OTHER THINGS YOU MAY HAVE MISSED – APRIL 1

Panama Covid-19 update – numbers in ICu fall below 10 again at 8, with 75 more in other wards; and active cases fall by 84 (oddly, the number by which the total rose yesterday) to 2,523. There were no new fatalities reported, but 295 new cases.

1 APRIL 2022

US SANCTIONS RUSSIAN TECH COMPANIES, WHOLE SECTORS OF RUSSIAN ECONOMY

On 31 March, the Wall Street Journal reported that the US Treasury has imposed sanctions on nearly 3 dozen Russian companies and individuals that it said are helping Moscow evade the West’s economic pressure campaign and aiding the country’s defence and intelligence agencies.  Among those blacklisted include Russia’s largest microchip manufacturer, Mikron and supercomputer company T-Platforms.

https://www.wsj.com/articles/u-s-sanctions-russian-tech-companies-whole-sectors-of-russian-economy-11648748173

MONEY LAUNDERING IN TRADING WORKS OF ART – US TREASURY REPORT ADDRESSES NFT MARKETPLACES

On 31 March, DLA Piper published an article about a new report which sought to identify market participants and sections of the high-value art market that may present money laundering and terrorist financing risks to the US financial system.  While the Treasury report primarily focused on the traditional art market it included a section addressing the “emerging digital art market”. 

https://www.dlapiper.com/en/us/insights/publications/2022/03/money-laundering-in-trading-works-of-art/

THE GLOBAL THREAT OF GREEN FRAUD

On 29 March, an article from FTI Consulting Inc looks at how fraudsters threaten the system of government-funded net zero initiatives, the impact on public and private sectors, and actions one must take now to mitigate risk.  It says that protecting green investment from green fraud will not be easy.

https://www.fticonsulting.com/emea/insights/fti-journal/global-threat-green-fraud

AUSTRALIA ANNOUNCES FIRST MAGNITSKY-STYLE SANCTIONS

On 30 March, Nyman Gibson Miralis reported that the foreign minister issued the first set of Australian Magnitsky-style sanctions, targeting Russian individuals responsible for corruption.  The article explores how these sanctions emerged, who they apply to, and the implications for Australian businesses and individuals.

https://ngm.com.au/australia-announces-first-magnitsky-style-sanctions/

THE SWEDISH P+I CLUB: SANCTIONS AGAINST RUSSIA

On 30 March, an article from the Swedish Club says that the current sanctions landscape concerning Russia involves a wide number of states issuing their own, and differing, sanctions regimes against Russia and Russian interests meaning that due diligence requires other relevant sanctions regimes and lists to be consulted depending on the trade.  This adds a whole new layer of complexity to consider in international shipping.  

https://www.swedishclub.com/news/member-alert/sanctions-against-russia

A HIDDEN SPANISH GOVERNMENT REPORT REVEALS AN ALLEGED EMBEZZLEMENT OF $5 MILLION IN PANAMA

On 31 March, La Estrella carried an article about a report prepared by the Division of Control and Improvement of Management of the Ministry of Foreign Affairs that reveals an alleged embezzlement of $5 million in the office of the Spanish Agency for International Development Cooperation (AECID) in Panama.  It is said that the embezzlement carried out by an employee of the AECID office in Panama amounted to at least $5 million and that they were stolen over a period of 10 years.

https://www.laestrella.com.pa/internacional/mundo/220331/informe-oculto-gobierno-espanol-revela-supuesto-desfalco-5-millones-panama

GUIDANCE ON WHETHER THE CONTINUED LEASING OR FINANCE OF AIRCRAFT IN RUSSIA VIOLATES US LAW

On 21 March, an article in the National Law Review about recent US Commerce Department Press Release which clarifies that the Department’s restrictions on aviation exports to Russia issued in the wake of the invasion of Ukraine apply to whole aircraft, and not just to as aircraft components, software, and technology.

https://www.natlawreview.com/article/commerce-department-identification-aircraft-exported-to-russia-violation-export

LITHUANIA APPLIES SANCTIONS TO RUSSIAN CHANNEL ONE HOST

On 1 April, LRT reported that Lithuania has applied financial sanctions to Russian TV host Artyom Sheynin, who works for the state-owned propaganda outlet, Channel One.  Sheynin and his wife own an apartment in the Baltic Sea resort of Palanga. 

https://www.lrt.lt/en/news-in-english/19/1659995/lithuania-applies-sanctions-to-russian-channel-one-host

JAPAN: NEW SANCTIONS ON NORTH KOREA AFTER MISSILE LAUNCH

On 1 April, the Khaleej Times reported that Japan’s government has approved fresh sanctions against North Korea over its recent test-firing of an intercontinental ballistic missile (ICBM).

