OTHER THINGS YOU MAY HAVE MISSED – MARCH 28

Panama Covid-19 update – first day of relaxed mask mandate – with facemasks no longer required in “open spaces” when can distance from others – and with face screens no longer required on public transport. Out and about it seemed many people still wearing masks in the street (this may have been at least partly for the practical reason that, in a country where people don’t wear jackets or coats, it’s easier to carry on wearing them, as you have few other options to store it if you remove it – and you should be handling them unnecessarily anyway).

Also, from today, “mass religious activities” will be allowed, while those congregations that consider performing these activities, must comply with bioseafety measures (use of mask, hand hygiene etc).

Meanwhile, 125 new cases and 2 new fatalities reported, with active cases down a further 36 to stand at 2,414, of whom 11 are in ICU and 86 in other wards, and another 25 in the so-called “hospital hotel” quarantine.

28 MARCH 2022

WORLD’S LARGEST CHARTER SUPERYACHT DETAINED IN DOMICICAN REPUBLIC

On 27 March, it was reported that MY Flying Fox had been detained in the Dominican Republic at the request of the US authorities.  The Department of Homeland security asked the Dominican government to prevent the vessel from leaving.  The 136-metre long superyacht os of 9,000 gross tons displacement.  The ultimate beneficial owner of the vessel is thought to be Dmitry Kamenshcik, the billionaire owner of Moscow’s Domededovo Airport.

https://www.youtube.com/watch?v=sR4lFm-ivpo

https://www.imperial-yachts.com/charter/superyachts-for-charter/flying-fox

https://www.superyachtnews.com/business/flying-fox-detained-in-the-dominican-republic 

THE HIDDEN STORY OF A NOTORIOUS GUATEMALAN NICKEL MINE

On 27 March, The Intercept carried an article about the Fenix nickel mine, owned by the Switzerland-based Solway Investment Group.  Journalists reporting for The Intercept and 19 other media organisations in Europe and Latin America joined forces to investigate the Fenix nickel mine; Solway; and the conglomerate’s 2 Guatemalan subsidiaries, Pronico and CGN.  It is said that Solway’s subsidiaries failed to report pollution and used a host of troubling methods to exert influence over local politics and repress dissent.

https://theintercept.com/2022/03/27/solway-guatemala-nickel-mine 

MADELEINE ALBRIGHT WAS AMBASSADOR FOR HERBALIFE PYRAMID SCHEME

The Intercept on 25 March carried an article reflecting (critically) on the life of the former UN ambassador and Secretary of State under President Bill Clinton.  It reminds one that shewas a long-time brand ambassador for Herbalife Nutrition, a dietary supplement company, reportedly being paid $10 million for these efforts over 6 years.  In a 2016 settlement with the Federal Trade Commission, Herbalife agreed to pay $200 million in response to charges that it had “deceived consumers” into participating as the dupes in a pyramid scheme.

https://theintercept.com/2022/03/25/madeleine-albright-dead-iraq-war-herbalife

EXPORT COMPLIANCE AND WHEN DO YOU NOT NEED A US EXPORT LICENSE?

On 18 March, Harris Bricken provided a post about the basics to ensure compliance with US export laws and licensing requirements?

https://harrisbricken.com/blog/export-compliance-and-when-do-you-not-need-an-export-license/

GUIDE TO THE EUROPEAN CROWDFUNDING REGULATION

On 11 March, Bird & Bird provided a guide to the European Crowdfunding Service Provider Regulation (Regulation (EU) 2020/1503 – ECSPR); which covers different topics in relation to the ECSPR and crowdfunding.  The firm says that it shall be updated from time to time.

https://www.twobirds.com/-/media/new-website-content/pdfs/2022/articles/ecspr-guide-to-the-european-crowdfunding-regulation.pdf

HANDBOOK OF TERRORISM PREVENTION AND PREPAREDNESS

The International Centre for Countering Terrorism is said to contain all things counter-terrorism related and features chapters from 37 expert contributors.  ICCT this month is re-releasing key sections of the book, together with paired live briefings.  It was first published in 2020.

