OTHER THINGS YOU MAY HAVE MISSED – JUNE 9

Panama Covid-19 update – numbers continue high, or even increased, with 2,973 new cases and 3 new fatalities. Active cases are up to 28,406, with 36 in ICU and 294 in other wards. Testing continues to produce a high positive result, at 20.5% – although for us a new test has now cleared out daughter, although my wife continues in quarantine (and my birthday weekend jaunt is loost…)

9 JUNE 2022

INDONESIAN NAVAL OFFICERS REPORTEDLY ASKED FOR $375,000 TO RELEASE A FUEL TANKER

On 8 June, Reuters reported claims that Indonesian naval officers have asked for $375,000 to release a fuel tanker they detained the week before for anchoring illegally in Indonesian waters off Singapore.  It notes that Reuters reported a dozen similar detentions last year, and in those cases, the shipowners made unofficial payments of about $300,000 each.

https://www.msn.com/en-gb/news/world/exclusive-indonesian-navy-officers-ask-for-375-000-to-release-tanker-sources/ar-AAYeNgv?bk=1&bk=1&ocid=msedgntp&cvid=a61d56228042404cb918729b585269ab

FIRST SFO TRIAL OF 2022 RESULTS IN DOUBLE CONVICTION

On 8 June, Security Matters reported that the SFO in the UK had secured the convictions of the 2 company directors behind fraudulent green investment schemes in Brazil, which took in approximately £37 million of investments.  Meanwhile, the SFO also confirmed the imprisonment of a convicted fraudster who conned investors out of £72.5 million with false claims of supplying services to the London Olympic Village.

https://securitymattersmagazine.com/inaugural-sfo-trial-of-2022-results-in-double-conviction

PODCAST – DISHONEST PROFESSIONALS: RECENT DEVELOPMENTS

On 1 June, 4 New Square chambers released a podcast which aims to bring listeners up to date on some of the core features of allegations of dishonesty in the professional liability context.  It considers what dishonesty is, and how the boundaries of ‘blind-eye knowledge’ have been tested; the practicalities of proving dishonesty and ways that allegations of fraud have been summarily determined in recent cases; the causes of action which are unlocked by pleading dishonesty, and in particular the developments in the law of bribery and secret commissions and misrepresentation; and finally, the pros and cons of alleging fraud.

https://www.4newsquare.com/podcast/dishonest-professionals-recent-developments/

PORTUGAL – THE GENERAL REGIME FOR THE PREVENTION OF CORRUPTION ENTERS INTO FORCE

On 8 June, Garrigues provided a 6-step checklist on compliance with the new law.  Companies have 1 year to finalise the full adaptation of their compliance programs or endow their organisation with all the necessary means to implement, review and control an effective system for preventing cases of corruption or face the regulatory penalty regime.

https://www.garrigues.com/sites/default/files/documents/portugal_-_the_general_regime_for_the_prevention_of_corruption_enters_into_force_6-step_check-list.pdf

US: AUDIT AND ADVISORY FIRM PAYS $1.9 PENALTY FOR IMPROPER CONDUCT RELATED TO WORK FOR COLLAPSED CRYPTO COMPANY LONGFIN

On 8 June, the Wall Street Journal reported that CohnReznick LLP has agreed to pay $1.9 million to resolve SEC charges accusing the audit and advisory firm of improper professional conduct in connection with its audit of Longfin Corp., a cryptocurrency company accused of fraud.

https://www.wsj.com/articles/cohnreznick-to-pay-1-9-million-in-sec-settlement-over-audit-issues-11654725386

QUAD NATIONS PLAN TRACKING FOR CHINA ILLEGAL FISHING IN INDO-PACIFIC

On 3 June, Dryad Global reported that India, US, Japan and Australia announce plans to launch a satellite-based maritime security system at the Quad summit in Tokyo to check China’s illegal fishing in the Indo-Pacific region.