https://www.khaleejtimes.com/asia/japan-slaps-new-sanctions-on-north-korea-after-missile-launch

US REPATRIATES SMUGGLED ANCIENT ARTIFACTS TO LIBYA

On 1 April, the New Arab reported that the repatriated items include 2 sculptures dating to the 4th Century BC from the ancient city of Cyrene.

https://english.alaraby.co.uk/news/us-repatriates-smuggled-ancient-artifacts-libya

US: STUDENTS HELP COAST GUARD TO FIND UNMANNED SMUGGLING BOATS

On 31 March, the Seapower website reported that a unique student project is helping the US Coast Guard find small and hard to detect unmanned autonomous surface vessels that might be used to transport drugs into the US.  The US Coast Guard engaged the National Security Innovation Network, a Department of Defense office which collaborates with major universities and the venture community to develop solutions that drive national security innovation.  A project is to improve coastal surveillance, detection and interdiction capabilities to threats posed by this evolving threat.  The students were tasked with designing and testing a USV with similar characteristics to ones previously detected, and to test and demonstrate detection using an existing surveillance tool.

https://seapowermagazine.org/students-help-coast-guard-to-find-unmanned-smuggling-boats/

MONEYVAL CARRIES OUT A FACE-TO-FACE MEETING WITH BULGARIA

On 18 March, the Council of Europe reported that, in the framework of the 5th round of mutual evaluation of Bulgaria, MONEYVAL organised a meeting between the assessment team and Bulgarian authorities on 16-18 March in Strasbourg. 

https://www.coe.int/en/web/moneyval/-/moneyval-carries-out-a-face-to-face-meeting-with-bulgaria

GHANA: CRIMINALS CONCEALING MONEY LAUNDERING ACTIVITIES IN REAL ESTATE MARKET 

On 1 April, Ghana Web reported that the FATF-style regional body GIABA has said that real estate in Ghana is said to be a major avenue for money laundering in the country. 

https://www.ghanaweb.com/GhanaHomePage/business/FLASHBACK-Criminals-concealing-money-laundering-activities-in-real-estate-market-GIABA-1505006

4 MAJOR CHANGES TO CORPORATE TRANSPARENCY IN 2022

On 31 March, an article from Control Risks puts a spotlight on what the corporate transparency landscape will look like in 2022 and what steps you should take now to respond.

https://www.controlrisks.com/our-thinking/insights/beneficial-ownership

DEMOCRACY IS BEING DESTROYED IN LATIN AMERICA

On 30 March, an article from Control Risks says that Latin America is experiencing a wave of authoritarianism and populism, and populist authoritarianism, eroding and, in some cases, destroying democracy; and this will continue in 2022. 

https://www.controlrisks.com/our-thinking/insights/latin-america-democracy-is-being-destroyed

CPS RESPONDS TO CHANGING NATURE OF SERIOUS ECONOMIC AND ORGANISED CRIME WITH A NEW TEAM

On 1 April, a news release from the Crown Prosecution Service announced the launch of a united team to tackle the changing nature of serious and organised crime.  The Serious Economic, Organised Crime and International Directorate (SEOCID) brings together specialists in economic crime, organised crime, proceeds of crime and international to deliver justice, combat crime across borders and take money from criminals.

https://www.cps.gov.uk/cps/news/cps-responds-changing-nature-serious-economic-and-organised-crime-new-team

US DoJ DECLINES TO PROSECUTE INSURANCE BROKER OVER ECUADOR BRIBES

On 31 March, the Wall Street Journal reported that prosecutors claim that Marsh & McLennan’s Jardine Lloyd Thompson funnelled over $3 million in bribes to Ecuadorian officials.  Prosecutors made public their decision not to prosecute the company, Jardine Lloyd Thompson Group Holdings Ltd., in a letter posted without announcement to a Justice Department website.

https://www.wsj.com/articles/justice-department-declines-to-prosecute-insurance-broker-over-ecuador-bribes-11648680240

BNP PARIBAS SA FACED EXTRA SCRUTINY FROM THE FCA OVER HOW IT TREATS ITS OWN WHISTLE-BLOWERS

On 30 March, Bloomberg Law reported that a case before the Employment Tribunal reported that the Financial Conduct Authority conducted a “specialist-led financial crime visit” at the bank’s London offices following allegations that it sold products unlawfully through a network of “rogue” agents to win business in Italy.

https://news.bloomberglaw.com/securities-law/bnps-treatment-of-bribery-whistle-blowers-gets-fca-scrutiny

