OTHER THINGS YOU MAY HAVE MISSED – JUNE 15

Panama Covid-19 update – the garbage workers strike is over (I hadn’t noticed any difference), which is good for health, I guess. Meanwhile, today’s statistics sees 2,080 new cases and 2 new fatalities; with 21,130 active cases and test results still high at 18.7% positive. There are 34 patients in ICU and 243 in other wards.

15 JUNE 2022

UK: ADMISSIBILITY OF BUSINESS RECORDS IN CIVIL PROCEEDINGS

On 13 June, an article from Addleshaw Goddard LLP was concerned with the effects of the Civil Law and Criminal Law (Miscellaneous Provisions) Act 2020, saying that while the overriding objective of the Act was to introduce reform to both the Civil and Criminal Courts in response to the difficulties caused by the COVID-19 pandemic, certain provisions of the Act address pre-existing non-Covid related issues – in particular, the “Hearsay Rule” concerning the admissibility of business records.  The Act introduced a significant change to the law of evidence in civil proceedings by creating a statutory exception to the Hearsay Rule in relation to the admissibility of business records – and creates a presumption that information contained in “business records” are proof of fact without the relevant individual being required to give evidence or be cross-examined.

https://www.addleshawgoddard.com/en/insights/insights-briefings/2020/litigation/the-civil-law-and-criminal-law-miscellaneous-provisions-act-2020-admissibility-of-business-records-in-civil-proceedings/

US AND UK COLLABORATE TO SPUR INNOVATION IN TECH USED TO COMBAT MONEY LAUNDERING

On 13 June, the Wall Street Journal reported that the two governments are teaming up to encourage the development of new machine-learning technologies that could be used to combat money laundering; with a “prize challenge” programme meant to spur innovation in ways to train software to combat financial crime.

https://www.wsj.com/articles/u-s-u-k-collaborate-to-spur-innovation-in-tech-used-to-combat-money-laundering-11655161935

US TREASURY TO EXTEND SANCTIONS CARVE-OUT FOR RUSSIAN ENERGY PAYMENTS

On 14 June, the Wall Street Journal reported that extended a sanctions carve-out allowing US financial institutions to process transactions related to Russian energy sales for nearly 6 months – to 5 December (it was due to expire on 24 June) – as the US seeks to minimise further disruption in global energy markets.

https://www.wsj.com/articles/treasury-to-extend-sanctions-carve-out-for-russian-energy-payments-11655216100

PROLIFERATION OF NEW PSYCHOACTIVE SUBSTANCES BEING SOLD AND CONSUMED IN EUROPE

On 14 June, Sky News reported that total of 52 new psychoactive substances were discovered in 2021 in Europe, according to a report by the EU drug agency.  The European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) said illegal drug manufacturing is on the rise in Europe.

https://news.sky.com/story/drug-production-in-eu-on-the-rise-with-one-new-psychoactive-substance-discovered-each-week-12633690

EU SANCTIONS TO BAN RUSSIAN WOOD PELLET EXPORTS TO EUROPE

On 14 June, Canadian Biomass reported that EU sanctions from 10 July will end Russian wood pellet exports to Europe.  It is said that the EU accounted for 80% of Russian wood pellet exports.

https://www.canadianbiomassmagazine.ca/eu-sanctions-to-ban-russian-wood-pellet-exports-to-europe/

SMUGGLERS TRYING TO MOVE COUNTERFEIT GOODS INTO SINGLE MARKET VIA NORTHERN IRELAND, SAYS EU

On 15 June, Yahoo News reported that the EU has said that several large-scale smuggling incidents show that EU concerns over the operation of the Northern Ireland Protocol are not theoretical.  It was reported that an official said there was evidence criminals were trying to use the Irish Sea crossing to get prohibited products into the EU single market.

https://uk.sports.yahoo.com/news/smugglers-trying-move-counterfeit-goods-113051231.html

Meanwhile –

EU COMMISSION LAUNCHES INFRINGEMENT PROCEEDINGS AGAINST THE UK FOR BREAKING INTERNATIONAL LAW AND PROVIDES FURTHER DETAILS ON POSSIBLE SOLUTIONS TO FACILITATE THE MOVEMENT OF GOODS BETWEEN GREAT BRITAIN AND NORTHERN IRELAND