https://channel16.dryadglobal.com/quad-nations-plan-tracking-for-china-illegal-fishing-in-indo-pacific

GERMANY: SANCTIONS ENFORCEMENT ACT I – SEEN AS THE FIRST PACKAGE OF LEGISLATIVE REFORMS TO THE COUNTRY’S ENFORCEMENT OF EU SANCTIONS

On 9 June, European Sanctions blog reported on the adoption of this new legislation, intended to enact short-term regulatory changes.  A further Act is expected to establish a national register for frozen assets and assets of unclear origin.

https://www.europeansanctions.com/2022/06/germany-adopts-sanctions-enforcement-act-i/

PROPOSED NEW US EXPORT CONTROLS ON MARINE TOXINS

On 8 June, Squire Patton Boggs reported that, on 23 May, the US Commerce Department’s Bureau of Industry and Security (BIS) published in the Federal Register a proposed rule and request for comments.  The proposed rule also would identify the synthesis and collection of these toxins for evaluation as “emerging and foundational technologies”. 

https://www.tradepractitioner.com/2022/06/bis-proposes-new-us-export-controls-on-marine-toxins/#page=1

LITHUANIA TO CONTINUE PUSHING FOR SANCTIONS AGAINST PATRIARCH KIRILL 

On 9 June, LRT reported that the Lithuania Foreign Minister has said that the country will seek to have Russian Orthodox Church leader Patriarch Kirill blacklisted in the 7th package of EU sanctions on Russia.  He was excluded from the 6th package of sanctions at Hungary’s request.

https://www.lrt.lt/en/news-in-english/19/1715576/lithuania-to-continue-pushing-for-sanctions-against-patriarch-kirill-foreign-minister

GENETICALLY-MODIFIED PINK PINEAPPLE IS ILLEGAL IN THAILAND, SMUGGLERS FACE JAIL

On 9 June, Thiager reported that a type of genetically-modified pink pineapple is being illegally sold in Thailand, according to a warning issued by the Ministry of Agriculture.  ‘Pinkglow’ pineapples are allegedly less sour than regular pineapples.  Thailand has a strict GMO-free policy in place, and smuggling Pinkglows into the kingdom is a criminal offence.

https://thethaiger.com/news/national/pink-pineapple-is-illegal-in-thailand-smugglers-face-jail-time

IRAN “SMUGGLING MISSILE PARTS VIA PASSENGER FLIGHTS” 

An article in the Jerusalem Post on 9 June reported that Iran has resorted to smuggling precision missile components into Syria via hand luggage on European passenger flights, following an alleged Israeli Air Force strike in May that damaged runways at Damascus International Airport. 

https://www.jewishpress.com/news/middle-east/iran-news/iran-smuggling-missile-parts-via-passenger-flights-after-alleged-iaf-strike-on-damascus-airport/2022/06/09/

UK: FOURTH DOCK WORKER CHARGED WITH DRUG IMPORTATION

A news release from the NCA on 9 June advised that a 44-year-old man has become the fourth Portsmouth dock worker to be charged with drug importation offences as part of a NCA investigation.

https://www.nationalcrimeagency.gov.uk/news/fourth-dock-worker-charged-with-drug-importation

UK: POST-LEGISLATIVE ASSESSMENT OF THE FRAUD ACT 2006

On 8 June, the MoJ published a memorandum which provides an updated post legislative assessment of the Fraud Act 2006 for submission to the House of Lords Select Committee on the Fraud Act 2006 and Digital Fraud.  This was in response to its queries to consider again how effective the Fraud Act 2006 is in tackling fraud and in particular, fraud committed digitally.

https://www.gov.uk/government/publications/post-legislative-assessment-of-the-fraud-act-2006–2

