Last day of tour – hopefully will get back to something like normal (whatever that is) from tomorrow…

Panama Covid-19 update – the Rt rate has fallen slightly from 0.67 to 0.66, hence still below the important 1.0 level. Meanwhile, 269 new cases and 3 new fatalities have been reported; with there now being 2,449 active cases – 15 in ICU and 112 in other wards.

Meanwhile, the Government has announced that the last “high risk” countries (including the UK) have been removed from the list of those countries whose arrivals in panama faced special conditions.

18 MARCH 2022

UK: High Court confirms narrow test for “iniquity exception” to legal professional privilege (LPP)

On 16 March, Travers Smith LLP published an article saying that the High Court has confirmed the narrow scope of the “iniquity exception” to legal professional privilege in a fraud claim brought by a London law firm against a former client.  The firm sought to rely on privileged communications and confidential information in its evidence.  The Court held that the firm could not rely on the iniquity exception and rejected an argument that a client owes its solicitor a duty of good faith.  The iniquity exception prevents a party from asserting privilege in relation to documents brought into existence for the purpose of furthering a crime or fraud.

Germany probes possible exports of dual-use goods by Bosch

On 18 March, KFGO reported that Germany’s economy ministry has triggered an investigation into whether engineering group Bosch violated an export ban on goods that can be used for both civilian and military purposes.  Meanwhile, Deutsche Welle considers how dual-use goods, until now, could have slipped under the radar.

Australia sanctions Russian billionaires with mining industry links

On 17 March, Yahoo Finance reported that Australia has imposed sanctions on two Russian oligarchs with links to its mining industry – Oleg Deripaska and Viktor Vekselberg, one of them a billionaire with an investment connection to Rio Tinto’s Gladstone alumina refinery joint venture.

Russia retaliates against sanctions by curtailing foreign owners’ IP rights

On 17 March, Osborne Clarke reported that legislation has been passed allowing goods to be exempted from intellectual property protection and compulsory licensing without compensation.  The change in law allows the IP rights of rightsholders who are associated with foreign states that commit “unfriendly acts” against Russia to be used without their consent.

Russian Federation is excluded from the Council of Europe and MONEYVAL

On 17 March, the Council of Europe said that Russia had been excluded from its activities, including the FATF-style regional body MONEYVAL.

Bank of Israel issues draft guidelines for digital asset AML/ CFT

On 18 March, Coingeek reported that the Israeli digital asset firms will now be able to access banking services easily after the Bank of Israel clarifies its stance on the provision of these services to virtual asset service providers (VASP). The new guidelines prohibit banks from denying services to VASP as adoption surges.

Lebanon: Authorities arrest brother of central bank chief

On 17 March, the Business Standard reported that the move comes after the same judge imposed a travel ban and froze some assets of the central bank governor, Riad Salameh, 71, who is accused of corruption.  A judge questionedRaja Salameh for several hours before placing him under arrest.

Rome film producer and 2 cops arrested in Camorra laundering

On 17 March, ANSA reported that Daniele Muscariello, 45, owner of the Henea Production company, was arrested along with another 8 people including 2 police officers in the probe into one of the first cases of the Camorra investing in the Italian cinema industry.

EU Commission initiates ban on 2 harmful new drug substances

On 18 March, the EU advised that the Commission is proposing to ban 2 new drug substances across the European Union: 3-MMC and 3-CMC.  The substances are life threatening due to their toxicity. They have been available in the EU since at least 2012 and 2014, respectively. Both substances are mainly sold as a powder, but also available as tablets and capsules.  Once the EU measure is in force, EU Member States will have 6 months to enact the ban into national law.

Guernsey suspends all tax cooperation with Russia

On 17 March, Guernsey announced that it was suspending all forms of tax cooperation (exchange of information for tax purposes) with Russia, with immediate effect.


On 17 March, Europol reported that it had decided to suspend any cooperation with Russia, including through the strategic agreement concluded in November 2003.

UK Register of Overseas Entities – impact on English and Welsh real estate: Interactive tool kit

On 17 March, Dentons announced that it had developed an interactive toolkit about the Register which will impact all overseas investors into UK real estate.

Russian sanctions: the impact of UK, EU and US sanctions for UK and EU businesses

On 18 March, Out-Law published a Guide about the financial, sectoral and trade sanctions which target Russia-related business.

New Zealand: impact of Russian sanctions on AML/CFT reporting entities

A release on Mondo Visione on 18 March advised that the 3 AML/CFT Act supervisors – FMA, DIA and RBNZ – have provided an update to reporting entities on what is required of them under the new Russia Sanctions Act 2022. The Ministry of Foreign Affairs and Trade (MFAT) has detailed the individuals, entities, and classes of persons impacted by the Sanctions Act 2022

Sea piracy and armed robbery in Asia – update

On 18 March, an article in Hellenic Shipping News says that the overall situation in Asia in 2021, compared to 2020, has improved with regards to the number of reported incidents related to piracy and robbery on ships, but there have been a continued increase of incidents in the Singapore Straits.

Iran’s Revolutionary Guards Called For Travel Ban On Ex-Oil Officials To Prevent Disclosure Of Sanctions-Evading Tactics

On 17 March, Rferl reported that last year the IRGC urged the judiciary to issue travel bans against several oil officials for fear they could expose the “secret” tactics Iran has used to evade US sanctions and sell its oil.  A leaked document contains names and national identification numbers of 37 mid-ranking officials and managers, including from the Oil Ministry as well as 2 state-owned companies, the National Iranian Oil Company and the National Iranian Tanker Company.