AUSTRALIA: STAR CASINO JUNKET CEASED ONLY AFTER CEO ARREST

On 31 March, the Canberra Times reported that it took the arrest of Macau-based junket operator Suncity’s CEO for the company to be stopped from running private gaming rooms at Sydney’s Star casino. Star’s general manager of financial crime and investigations had resumed giving evidence to the New South Wales gaming regulator’s inquiry into the casino’s fitness to hold a licence.

https://www.canberratimes.com.au/story/7680634/star-junket-ceased-only-after-ceo-arrest/

TAKEDOWN OF ONLINE INVESTMENT FRAUD IN ALBANIA WITH 15 ARRESTS

A news release from Eurojust on 31 March reported that authorities in Albania and Germany have taken down a fraudulent online investment platform that defrauded victims, including many Germans, of at least several million euros. During a recent action day, 15 suspects were arrested and 8 places were searched in Tirana.

https://www.eurojust.europa.eu/news/takedown-online-investment-fraud-albania-15-arrests

SEC PROPOSES RULES TO ENHANCE DISCLOSURE AND INVESTOR PROTECTION RELATING TO SPECIAL PURPOSE ACQUISITION COMPANIES (SPAC), SHELL COMPANIES, AND PROJECTIONS

On 30 March, the SEC issued a news release saying that it has proposed new rules and amendments to enhance disclosure and investor protection in initial public offerings by special purpose acquisition companies (SPAC) and in business combination transactions involving shell companies, such as SPAC, and private operating companies.

https://www.sec.gov/news/press-release/2022-56

RUSSIAN OIL COMPANY SHUFFLES VENEZUELA ASSETS AS SANCTIONS BITE

On 28 March, Yahoo reported that a Russian oil company used to provide a workaround to US oil trading sanctions on Venezuela is scrabbling to avoid another set of sanctions, documents show, this time from Europe and the US over Russia’s invasion of Ukraine.  Roszarubezhneft is attempting to transfer ownership of its Venezuelan assets from its European units to another company in Russia.

https://uk.sports.yahoo.com/news/exclusive-russian-oil-firm-shuffles-040451353.html

WAKING UP TO REPUTATION LAUNDERING AS A MECHANISM FOR TRANSNATIONAL KLEPTOCRACY

The National Endowment for democracy in the US has published this report saying that while much of the focus on combating transnational kleptocracy has centred on money laundering, addressing the vulnerabilities that allow kleptocrats to engage in reputation laundering — the process by which they attempt to distance themselves from the illicit source of their wealth — is critical for combating authoritarian influence and defending the health and viability of democracy.  The 5 essays in the report illuminate the scope and scale of this transnational challenge and offer recommendations for countering the corrosive effects of reputation laundering on democratic institutions.

https://www.ned.org/global-insights-waking-up-to-reputation-laundering-as-a-mechanism-for-transnational-kleptocracy-march-2022/

DUTCH POLICE SEIZE NFT FOR THE FIRST TIME

On 30 March, NL Times reported that police cybercrime investigators in Oost-Nederland seized cryptocurrency and non-fungible tokens as part of its investigation into the widespread trade in private data.  It marks the first time that a Dutch investigative service seized NFT. 

https://nltimes.nl/2022/03/30/dutch-police-seize-nfts-first-time-ever

PRESIDENT’S RELATIVE CONTROLS TURKMENISTAN’S ONLY MOBILE OPERATOR

On 31 March, an article from OCCRP says that Turkmenistan’s only mobile operator, Altyn Asyr, enjoys an undisputed monopoly despite frequent complaints about poor service and exorbitant prices.  Though its shareholders are not publicly named, reporters learned that it is run by a member of the President’s family.

https://www.occrp.org/en/investigations/one-familys-golden-age-presidents-relative-controls-turkmenistans-only-mobile-operator

US ADDS 120 ENTITIES IN BELARUS AND RUSSIA TO ITS EXPORT CONTROL ENTITY LIST

On 1 April, KPMG reported that the Bureau of Industry and Security (BIS) of the US Commerce Department had added120 entities to the EAR Entity list.   95 of the 120 entities on the Entity List because they are determined to be military end-users.

https://home.kpmg/us/en/home/insights/2022/04/tnf-us-additions-to-entity-list-120-entities-in-belarus-and-russia.html

PROJECT SAPPHIRE: HOW TO KEEP 600 TONS OF KAZAKH HIGHLY ENRICHED URANIUM SAFE

On 1 April, an article from War on the Rocks relates the story of a a secret US-Kazakh operation codenamed Project Sapphire in the 1990s. The story of its success reveals that trust between countries can make the most challenging and high-stake cooperative security initiatives a reality.

https://warontherocks.com/2022/04/project-sapphire-how-to-keep-600-tons-of-kazakh-highly-enriched-uranium-safe