NIGERIA: MILITARY DESTROYS 40 ILLEGAL OIL REFINERIES

On 9 June, OCCRP reported that the Nigerian Army had destroyed 40 illegal refineries and arrested 21 people in a continued clampdown against oil theft in the oil-rich Niger Delta Region.  Oil theft, conducted through tapping and siphoning off official pipelines, is rampant in the region.  The massive pollution caused by oil drilling has disrupted farming and fishing, 2 main sources of income in the region.

https://www.occrp.org/en/daily/16419-nigeria-military-destroys-40-illegal-oil-refineries

SUSPECT ARRESTED IN SLOVAKIA FOR SPREADING HATE SPEECH AND 3D PRINTED WEAPONS MANUALS

A news release from Europol on 8 June advised that an investigation has led to the arrest of a dangerous right-wing extremist.  The individual, known in the international far-right cyberspace, is suspected of spreading extremist hate speech and terrorist activities.  Linked to groups and individuals spreading neo-Nazi, far-right and white supremacist extremist propaganda, he is part of the so-called Siege extremist movement.  The suspect allegedly published instructions and diagrams for manufacturing improvised cold weapons, home-produced automatic firearms, explosives and mines, and instructions for sabotage attacks.

https://www.europol.europa.eu/media-press/newsroom/news/suspect-arrested-in-slovakia-for-spreading-hate-speech-and-3d-printed-weapons-manuals

RECORD HAUL OF ‘SYNTHETIC QAT (KHAT)’ NARCOTICS SEIZED AT SPANISH PORT

On 8 June, The National reported that Spanish police made Europe’s biggest seizure of substances derived from the khat plant, confiscating more than 3.2 tonnes of synthetic cathinones at Barcelona port.

https://www.thenationalnews.com/world/europe/2022/06/08/record-haul-of-synthetic-qat-narcotics-seized-at-spanish-port/

FRAGILE BORDERS: THE ROLE OF CUSTOMS IN SITUATIONS OF CONFLICT AND FRAGILITY

On 7 June, a report from WCO is based on the outcomes of the research programme initiated in 2016 and initially focused on African countries, particularly the Sahel and East Africa, as well as countries in the North Africa and Middle East.  It analyses the specificities of and state responses in border areas in situations of fragility and conflict.  It also shares insights on how Customs can manifest their role in fragile borderlands and post-conflict situations.

http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/research/fragility_secretariatnote_pc_council_2022_may19version_en.pdf?db=web

GREECE PREVARICATES OVER IRAN CRUDE SEIZURE AS DIPLOMATIC STORM ERUPTS

On 8 June, Lloyds List reported that shipment of a confiscated Iranian oil cargo to the US has met days of delay as the Greek Government mulls its next move in efforts to free 2 Greek tankers recently snatched by Iran in retaliation.  It has temporarily blocked 2 shipments of Iranian crude seized by the US amid diplomatic negotiations over the return of 2 Greek tankers seized by Iran last month.

https://lloydslist.maritimeintelligence.informa.com/LL1141163/Greece-prevaricates-over-Iran-crude-seizure-as-diplomatic-storm-erupts

https://www.hellenicshippingnews.com/greek-court-overturns-decision-on-u-s-seizure-of-iranian-oil-cargo-sources/

CONNECTIONS TO PARAGUAY PROSECUTOR’S MURDER STRETCH FROM COLOMBIA TO BRAZIL

On 8 June, Insight Crime reported that new details have emerged about the assassination of Paraguayan prosecutor Marcelo Pecci, including that the hit was methodically planned in the Colombian city of Medellín, that its intellectual authors in Paraguay paid more than $500,000 and that Brazil’s most powerful gang was involved.

https://insightcrime.org/uncategorized/paraguay-prosecutors-murder-plot-hatched-in-colombia/

SIGNIFICANT PROGRESS BEING MADE IN EVIDENCE COLLECTION OF ISIL/DA’ESH’S CRIMES IN IRAQ

A news release from the UN on 8 June advised that significant investigative progress in the collection of evidence has been made into the financing, use of chemical weapons and crimes committed by Islamic State in Iraq and the Levant (ISIL), aka Da’esh, the head of the UN team investigating that group’s crimes told the Security Council, as speakers welcomed the Team’s use of technology to facilitate prosecution and stressed the need to address the group’s continuing proliferation across other regions.