China repatriates trafficked ‘illegal’ workers found at Guangdong factory

On 17 March, RFA reported that nearly 50 Vietnamese nationals have been sent back home, while 4 Myanmar nationals will soon follow.  The migrant workers found working illegally at a factory in Yangjiang.  Myanmar sources in China said the workers had been smuggled into China by labour agents and employed illegally.

Australia: Star Entertainment Group allegedly disguised as “hotel expenses” some $900 million in transactions linked to Chinese high rollers

On 17 March, Financial Review reported that an inquiry heard the plan was to help them circumvent rules and access cash to gamble at its flagship casino in Sydney.  The inquiry also heard a Star senior executive “misled” the National Australia Bank when the bank queried the activities.

US: OCC Final Rule Addressing Authority for Exemptions to SAR Requirements

On 16 March, the Office of the Comptroller of the Currency (OCC) said that it had issued a final rule amending the OCC’s suspicious activity report (SAR) regulations.  The rule clarifies the OCC’s authority to issue exemptions from the requirements of those regulations based on a request from a national bank or federal savings association, including federal branches and agencies of foreign banks.

Kroll Anti-Money Laundering and Countering the Financing of Terrorism Focus Report 2022

On 17 March, Kroll said that its latest report was available after it had conducted a survey of central banks across a variety of jurisdictions to explore how they are addressing AML/CFT risks.  Its finding include pressure as the payments landscape shifts with the growth of payment and e-money firms, and that more cross-border collaboration is needed to effectively tackle shared financial crime risks.

Russia’s richest man may have avoided sanctions freeze on £1 billion Tui shares

On 16 March, the Guardian reported that Alexei Mordashov sold most of 34% stake in world’s biggest tourism operator to a company in the BVI, and hence may have avoided a freeze on a shareholding in Tui, the world’s biggest tourism company.

Jersey: finance sector has been urged to tighten monitoring of all customers with ties to Russia or Belarus

On 18 March, Jersey Evening Press reported that the External Relations Minister Ian Gorst and the Jersey Financial Services Commission had warned that the Island’s largest industry needed to be ‘particularly vigilant’ as the financial system was more likely to be ‘abused’ by those seeking to support Russian President Vladimir Putin’s war effort.  A statement added that increased risks identified included money laundering, terrorist financing and proliferation financing – gathering funds involved with the acquisition of chemical, nuclear or biological weapons.

US Treasury Sanctions Guatemala’s Los Huistas Drug Trafficking Organisation with Ties to Mexican Cartels

On 18 March, US Treasury advised that OFAC has designated the Los Huistas Drug Trafficking Organisation (DTO) – the dominant criminal structure in the Guatemalan department of Huehuetenango (along the border of Guatemala and Mexico) – and its leaders pursuant to Executive Order (E.O.) 14059 for drug trafficking that threatens the people and security of the United States and Guatemala.

eDisclosure Practical and Technical Checklist

On 18 March, Field Fisher published this Checklist saying that disclosure (or discovery, as it is known outside the UK) is to ensure that parties to proceedings know of all documents that relate to their case, thus avoiding an ambush at trial. It is of paramount importance that parties understand disclosure requirements, particularly where electronic documents are concerned.  The checklist provides a high-level best-practice approach to key electronic disclosure (eDisclosure/eDiscovery) requirements in the UK.

North Korean Hackers’ Ties to the Global Underground

On 15 March, the Belfer Center published a report saying that the illicit revenue operations generate helps blunt the impact of tough global sanctions and supports the regime’s ballistic-missile and nuclear-weapons programs. It can enable the procurement of banned military or dual-use technology as well as luxury goods for Pyongyang elites.  Profits from computerised theft are also believed to help fund other components of North Korea’s cyber program, from hacker training to tooling development to non-remunerative campaigns designed to gather intelligence or cause destruction.  The report explores North Korean financially motivated actors’ convergence of interests and tradecraft with cybercriminals, focusing on their dealings with the Russian-language underground.


On 18 March, OFAC published new General License 24: Transactions Related to the Provision of Maritime Services and a new FAQ.


On 18 March, a Client Alert from Wilmer Hale, published in both English and Spanish and accompanied by a Spanish-language webcast — summarises key Latin America anti-bribery enforcement developments from 2021 and provides predictions for 2022.

US: FAQ on imports and exports of alcohol, tobacco (Russia and Belarus)

On 18 March, KPMG reported that the US Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB) has updated a set of FAQ regarding imports and exports of alcohol beverages and tobacco products to reflect an Executive Order prohibiting the importation of alcohol beverages of Russian origin.


On 18 March, MSN reported that Elvira Nabiullina, 58, reportedly handed in her resignation after arguing with Putin over the devastation caused by Western Sanctions on the Russian people.

UK: 79 entries amended on the consolidated sanctions list and Russian sanctions amendments

On 18 March, HM Treasury advised that 79 entries have been amended on the consolidated list and remain subject to an asset freeze.  The entries relate to the sanctions lists concerned with cyber, Russian, Belarus, chemical weapons and Zimbabwe sanctions.  In addition, 2 duplicate entries have also been removed from the Russia financial sanctions regime.


On 18 March, EU Council Decision 2022/450/CFSP renewed the EU restrictive measures should until 31 March 2024.


On 18 March, 3 news releases advised that North Macedonia, Montenegro, Albania, Bosnia and Herzegovina, Iceland, Liechtenstein and Norway, as well as Ukraine align themselves with Council Decision (CFSP) 2022/430; Council Decision (CFSP) 2022/429 (which adds 15 individuals and 9 entities to the list of persons, entities and bodies);  and Council Decision (CFSP) 2022/241 (which adds 5 individuals to the list of persons, entities and bodies subject to restrictive measures).

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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