On 15 June, the EU announced that it had launched its (postponed) infringement proceedings against the UK.  It says that there is a clear breach of international law. The aim of these infringement proceedings is to restore compliance with the Protocol in a number of key areas where the UK hasn’t been implementing it properly – ultimately with the goal of protecting the health and safety of EU citizens.  At the same time, the Commission is providing additional details in position papers on the possible solutions it put forward in October 2021 to facilitate the movement of goods between Great Britain and Northern Ireland.

https://ec.europa.eu/commission/presscorner/detail/en/ip_22_3676

https://ec.europa.eu/commission/presscorner/detail/en/QANDA_22_3679

https://www.gov.uk/government/news/government-introduces-bill-to-fix-the-northern-ireland-protocol

https://ukconstitutionallaw.org/2022/06/13/ronan-cormacain-does-the-vienna-convention-provide-a-legal-off-ramp-for-unilaterally-changing-the-northern-ireland-protocol/ 

EGYPT RECOVERED 29,000 SMUGGLED ANTIQUITIES OVER THE PAST 7 YEARS

On 15 June, the Egypt Independent reported that the items were recovered from several countries such as Austria, Denmark, Kuwait, the UAE, Mexico, France, Italy, Switzerland, the UK, Cyprus, Jordan, Germany and the US.  It is said that in the first money laundering case in which a conviction was issued in Egypt, this was associated with antiquities smuggling.

https://www.egyptindependent.com/egypt-recovers-29000-smuggled-antiquities-in-7-years/

WOMAN PLEADS GUILTY TO ROLE IN LAUNDERING $4 BILLION VIA DANSKE BANK IN ESTONIA

On 15 June, Reuters reported that a Lithuanian woman has pleaded guilty in Denmark to involvement in laundering more than $4.1 billion through Danske Bank’s Estonian branch. 

https://www.reuters.com/business/finance/woman-pleads-guilty-role-laundering-4-bln-via-danske-bank-estonia-2022-06-15/

RUSSIA SANCTIONS: DUTCH NATIONAL COORDINATOR FOR SANCTIONS COMPLIANCE AND ENFORCEMENT REPORT

On 15 June, EU Sanctions blog reported that report considered the Netherlands’ compliance with, and enforcement of, EU sanctions imposed in response to Russia’s aggression against Ukraine.  It is noted that there is no evidence that assets or economic resources of those subject to Russia sanctions have not been frozen.  It criticises the UBO register and data-sharing between official bodies.

https://www.europeansanctions.com/wp-content/uploads/2022/06/ReportbytheNationalCoordinatorforSanctionsComplianceandEnforcement-1.pdf

https://www.europeansanctions.com/2022/06/report-issued-by-dutch-national-coordinator-for-sanctions-compliance-enforcement/

UK: CLASSIFICATION AND SCHEDULING OF BRORPHINE AND METONITAZENE

On 15 June, the Home Office said that it was writing to the Advisory Council on the Misuse of Drugs for advice on the appropriate classification and scheduling of Brorphine and Metonitazene under the Misuse of Drugs Act legislation.  Brorphine is known as “purple heroin” and is a synthetic opioid similar to fentanyl.  Metonitazene is another synthetic opioid, with an indicated potency of between 30 and 200 times that of morphine and has been linked to at least 20 deaths in the US.

https://www.gov.uk/government/publications/classification-and-scheduling-of-brorphine-and-metonitazene

CHINA ALUMINIUM FRAUD ALLEGATIONS SUGGEST LESSONS NOT LEARNED FROM QINGDAO SCANDAL IN 2014

On 14 June, Global Trade Review reported that allegations of financing fraud at aluminium warehouses in China have dredged up memories of the 2014 Qingdao scandal, prompting calls for stronger efforts to tackle double financing and warehouse frauds.  Such cases involve fraud by pledging the same aluminium stocks several times as collateral to different financiers.

https://www.gtreview.com/news/asia/china-aluminium-fraud-allegations-suggest-lessons-not-learned-from-qingdao/