https://www.un.org/press/en/2022/sc14928.doc.htm

POLICE PROBE INTO CHINESE MONEY LAUNDERING SYNDICATE HEADQUARTERED IN AUSTRALIA

On 8 June, the Sydney Morning Herald reported that police have uncovered a suspected Chinese money laundering syndicate headquartered in Victoria and NSW that is moving hundreds of millions of dollars annually to China and across the globe, raising serious questions about whether it is turning a blind eye to organised crime.

https://www.smh.com.au/politics/federal/police-probe-into-chinese-money-laundering-syndicate-headquartered-in-australia-20220608-p5as2t.html

FRAUD WITH SALE OF USED CARS IN CZECH REPUBLIC HALTED WITH EUROJUST SUPPORT

On 8 June, a news release from Eurojust advised that authorities in the Czech Republic and Romania have halted a fraud scheme allegedly involving the sale of used cars, depriving close to 200 victims of approximately €1.6 million.  During an action day, 17 places were searched and 4 suspects were arrested in both countries.

https://www.eurojust.europa.eu/news/fraud-sale-used-cars-czech-republic-halted-eurojust-support

US AUTHORITIES TO START COLLECTING MARIJUANA BUSINESS DATA TO HELP COMBAT MONEY LAUNDERING

On 8 June, the Marijuana Moment website reported that the US Treasury is proposing to start collecting data on marijuana businesses from banks, and the Office of the Comptroller of the Currency (OCC) has posted a notice in the Federal Register saying it plans to track marijuana businesses as part of an annual Risk Summary Form (RSF) that needs to be filed by financial institutions.  The notice says the data allows the agency to “better identify those institutions, and areas within institutions, that may pose heightened risk and allocate examination resources accordingly”. 

https://www.marijuanamoment.net/treasury-department-wants-to-start-collecting-marijuana-business-data-to-help-combat-money-laundering/

NEW YORK: THE ISSUANCE OF US DOLLAR-BACKED STABLECOINS  

On 8 June, the New York State Department of Financial Services (DFS) Superintendent has issued new DFS Regulatory Guidance, setting foundational criteria for dollar-backed stablecoins issued by DFS-regulated entities.   This is said to be the first US financial regulator to issue stablecoin expectations to virtual currency industry.

https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202206081

US PROPOSES $4.3 BILLION FOR URANIUM TO WEAN USERS OFF RUSSIA SUPPLY

On 7 June, Bloomberg reported that the Biden administration has a $4.3 billion plan to buy enriched uranium directly from domestic producers to wean the US off Russian imports of the nuclear-reactor fuel. Energy officials made the case that any interruption in the supply of enriched Russian uranium could cause operational disruptions at commercial nuclear reactors, the person said.  The proposal requires approval from Congress.

https://www.bloomberg.com/news/articles/2022-06-07/us-seeks-4-3-billion-for-nuclear-fuel-to-wean-off-russia-supply

SWISS FEDERAL COUNCIL CONFIRMS THAT SWITZERLAND WILL NOT EXPORT WAR MATERIEL TO UKRAINE 

A news release from the Federal Council on 3 June advised that it had reached a decision on the matter of allowing Swiss war materiel to be transferred by third countries to Ukraine, and on the export of war materiel supplies in the form of individual parts and assembly packages to European defence companies.  Under the War Materiel Act Switzerland cannot approve requests to transfer Swiss-produced war materiel to Ukraine. However, it also says that deliveries of war materiel supplies in the form of individual parts or assembly packages can still be made to European defence companies, even if these parts or packages will be used to produce war materiel abroad that could later be transferred to Ukraine.