https://icct.nl/handbook-of-terrorism-prevention-and-preparedness 

NEW UK RUSSIA SANCTIONS GENERAL LICENCE

On 25 March, HM Treasury issued a further General Licence concerned with the continuation of business involving Russian Railways, and the joint venture GEFCO.  Subsidiaries affected are any entity owned or controlled by the Russian Railways including: GEFCO UK Ltd; GEFCO Forwarding UK; Auto XP Limited; and XP Tech Limited.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1063679/INT2022.1438977_GEFCO_GL_notice.pdf 

SANCTIONS AGAINST RUSSIA WILL AFFECT ARMS SALES TO AFRICA

On 27 March, Modern Ghana reported that the wide-ranging sanctions could have serious implications for Africa. Importantly, they could affect the continent’s ability to procure and maintain military hardware from Russia.  It says that almost half of Africa’s imports of military equipment (49%) come from Russia: including major arms (battle tanks, warships, fighter aircraft and combat helicopters) and small arms (pistols and assault rifles such as the new Kalashnikov AK-200 series rifle).  By comparison, China accounts for 13% of the continent’s arms imports.  The biggest buyers of armaments from Russia – and most long-standing importers – are Algeria, Angola, Burkina Faso, Egypt, Ethiopia, Morocco and Uganda.  It also warns that repairing, maintaining or overhauling existing Russian-made hardware will be hard, if not impossible; because essential spares, tools and certification cannot be provided.

https://www.modernghana.com/news/1147922/sanctions-against-russia-will-affect-arms-sales.html

FORMER MICROSOFT EMPLOYEE ALLEGES BRIBERY SCHEME IN MIDDLE EAST AND AFRICA

On 25 March, the Wall Street Journal reported that Microsoft had said that it had fired some employees and terminated partnerships in relation to allegations made public of bribery in its sales efforts in the Middle East in recent years.  The allegations have been made by a former manager for the company named Yasser Elabd, who worked for the tech giant throughout the Middle East and Africa from 1998 to 2018.  He alleged that Microsoft employees were involved in widespread bribery schemes across several countries in the region.

https://www.wsj.com/articles/former-microsoft-employee-alleges-bribery-scheme-in-middle-east-and-africa-11648221986

https://www.theverge.com/2022/3/25/22995144/microsoft-foreign-corrupt-practices-bribery-whistleblower-contracting

ISLE OF MAN: NEW SANCTIONS NOTICES

On 28 March, the Isle of Man published 4 news releases –

  • Advising the addition of 4 individuals and 2 entities to the Myanmar/Burma sanctions regime;
  • Advising of the issue of a General Licence in respect of Bank Dabrabyt Joint Stock Company of Belarus;
  • Amending and correcting 3 entries on the Russia sanctions lists; and
  • Advising of a General Licence governing transactions involving Alfa Bank JSC; GazPromBank; Rosselkhozbank; SMP Bank; and Ural Bank for Reconstruction and Development  

https://www.gov.im/news/2022/mar/28/financial-sanctions-myanmar/

https://www.gov.im/news/2022/mar/28/financial-sanctions-belarus-general-licence/

https://www.gov.im/news/2022/mar/28/financial-sanctions-russia/

https://www.gov.im/news/2022/mar/28/financial-sanctions-russia-general-licence/

IRELAND: KINAHAN CARTEL LIEUTENANT JAILED FOR 21 YEARS AFTER FALL OF €36 MILLION DRUG SMUGGLING EMPIRE

On 28 March, Dublin Live and others reported that senior Kinahan cartel member Thomas “Bomber” Kavanagh, 54, has been jailed for 21 years in the UK after he headed a cocaine and cannabis drug smuggling operation.

https://www.dublinlive.ie/news/kinahan-cartel-lieutenant-thomas-bomber-23519771

https://www.newstalk.com/news/dubliner-thomas-kavanagh-jailed-for-21-years-for-drug-smuggling-in-uk-1326013

https://www.nationalcrimeagency.gov.uk/news/uk-head-of-kinahan-crime-group-jailed-for-21-years

MONEY LAUNDERED MILLIONS SEIZED IN JERSEY TO BE SENT TO KENYA

On 28 March, ITV reported that millions of pounds that were seized in Jersey from money laundering is being returned to Kenya in a world first.  £3 million was confiscated in 2016 following a conviction of a Jersey registered company, Windward Trading Ltd, for money laundering offences. The money originated in Kenya, and was being fed through the Jersey company.

