Month: April 2022

On 28 April, a report from Global Witness explains that minerals extracted by hand from the African Great Lakes region are in huge demand. The Democratic Republic of the Congo (DRC) and Rwanda produce nearly half the world’s coltan, the main ore of tantalum, as well as large amounts of tin and tungsten ores – collectively known as 3T minerals. The metals obtained from the smelted 3T minerals are widely used in electronic equipment such as mobile phones, computers and automotive and aeronautical systems.  Due to concerns, industry interests set up traceability systems which, working alongside government validation of mines, were intended to establish a supply of “conflict-free”, responsibly sourced minerals.  However, the report contains evidence of how the most widely used of these schemes – the International Tin Supply Chain Initiative (ITSCI), established in 2009 – appears to facilitate the laundering of minerals originating from mines controlled by abusive militias or that use child labour.  Furthermore, it is said that the scheme many international companies are relying on to source responsibly, is also used to launder huge amounts of minerals that have been smuggled and trafficked, new evidence suggests.

https://www.globalwitness.org/en/campaigns/natural-resource-governance/itsci-laundromat/

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This report published by Conflict Armament Research examines the use of a Diversion Analysis Framework (DAF), an analytical tool designed to help unpack the problem of diversion. The Framework is part of a wider research project through which the 3 partner organisations hope to support Arms Trade Treaty (ATT) States Parties in understanding the impact of the Treaty in addressing diversion risks associated with arms transfers.  It draws on findings from CAR field investigations of weapon diversion in conflict-affected locations to illustrate how the DAF can be applied to real-world cases.  These studies also explore what measures States that have been involved in such cases have introduced to create or strengthen an ‘enabling environment’ to better prevent, mitigate, and address cases of diversion.

https://storymaps.arcgis.com/stories/85696cc9a7e24d18ba87b0b9fe6d353f

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A report from Conflict Armament Research says that a wide spectrum of materials can be used to manufacture improvised explosive devices (IED).  These include both military and civilian commercial products. The variety in design and means of deployment of IED vastly complicates efforts to regulate and control their proliferation.  The UN General Assembly has repeatedly stressed the urgent need to prevent illicit actors from obtaining and using materials to produce IED.  CAR investigators have been working to document and trace components, subcomponents, and materials like commercial explosives that can be used to create IED.  The report presents case studies from CAR investigations that demonstrate examples of upstream IED prevention in action.  It highlights the importance of field documentation, analysis, and tracing to provide governments, manufacturers, and distributors with verified evidence on patterns of illicit production and procurement of IED materials.

https://storymaps.arcgis.com/stories/6f06554d7c6c407c9952236fd78763b6

On 30 April, the Guardian reported that the acting premier has said he opposes a recommendation that the UK take direct control of the territory after his predecessor appeared in a US court on charges linked to drugs trafficking.  BVI operates under a 2007 constitution that gives them limited self-governance under a Governor who is the ultimate executive authority as the representative of the Queen.  However, an inquiry into corruption in the territory recommended the Governor take direct rule of the territory for 2 years, saying that “Almost everywhere, the principles of good governance, such as openness, transparency and even the rule of law, are ignored”.

https://www.theguardian.com/world/2022/apr/30/call-for-direct-rule-of-british-virgin-islands-resisted-by-acting-premier

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On 29 April, OCCRP published a report saying that the RCB Bank was set up and owned by VTB, a Russian bank dubbed Putin’s “piggy bank” and that, despite making moves to obscure its Russian ties following the invasion of Ukraine, current and former RCB executives have ties to the Kremlin and acquired Cypriot passports under dubious circumstances.

https://www.occrp.org/en/investigations/the-kremlin-connections-behind-cypruss-rcb-bank

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On 29 April, FinCEN advised the renewal and expansion of its Geographic Targeting Orders (GTO) that require US title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. FinCEN renewed the GTO that cover certain counties within the following major US metropolitan areas:  Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.  FinCEN has also expanded the geographic coverage of the GTO to parts of the District of Columbia, Northern Virginia, and Maryland (DMV) metropolitan area, the Hawaiian islands of Maui, Hawaii, and Kauai, and Fairfield County, Connecticut.  The purchase amount threshold remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase threshold is $50,000.

https://www.fincen.gov/news/news-releases/fincen-renews-and-expands-real-estate-geographic-targeting-orders

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On 29 April, FinCEN advised that the US Treasury was replacing the Ukraine Related Sanctions Regulations, with them being replaced by being renamed as the Ukraine-/Russia-Related Sanctions Regulations.  The new regulations are intended to provide a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licences, and other regulatory provisions that will provide further guidance to the public.  OFAC has also revised several FAQ accordingly.

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-04-29

https://home.treasury.gov/system/files/126/20220429_ukraine_regulations.pdf

https://content.govdelivery.com/accounts/USTREAS/bulletins/315b037

https://home.kpmg/us/en/home/insights/2022/04/tnf-us-final-rule-replacing-ukraine-related-sanctions-regulations.html

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On 29 April, the EU Sanctions blog reported that, in addition to OFAC financial sanctions, the US State Department has applied sanctions and visa restrictions on numerous people in response to human rights abuses committed in Russia and Belarus.

https://www.europeansanctions.com/2022/04/us-state-department-imposes-russia-belarus-visa-restrictions-sanctions/

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Another helpful chart provided by ACAMS and which includes the key export restrictions imposed by certain G7 countries, namely the US, the EU, Japan, Australia, and the UK on luxury goods destined for Russia.

https://www.acams.org/sites/default/files/2022-04/ADT1116_Ukraine%20Rapid%20Response_Luxury%20Goods%20Infographic%20vF.pdf

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On 28 April, INTERPOL published a report, saying that it has established a dedicated team to support member countries combating illegal gold mining in Latin America and beyond.  Analysis for law enforcement shows the clear involvement of organized criminals in illegal gold mining, taking advantage of surging gold prices and leaving severe environmental degradation in their wake. Latin America is especially affected by this crime area, experiencing one of the world’s largest illegal gold extraction rates, according to INTERPOL’s findings. The high involvement of sophisticated criminal networks in illegal gold mining and the transnational dimension of illegal mining and associated crimes also pose challenges for law enforcement, who sometimes lack the necessary resources to combat this crime threat effectively. 

https://www.interpol.int/en/News-and-Events/News/2022/The-devastating-impact-of-illegal-gold-mining-in-Latin-America

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