https://www.seco.admin.ch/seco/en/home/seco/nsb-news.msg-id-89141.html

THE FIRST NFT INFRINGEMENT CASE IN CHINA

On 9 June, a post from Field Fisher reported on a recent court decision in the first NFT infringement case in China, which it is said is likely to have implications for Chinese and foreign businesses looking to safeguard their rights in the emerging NFT space in China.  In the case, the NFT platform was found liable for its failure to fulfil its duty of care to verify the copyright owner of the work when approving the NFT.  It ordered the platform to immediately delete the NFT work and compensate the Plaintiff for losses.

https://www.fieldfisher.com/en/services/intellectual-property/intellectual-property-blog/new-model-new-rules—no-safe-harbour-in-china-fo

https://elements.visualcapitalist.com/what-are-the-five-major-types-of-renewable-energy/

GAME OVER FOR LOOT BOXES?

On 9 June, a post from Field Fisher posed this question in the light of a recent report published by the Norwegian Consumer Council which criticises the use of loot boxes in video games.  It reviews the current position in the EU under consumer protection laws and gambling laws. The post advises that studios and publishers releasing games with loot boxes should keep a watching brief, and whether an EU-wide approach is adopted remains to be seen.

https://www.fieldfisher.com/en/insights/game-over-for-loot-boxes

LITHUANIA TO BAN ANONYMOUS CRYPTO WALLETS

On 9 June, Crypto Briefing reported that the Finance Ministry is looking to ban non-custodial crypto wallets, with a new regulation which also imposes strict regulations on crypto service providers operating within the nation.

https://cryptobriefing.com/lithuania-to-ban-anonymous-wallets-following-eu-regulation/

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OFAC: NEW RUSSIA SANCTIONS FAQ

On 9 June, OFAC issued 11 new FAQ about the current Russian sanctions regime – the Russian Harmful Foreign Activities Sanctions.

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-06-09

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DETECTING AND REPORTING THE ILLICIT FINANCIAL FLOWS TIED TO ORGANISED THEFT GROUPS AND ORGANISED RETAIL CRIME

A report from ACAMS and the US Immigration & Customs Enforcement published a document described as a Comprehensive Educational Guide for Law Enforcement and Financial Crime Investigators.  It describes organised retail crime as a low-risk, high-reward business line for transnational criminal organizations’ portfolios that presents a significant financial and public safety risk.  While retailers and law enforcement partner to investigate such cases and provide education on the misconceptions and misunderstandings, it is clear there is a missing link in these partnerships, and that link is financial institutions.  It says that criminal organizations need to launder the nearly $70 billion of illicit proceeds gained from such activities annually.  These organisations are looking to launder their billions through the formal financial sector, unregulated payment processors, and online marketplaces.

https://www.acams.org/en/media/document/29436

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UK: TRADING UNDER SANCTIONS WITH RUSSIA

On 8 June, the Department for International Trade provided guidance on what import and export restrictions apply due to sanctions for UK companies when trading with Russia.

https://www.gov.uk/guidance/trading-under-sanctions-with-russia

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FATF: UPDATED AML/CFT CONSOLIDATED RATINGS SCHEDULE

On 9 June, FATF published an updated schedule following publication of a follow-up report on the UK.

https://www.fatf-gafi.org/media/fatf/documents/4th-Round-Ratings.pdf

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UK ORDER TO SUSPEND BVI CONSTITUTION

The UK has made the Virgin Islands Constitution (Interim Amendment) Order 2022.  Following an inquiry into allegations of impropriety in the BVI, this Order is designed to allow action to be taken to address concerns about poor governance by providing for certain provisions of the Constitution to be suspended in whole or in part on an interim basis, and certain other provisions to be given effect in their place.  The Order is being made in order to fulfil the UK broad responsibility to support the Overseas Territories and to ensure their security and good governance for the people in each Territory.  The final report of the Commission of Inquiry identified numerous, serious, failures of governance and concluded that serious dishonesty in relation to public officials is highly likely to have taken place.  Amongst numerous recommendations, the report concluded that the only way in which the relevant issues can be addressed is for there to be a temporary suspension of those parts of the Constitution by which areas of government are assigned to elected representatives.  The report recommended that the suspension should be as short as possible to enable principled elected government to be restored. come into force on such day as the Governor, acting in his or her discretion, may appoint by proclamation 