https://www.itv.com/news/channel/2022-03-28/money-laundered-millions-seized-in-jersey-to-be-sent-to-kenya

https://www.gov.je/News/2022/Pages/JerseyKenyaCOVID-19.aspx

NIGERIA: COURT ACQUITS FORMER MINISTER TURAKI OF MONEY LAUNDERING CHARGES

On 28 March, Nairametrics reported that the Abuja Division of the Federal High Court has discharged and acquitted former Minister of Special Duties and Intergovernmental Affairs, Kabiru Turaki, of money laundering charges.

https://nairametrics.com/2022/03/28/alleged-n715million-fraud-court-acquits-former-minister-turaki-of-money-laundering-charges/

EU SAYS $132 MILLION IN LEBANESE ASSETS FROZEN OVER MONEY LAUNDERING CONCERNS

On 28 March, Al Arabiya reported that Eurojust said it assisted in freezing some €120 million of Lebanese assets linked to a money laundering investigation.  It is said to be linked to 5 people suspected of embezzling around $330 million, and seized in France, Germany, Luxembourg, Monaco and Belgium. 

https://english.alarabiya.net/News/middle-east/2022/03/28/EU-says-132-million-in-Lebanese-assets-frozen-over-money-laundering-concerns

https://www.thenationalnews.com/world/2022/03/28/european-prosecutors-seize-assets-worth-132m-in-riad-salameh-probe/

DUBAI DEVELOPER UNION PROPERTIES SAYS $42 MILLION ‘MISAPPROPRIATED’

On 28 March, Al Arabiya reported that a troubled Dubai real estate developer Union Properties said it suspected that $42 million had been “misappropriated” by the company’s former officials while declaring it massively overvalued its holdings.

https://english.alarabiya.net/business/property/2022/03/28/Dubai-developer-Union-Properties-says-42-mln-misappropriated-

THE ROLE OF BRITISH AND OVERSEAS JUDGES IN HONG KONG

On 28 March, the House of Commons Library said that when Hong Kong was a British Overseas Territory, its final court of appeal was the Judicial Committee of the Privy Council (JCPC).  This arrangement was the norm for many, but not all, Commonwealth jurisdictions.  The judges that serve on the JCPC are predominantly the permanent justices of the UK Supreme Court, though they are often supplemented by senior UK judges and occasionally senior judges from the relevant Commonwealth jurisdiction(s).  Following the formation of the Hong Kong Special Administrative Region in 1997, the JCPC’s jurisdiction in relation to Hong Kong ended.  Currently, the HKCFA includes judges otherwise or previously based in the UK, Australia and Canada. In the past, it has also included justices from New Zealand. 

https://commonslibrary.parliament.uk/research-briefings/cdp-2022-0068/

FORMER SPANISH KING LOSES STATE IMMUNITY BID

On 25 March, the Law Society Gazette reported that the former king of Spain is not entitled to sovereign immunity from the jurisdiction of the English courts in a harassment claim brought by his former lover, the High Court has ruled.  He is being sued by Corinna zu Sayn-Wittgenstein-Sayn, who claims the former monarch, or his servants or agents, placed her under surveillance and tried to intimidate her.

https://www.lawgazette.co.uk/news/former-spanish-king-loses-state-immunity-bid/5112002.article

UK APPOINTS WAR CRIMES JUDGE TO INVESTIGATE UKRAINE ATROCITIES

On 28 March, the Law Society Gazette reported that the Attorney General has appointed a former judge at the International Criminal Court to assist the Ukrainian government in investigating war crimes allegedly committed by Russia in Ukraine. 

https://www.lawgazette.co.uk/news/uk-appoints-war-crimes-judge-to-investigate-ukraine-atrocities/5112010.article

https://www.gov.uk/government/news/attorney-general-appoints-leading-war-crimes-lawyer-to-support-ukraines-journey-to-justice

UK: PUBLIC SECTOR TO INVESTIGATE CUTTING CONTRACTS WITH RUSSIAN AND BELARUS SUPPLIERS

On 28 March, the Cabinet Office said that it had published a Procurement Policy Note for public sector organisations holding contracts with Russian or Belarusian suppliers.