PODCAST: WHAT BANKS NEED TO KNOW ABOUT RUSSIA SANCTIONS COMPLIANCE

On 23 March, the American Banking Association released this podcast which includes red flags, an overall view of sanctions and what banks should be anticipating in the near future, and the role of software.

https://bankingjournal.aba.com/2022/03/podcast-what-banks-need-to-know-about-the-russia-sanctions/

CMA CGM IS SAID TO BE POISED TO ACQUIRE FRENCH AUTOMOTIVE AND INDUSTRIAL LOGISTICS FIRM GEFCO, CURRENTLY 75%-OWNED BY RUSSIAN RAILWAYS (RR)

On 1 April, Loadstar reported that CMA CGM reportedly wanting to acquire the Russian state utility has been on the EU and US trade sanctions lists since late-February following Russia’s invasion of Ukraine.

https://theloadstar.com/cma-cgm-poised-to-acquire-gefco/

GHANA: GOLD ROYALTIES DEAL CHALLENGED BY ANTI-CORRUPTION ORGANISATIONS IN ECOWAS COURT OF JUSTICE

On 31 March, Transparency International reported that the ECOWAS Court of Justice heard a case to determine whether the government of Ghana had violated the rights of its people by proposing to sell the country’s gold royalties in perpetuity in the Agyapa Royalties deal; which involves mining leases to an offshore company registered offshore in Jersey.

https://www.transparency.org/en/press/controversial-ghana-agyapa-deal-hearing-regional-ecowas-court

HOW NIGEL FARAGE COULD MAKE MILLIONS FROM A COMPANY BETTING ON NET ZERO

On 30 March, Unearthed reported that former MEP and “Mr Brexit”, Nigel Farage, could make €18.5 million from share options he holds in a carbon offsetting company that says it disagrees with his recent comments on net zero. 

https://unearthed.greenpeace.org/2022/03/30/nigel-farage-net-zero-offsetting/

EU COURT ANNULS SANCTIONS DESIGNATIONS OF FORMER PRESIDENT OF UKRAINE VIKTOR FEDOROVYCH YANUKOVYCH AND HIS SON, OLEKSANDR VIKTOROVYCH YANUKOVYCH WHO NEVERTHELESS REMAIN DESIGNATED

On 1 April, a news release from the European Court of Justice advised that the EU General Court had annulled the March 2020 acts maintaining the designations of the 2 individuals.  However, they remain subject to an asset freeze as their listings were renewed until 6 September 2022 (and are also listed by the UK).

https://www.europeansanctions.com/2022/04/2020-designations-of-former-president-yanukovych-and-son-annulled/

FinCEN ASSESSES $275,000 CIVIL MONEY PENALTY AGAINST A&S WORLD TRADING FOR VIOLATING GEOGRAPHIC TARGETING ORDER

On 1 April, a news release from FinCEN advised that it had imposed a penalty on A&S World Trading Inc (aka Fine Fragrance (A&S)) for wilful violations of the Bank Secrecy Act (BSA) and its implementing regulations.  This is FinCEN’s first enforcement action for failing to comply with a Geographic Targeting Order (GTO).  A&S failed to report more than $2 million in high-risk currency transactions relating to certain non-financial trades and businesses located within the Los Angeles Fashion District.

https://www.fincen.gov/news/news-releases/fincen-assesses-275000-civil-money-penalty-against-world-trading-violating

US MARITIME CYBER ALERT: SPOOFED BUSINESS WEBSITES

On 31 March, Homeland Security Today reported that the US Coast Guard encourages maritime stakeholders whose websites could be spoofed to regularly review their online presence and validate their legitimate websites.  It refers to an increase in fake business websites targeting the Marine Transportation System (MTS), with partners having discovered well-constructed, fake websites masquerading as their legitimate business websites.

https://www.hstoday.us/subject-matter-areas/cybersecurity/maritime-cyber-alert-spoofed-business-websites/

https://www.dco.uscg.mil/Portals/9/Maritime%20Cyber%20Alert%2001-22%20TLP%20WHITE.pdf

SDN AS TENANTS: HOW LANDLORDS CAN BE IMPACTED BY SANCTIONS AGAINST RUSSIAN NATIONALS

On 1 April, an article from Pillsbury says that the listing of Specially Designated Nationals (SDN) by OFAC in the US has the potential to impact any American doing business with a named party, including landlords who lease real estate to sanctioned persons.

https://www.pillsburylaw.com/en/news-and-insights/specially-designated-nationals-tenants.html

https://www.cityoflondon.police.uk/police-forces/city-of-london-police/areas/city-of-london/about-us/about-us/ifed/ghost-broking/

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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