UK: CROSS-MODAL AND CROSS-GOVERNMENT PLAN FOR THE UK FREIGHT TRANSPORT SECTOR 

On 15 June, the Department for Transport published its “Future of Freight” plan, which sets out how the UK Government and industry have agreed to work more closely together, and with the devolved administrations, to deliver a world-class, seamless flow of freight across our roads, railways, seas, skies and waterways.  Plans include a National Freight Network (NFN) across road, rail, maritime, aviation, inland waterway and warehouse infrastructure, with the long-term aim be to remove the barriers which prevent the seamless flow of freight.

https://www.gov.uk/government/speeches/future-of-freight-plan

EXTENT OF GLOBAL DARK FLEETS MAPPED FOR THE FIRST TIME

On 15 June, OCCRP reported that an international non-profit organisation has released the first ever global map of so-called ‘dark fleets,’ or fishing vessels that do not broadcast their location or appear in public monitoring systems.  The map is exposing the extent of illegal fishing worldwide.  In addition to engaging in often illegal, unregulated and unlicensed fishing, criminality, from human trafficking to labour exploitation and even murder, is rampant on board.

https://www.occrp.org/en/daily/16435-extent-of-global-dark-fleets-mapped-for-the-first-time

GREEK PROSECUTOR: CHARGES AGAINST JOURNALISTS IN NOVARTIS CASE SHOULD BE DROPPED

On 15 June, OCCRP reported that a prosecutor at the Greek supreme court has recommended that charges against 5 journalists accused of conspiring to defame politicians while reporting on the disputed Novartis corruption case should be dropped.  The Novartis case has been fuelled by various controversies, including the decision not to prosecute government ministers who were found to have large amounts of money on their accounts that was of unexplained origin.

https://www.occrp.org/en/daily/16434-greek-prosecutor-charges-against-journalists-in-novartis-case-should-be-dropped

INTERNATIONAL POLICE COOPERATION TARGETS TELECOMMUNICATION FRAUD, BUSINESS MAIL COMPROMISE (BEC) AND ASSOCIATED MONEY LAUNDERING

A news release from INTERPOL on 15 June advised that a 2-month worldwide crackdown on social engineering fraud has seen scammers identified globally, substantial criminal assets seized and new investigative leads triggered in every continent.

https://www.interpol.int/News-and-Events/News/2022/Hundreds-arrested-and-millions-seized-in-global-INTERPOL-operation-against-social-engineering-scams

INDIAN CUSTOMS OFFICIALS AND SRI LANKAN NATIONALS SPAR OVER ‘POSSESSION’ OF 7 KG GOLD

On 14 June, WION reported on a 12-day “battle for gold” between 6 Sri Lankan nationals and Air Customs Officials of the Chennai International Airport is expected to reach the Madras High Court.  The passengers have stayed put at the Chennai airport, demanding that Customs officials return the gold bars that were allegedly forcibly taken from them.  They argue that they are transit passengers on a Dubai-Chennai-Colombo route and that Indian Customs have no jurisdiction to seize legally purchased gold that was to be taken to Colombo and meant to be declared before Sri Lankan Customs. 

https://www.wionews.com/india-news/indian-customs-officials-and-sri-lankan-nationals-spar-over-possession-of-7kg-gold-488075

BRAZIL: POWERFUL NEW CHEMICAL USED TO CUT COCAINE AND CRACK FOUND IN SÃO PAULO

On 14 June, Insight Crime reported that police have made a rare yet large-scale seizure of a chemical intended for industrial applications – Irganox 1076, used as an antioxidant in multiple industries to extend the life of plastic – but which is now being used as a novel cutting agent in the final stages of cocaine and crack production.  Such a large seizure of Irganox 1076 may mark the introduction of a new cutting agent into the São Paulo drug economy, yet it joins the long list of such chemicals used in the country.  Similar antioxidants have been found in Brazilian cocaine products since 2019.

https://insightcrime.org/news/powerful-new-chemical-used-to-cut-cocaine-and-crack-found-in-sao-paulo/

PROLIFIC MONEY LAUNDERER DARIO MESSER SENTENCED IN BRAZIL 

On 14 June, Insight Crime reported that Dario Messer, the financier behind one of Latin America’s largest-ever money laundering schemes, has been sentenced to 13 years in prison, with a court rejecting his appeal against a sentence first handed down in August 2020.  In total, his network is believed to have moved $1.6 billion dollars illicitly across more than 3,000 bank accounts in 52 countries between 2011 and 2017.