https://www.gov.uk/government/news/public-sector-to-investigate-cutting-contracts-with-russian-suppliers

https://www.gov.uk/government/publications/procurement-policy-note-0122-contracts-with-suppliers-from-russia-and-belarus

SPANISH COURT BLOCKS EXTRADITION OF VENEZUELAN EX-MILITARY OFFICER HUGO ARMANDO ‘EL POLLO’ CARVAJAL BARRIOS TO THE US

On 26 March, Jurist reported that the Spanish National Court had blocked the extradition of Carvajal, former Director of Venezuela’s Military Intelligence (DIM) and former politician, who faces illicit drug trafficking and firearms trafficking charges in the US.  He is alleged to have conspired with the Revolutionary Armed Forces of Colombia (FARC).  The ECHR recently recommended that the Spain National Court suspend Carvajal’s extradition as a precautionary measure pending the outcome of his appeal. 

https://www.jurist.org/news/2022/03/spain-national-court-suspends-venezuelan-politician-extradition-to-us/

PAKISTAN: CUSTOMS SEIZE 11 CONTAINERS OF SMUGGLED GOODS 

On 27 March, Pakistan Today reported that the Federal Board of Revenue claimed that in a major operation against smugglers, Pakistan Customs Quetta has seized 11 containers fully stuffed with smuggled goods.   4 of these containers are fully loaded with fabric, 3 with new tyres and 4 with mixed goods including fabric, tyres, cigarettes, betel nuts etc. 

https://www.pakistantoday.com.pk/2022/03/27/customs-seize-11-containers-of-smuggled-goods-valuing-rs-450m/

RUSSIA’S WAR ON UKRAINE: IMPLICATIONS FOR EU COMMODITY IMPORTS FROM RUSSIA

On 25 March, the EU Parliament Research Service published a briefing saying that Russia is a major global commodity producer and exporter. The country’s invasion of Ukraine has already pushed commodity prices to historically high levels, and could also lead to commodity shortages. This situation may cause considerable economic damage, with far-reaching consequences for EU industry.

https://www.europarl.europa.eu/RegData/etudes/ATAG/2022/729341/EPRS_ATA(2022)729341_EN.pdf

CRIMINAL LAW IMPLICATIONS FOR TECHNOLOGY, MEDIA AND TELECOMMUNICATIONS (TMT) COMPANIES FACING RANSOMWARE DEMANDS

On 28 March, an article from Eversheds Sutherland says that, in the US and UK, paying a ransom is not illegal in itself.  However, deciding how to respond to a ransomware demand demands consideration not only of commercial considerations (which on occasions may be existential for the business concerned) but also of whether making a payment may in itself involve breaches of criminal law.  No 2 incidents are the same, and businesses should always receive specific advice on these points based on the facts.  It says that there are 3 key areas of concern.

https://www.eversheds-sutherland.com/global/en/what/articles/index.page?ArticleID=en/Financial-services-and-dispute-investigation/To_pay_or_not_to_pay_Criminal_law_considerations_for_TMT_companies_facing_ransomware_attacks

NEW ZEALAND: PROPOSED LEGISLATIVE CHANGES FOR BENEFICIAL OWNERSHIP INFORMATION AND UNIQUE IDENTIFIER NUMBERS

On 28 March, Dentons said that the New Zealand Government proposes to introduce new legislation later this year to increase transparency in beneficial ownership and the identity of corporate role holders.  The proposed new legislation intends to make it harder for companies and limited partnerships to be misused for illegal purposes (such as money laundering and tax evasion).  The 2 key proposed changes are described in the article.

https://www.dentons.co.nz/en/insights/alerts/2022/march/28/proposed-legislative-changes-for-beneficial-ownership-information

EU MEGA-RICH FUELLING ILLEGAL ‘BLOOD TIMBER’ TRADE IN MYANMAR

On 25 March, the investigative journalism website Oxpeckers carried an article saying that teak is one of the most highly prized hardwoods in the world due to its finish and durability, and is becoming increasingly popular among the mega-rich.  Since the military seized power in Myanmar in 2021 and the EU imposed economic and trade sanctions on the junta, the teak trade has been pushed underground.  The profit margins for teak dealers are high. And while EU imports are prohibited if legality and sustainability cannot be proven, the sought-after timber still finds a way on to Europe.

