this Act.  It says that the Act will allow charities to be run more efficiently, striking a careful balance between cutting regulation to liberate charity resources and maintaining appropriate regulatory oversight and safeguards.  The reforms will allow charities to be run more efficiently by empowering trustees and by reducing unnecessary bureaucracy, in turn enabling more funds to be used for charitable purposes.  It promotes consistency in the law by streamlining a number of processes across the different legal forms of charities.  The changes the Act makes are technical but will have great positive impact on the sector by improving the ways in which charities are run. A few of the key reforms being introduced are outlined in the article.

UK: Law Commission recommendations to allow electronic documents would revolutionise trade

On 16 March, the Law Commission published its recommendations and draft legislation to allow for electronic versions of trade documents, such as bills of lading and bills of exchange.

Portugal to change law under which Roman Abramovich gained citizenship

On 16 March, the Guardian reported that the Portuguese government is to tighten the law granting nationality to the descendants of Jews who were expelled from the Iberian peninsula 500 years ago, as concerns grow over the controversial decision to award Roman Abramovich citizenship because of his apparent Sephardic Jewish heritage.

Ukraine war’s impact on trade and development

On 16 March, an article from the UN Committee on Trade & Development says that the organisation’s rapid assessment of the war’s impact on trade and development shows a rapidly worsening outlook for the world economy, with the situation especially alarming for African and least developed countries.  It says that concern abounds over the 2 fundamental “Fs” of commodity markets – food and fuels.  Ukraine and Russia are global players in agri-food markets, representing 53% of global trade of sunflower oil and seeds and 27% of global trade of wheat.

US Lawmakers Probe Early Release of Top Russian Cybercrook

On 15 March, the Krebs on Security blog reported that Aleksei Burkov, a cybercriminal who long operated 2 of Russia’s most exclusive underground hacking forums, was arrested in 2015 by Israeli authorities.  The Russian government fought Burkov’s extradition to the US for 4 years — even arresting and jailing an Israeli woman to force a prisoner swap.  That effort failed: Burkov was sent to America, pleaded guilty, and was sentenced to 9 years in prison. But a little more than a year later, he was quietly released and deported back to Russia. Now some Republican lawmakers are asking why a Russian hacker once described as “an asset of supreme importance” was allowed to shorten his stay.

UK: Ministerial approval of JMLSG guidance

On 16 March, LexBlog reported that on 15 March, the Joint Money Laundering Steering Group (JMLSG) announced that Ministerial approval had been given to various revisions to its AML guidance.

The French Seizure of a Russian Merchant Vessel Raises Questions About High Seas Freedoms

On 16 March, an article on Lawfare is the second of 2 articles that analyse the seizure of Baltic Leader, a Russian car-carrier merchant ship intercepted by the French Navy in February.  This article turns from the law of neutrality to the law of the sea, addressing how the sanctions-based arrest relates to freedom of navigation and exclusive flag state jurisdiction on the high seas.

The first article is at –

4 Civil Guards in Spain accused of spying on the girlfriend of former Panama President Martinelli

On 16 March, La Estrella reported that 4 agents of the Civil Guard of the Balearic Islands had been arrested.  It says that, apparently, those arrested are accused of monitoring and spying on the Mallorca-based girlfriend of the former president of Panama, Ricardo Martinelli, during Summer 2020, even going so far as to place a globaliser on the woman without her consent.


Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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