https://www.legislation.gov.uk/uksi/2022/627/contents/made

https://rijock.blogspot.com/2022/06/read-uk-decision-not-to-institute.html

BVI COMMISSION OF INQUIRY REPORT

On 8 June, the Foreign Commonwealth and Development Office published the report presented to the BVI Governor following an inquiry into the Territory’s governance.

https://www.gov.uk/government/publications/british-virgin-islands-commission-of-inquiry-report

https://www.theguardian.com/world/2022/jun/08/uk-will-not-impose-direct-rule-on-british-virgin-islands-truss-says

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UK: FATF AML/CFT MUTUAL EVALUATION FOLLOW-UP REPORT

On 9 June, FATF published a follow-up report following the 2021 mutual evaluation report.  It says that the country has taken a number of actions to strengthen its framework, and FATF has now re-rated the country on Recommendation 13 from partially compliant to Compliant.  Hence, the UK is compliant on 24 FATF Recommendations and largely compliant on 15 others.  It remains partially compliant on 1 Recommendation.  The UK will remain in regular follow-up and will continue to inform the FATF of progress achieved on improving the implementation of its AML/CFT measures.

https://www.fatf-gafi.org/media/fatf/documents/reports/fur/Follow-Up-Report-United-Kingdom-2022.pdf

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THAILAND DELISTS MARIJUANA AS NARCOTIC

On 9 June, Nikkei Asia reported that Thailand has decriminalised cannabis, delisting hemp and marijuana as narcotics.  However, whereas individuals can grow cannabis plants at home for health purposes, smoking cannabis recreationally remains unlawful, and commercial cultivation without a licence is not allowed.

https://asia.nikkei.com/Politics/Thailand-delists-marijuana-as-narcotic-releases-3-071-inmates

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LETTERS OF CREDIT & SANCTIONS

On 8 June, an article from Hannaford Turner says that there has been concern for many years amongst trade finance practitioners and corporates dealing with LC that both the autonomy and irrevocability of LC are at risk of being undermined through the increasing use of a varied range of sanction clauses.  It says that it is accepted, certainly as a matter of English law, that sanctions (if they apply) override obligations under LC, such that the financial institution may be prevented from making payment regardless of the terms of the LC.  For that reason, it says, there are 2 key questions to be considered when considering the impact of sanctions on an LC transaction.  It warns that it cannot be assumed that any liability of the institution to make a payment under the LC is extinguished once the sanctions clause bites; the clause may simply have the effect of suspending the payment obligation for the period that the prohibition remains in place9 and limiting consequential liability, e.g. due to delay.

https://www.mondaq.com/uk/export-controls-trade-investment-sanctions/1199770/letters-of-credit-sanctions

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UNEXPLAINED WEALTH ORDERS AND TRUSTEES

On 8 June, an article from Charles Russell Speechlys says that trustees or fiduciaries may be at risk of becoming involved or even subject to UWO, if it is suspected that assets which may have been acquired with criminal funds have been invested into structures of which they are trustees.  It notes that the UK Government has also recently introduced new reforms to the UWO regime, which are intended to give enforcement agencies more scope to obtain, enforce, and monitor UWO.  The article considers the implications of the UWO regime for trustees and fiduciaries, looking at the most recent cases where such orders have been made.  It also reviews the recent amendments to the legislation governing UWO introduced in May and explains how those changes have broadened the UWO regime and its possible application to trustees and fiduciaries alike.

https://www.charlesrussellspeechlys.com/en/news-and-insights/insights/private-wealth/2022/unexplained-wealth-orders-trustees/

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