https://oxpeckers.org/2022/03/eus-blood-timber-trade/

ANATOMY OF AN NFT PHISHING SCAM

On 24 March, TRM published an article about what it describes as a particularly insidious type of scam on the rise — the “bait-and-switch contract”. This form of phishing prompts users to sign a contract, usually under the pretence of a legitimate transfer of ownership, which then grants control of the user’s entire wallet to the attacker.

https://www.trmlabs.com/post/anatomy-of-an-nft-phishing-scam

VANUATU PRIME MINISTER SAYS YES TO SATOSHI ISLAND CRYPTO PROJECT

On 25 March, the Coin Telegraph reported that the Vanuatu government announces its support for the Satoshi Island Community Project. 

https://cointelegraph.com/news/vanuatu-prime-minister-says-yes-to-satoshi-island-crypto-project

POLICY RESPONSES TO TECHNOLOGY-FACILITATED TRAFFICKING IN HUMAN BEINGS: ANALYSIS OF CURRENT APPROACHES AND CONSIDERATIONS FOR MOVING FORWARD

On 17 March, a report from the Organization for Security and Co-operation in Europe provides an analysis of how technology-facilitated trafficking in human beings has been approached from the perspective of policy and legislation across the OSCE participating states.  While looking primarily at the accelerating shift toward government-led responses, the report also examines the policies and practices adopted by the private sector and civil society organizations.  In addition, the report offers recommendations for policy and legislative responses by OSCE participating states to the misuse of technology to exploit victims.

https://www.osce.org/files/f/documents/0/d/514141.pdf 

LONDON INSURANCE FIRMS PROBED FOR BRIBERY AND CORRUPTION IN SOUTH AMERICA

On 25 March, Yahoo News reported that a handful of London insurance firms are reportedly being investigated for bribery and corruption by the SFO.  It is said that the investigation involves how the firms secured business in South America.  The investigation is linked to a US DoJ probe into corruption at Ecuador’s state-run insurance fund, Seguros Sucre. 

https://uk.finance.yahoo.com/news/london-insurance-firms-probed-bribery-100058858.html

THE “QUEEN OF COCA” ACCUSED OF MONEY LAUNDERING IN PANAMA IS ON TRIAL IN SPAIN

On 28 March, La Estrella reported that Ana María Cameno, known as the “queen of coca”, is accused of crimes related to drug trafficking, the laundering of millions of euros in Panama and illegal possession of weapons.  Allegations include money laundering in Panama through entities that provide investment services without being authorised.  The trial comes 8 years after she was arrested. 

https://www.laestrella.com.pa/internacional/mundo/220328/juzgan-espana-reina-coca-acusada-blanqueo-panama

DEMOCRATIC REPUBLIC OF CONGO: BACKGROUND AND US RELATIONS

On 25 March, the US Congressional Research Service published a briefing about the DRC, its assets and difficulties and the US attitude and policy.  Included in the topics discussed are wildlife poaching and trafficking, corruption in the mining sector, Global Magnitsky sanctions on Dan Gertler, an Israeli businessman, and China’s role in DRC’s mining sector and strategic competition.

https://crsreports.congress.gov/product/pdf/R/R43166

NORTH KOREA TESTS A BANNED MISSILE — AND GLAMORISES NUCLEAR WEAPONS

An article in the Bulletin of the Atomic Scientists on 24 March reported that North Korea launched what is presumed to be a banned intercontinental ballistic missile (ICBM) toward the East Sea.  It also reported that North Korea’s state TV released a Hollywood-esque video featuring Kim Jong Un in dark sunglasses and a leather jacket, flanked by generals, in a slow-motion walk accompanied by heart-pounding music while the colossal weapon rolls out behind him.

https://thebulletin.org/2022/03/north-korea-tests-a-banned-missile-raising-speculation-and-concern/

UN AUTHORISATION TO FIGHT PIRACY IN SOMALI WATERS ENDS

On 24 March, Homeland Security Today reported that the UN Security Council quietly let a deadline pass for it to renew UN authorisation to fight piracy in waters off lawless Somalia.  On 3 March, it did nothing to renew the authorisation and made no public announcement about the deadline passing.  Now that the UN authorisation has expired, those ships and planes can still ward off and chase pirates but only in international air space and waters, not those of Somalia.

https://www.hstoday.us/subject-matter-areas/maritime-security/un-authorization-to-fight-piracy-in-somali-waters-ends/

https://www.france24.com/en/live-news/20220311-un-authorization-to-fight-piracy-in-somali-waters-ends

COMPANIES FEAR PAYING RENT ON MOSCOW OFFICES 

On 28 March, K2 Integrity reported that several western companies still operating in Russia are trying to determine whether paying rent on their Moscow offices would breach sanctions because of potential links to an investment vehicle of prominent Russian billionaire Roman Abramovich.

https://www.k2integrity.com/en/knowledge/policy-alerts/daily-digest-sanctions-28-march-2022

JAPAN TO REVISE FOREIGN EXCHANGE LAW TO END CRYPTO LOOPHOLE FOR SANCTIONS ON RUSSIA

On 28 March, US News reported that Japan will revise its foreign exchange law to prevent Russia from evading Western financial sanctions following Moscow’s invasion of Ukraine through cryptocurrency assets.  It will submit a revision of the Foreign Exchange and Foreign Trade Act.

https://money.usnews.com/investing/news/articles/2022-03-28/japan-to-revise-foreign-exchange-law-to-end-crypto-loophole-for-sanctions-on-russia

ESTONIAN CENTRAL BANK CHIEF TELLS RUSSIAN OLIGARCHS: DON’T TRY MONEY LAUNDERING HERE

On 24 March, Politico reported that both Estonia’s banks and authorities have pulled out all stops to weed out illicit money after the country’s reputation was tainted by the Danske Bank scandal. 

https://www.politico.eu/article/estonian-central-bank-chief-tells-russian-oligarchs-dont-try-money-laundering-here/

RUSSIA’S SUPPLY OF ICEBREAKER SHIPS TO SHIP FUEL FROM PROJECTS IN THE ARCTIC

On 28 March, K2 Integrity reported an FT story that foreign companies may be unable to deliver the specialised vessels needed to ship the fuel from projects in the Arctic. The FT reported that Korean suppliers told the Financial Times they intended to honour their contracts but sub-contractors in Europe may cease deliveries. 

https://www.k2integrity.com/en/knowledge/policy-alerts/daily-digest-sanctions-28-march-2022

UPDATE ON OECD BEPS PILLAR 2 FOLLOWING COMMENTARY RELEASE

On 28 March, KPMG released an Executive Summary about the Model, Commentary and Examples which provide the framework for a Global Minimum Tax at 15% for Multinational Enterprises (MNE) with annual revenue of at least €750 million.  It notes that the OECD also opened a public consultation on the administrative and compliance aspects of the related GloBE Rules, with comments requested by 11 April, with a follow-on public consultation meeting scheduled for the end of April 2022. 

https://assets.kpmg/content/dam/kpmg/us/pdf/2022/03/kpmg-update-pillar-two-commentary-release-march-2022.pdf

VENEZUELAN TROOPS OPERATED ALONGSIDE COLOMBIAN REBELS, REPORT CLAIMS

On 28 March, the Guardian reported that Venezuelan soldiers conducted joint operations with Colombian rebels in the state of Apure earlier this year, as violence increased along a remote and often lawless stretch of the Colombia-Venezuela border, according to a new report by Human Rights Watch.

https://www.theguardian.com/world/2022/mar/28/venezuelan-troops-colombia-rebels-joint-operations-human-right-watch

MONEY LAUNDERING AND TERRORIST FINANCING (HIGH-RISK COUNTRIES) (AMENDMENT) REGULATIONS 2022

The principal policy objective behind these UK Regulations is to update the list of high-risk third countries in respect of which the regulated sector needs to apply enhanced due diligence in a timely manner in order to ensure the UK maintains robust defences against money laundering, terrorist financing and proliferation financing.  The new list of countries reflects those countries identified by the FATF in the ‘high-risk jurisdictions subject to a call for action’ and ‘jurisdictions under increased monitoring’ public statements released after the Plenary meeting in March 2022.  These countries are identified as having strategic deficiencies in their AML/CTF/CPF regimes. The instrument will therefore give effect to additional preventive measures in respect of these countries.

https://www.legislation.gov.uk/uksi/2022/393/contents/made

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

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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