https://insightcrime.org/news/prolific-money-launder-dario-messer-sentenced-in-brazil-but-paraguay-left-hanging/

NEW NATIONALITY AND BORDERS ACT MAY HAVE ‘SIGNIFICANT IMPACT’ ON TRAVEL TO UK

An article from Out-Law on 15 June warned that UK employers and inbound travellers may soon face delays to visa processing, as they prepare for the introduction of new immigration legislation on 28 June. The Act also includes new rules for Electronic Travel Authorisation (ETA) – an electronic waiver for travel to the UK in the absence of a visa.

https://www.pinsentmasons.com/out-law/news/new-nationality-borders-act-may-have-significant-impact-travel-to-uk

RUSSIA’S WAR ON UKRAINE: IMPLICATIONS FOR TRANSPORT

A briefing paper from the EU Parliament Research Service on 15 June says that the European Parliament is playing an active role by closely monitoring and evaluating the situation, including the EU action taken so far, while also proposing the adoption of additional EU measures to support passenger and freight traffic flows.

https://www.europarl.europa.eu/RegData/etudes/BRIE/2022/733536/EPRS_BRI(2022)733536_EN.pdf

THE CONSTRUCTION MAFIA IN SOUTH AFRICA

On 14 June, the Global Initiative Against Transnational Organised Crime published a report which focuses on understanding how these criminal groups, widely referred to as the construction mafia, operate, their involvement in systemic extortion, and the long-term implications for the construction industry in South Africa.

https://globalinitiative.net/wp-content/uploads/2022/06/GITOC-Extortion-or-Transformation-The-construction-mafia-in-South-Africa.pdf

NETHERLANDS: HOLIDAY PARKS ARE USED FOR LARGE SCALE MONEY LAUNDERING

On 13 June, Dutch News reported that holiday homes are being increasingly targeted as vehicles for large scale money laundering operations by criminal gangs.  It is said that said holiday parks are a relatively easy means for criminals to launder cash and that ‘worrying signals’ about investments in the parks by criminals had prompted an investigation.

https://www.dutchnews.nl/news/2022/06/holiday-parks-are-used-for-large-scale-money-laundering-report/

PODCAST: UK – “BUTLER TO THE WORLD”

In the latest TRACE podcast, Oliver Bullough joins the podcast again to discuss his latest book: Butler to the World.  The book addresses how the UK went from a colonial power dominating the world to a service provider—or butler or perhaps consigliere—to the world’s oligarchs.

https://www.traceinternational.org/resources-podcast

BETWEEN 24 FEBRUARY AND 7 JUNE CANADA FROZE $123 MILLION IN ASSETS AND BLOCKED $289 MILLION IN TRANSACTIONS PURSUANT TO ITS RUSSIA SANCTIONS REGIME

On 15 June, EU Sanctions blog reported on the latest update from the RCMP on assets frozen or blocked in Canada.

https://www.europeansanctions.com/2022/06/canada-has-frozen-123-million-under-russia-sanctions/

The information in the infographic is based on the latest Henley Global Citizens Report. 

https://www.visualcapitalist.com/migration-of-millionaires-worldwide-2022/

ART FRAUDSTER OF FAKE ‘TURNER’ PAINTING CON IS TRACKED DOWN AFTER 13 YEARS ON THE RUN AND FACES EXTRADITION TO US

On 15 June, the Daily Mail reported that a British art fraudster, Angela Hamblin, 73, who has been on the run for 13 years faces extradition to the US after finally being caught.  She made nearly £500,000 by passing off fake paintings as being by Turner and other artists, and pleaded guilty in New York before disappearing without serving a 12-month sentence.  She was stopped in Frankfurt on a flight from Vienna to Edinburgh, having lived quietly in the Scottish Borders village of St Boswells.

https://www.dailymail.co.uk/news/article-10921003/Art-fraudster-nearly-500-000-fake-Turner-painting-tracked-13-years.html

US: FORMER VICE-PRESIDENT OF A BUSINESS THAT OFFERED EDUCATIONAL TRIPS FOR GRADE SCHOOL AND HIGH SCHOOL STUDENTS HAS PLEADED GUILTY TO FRAUD AND MONEY LAUNDERING

A DoJ news release on 15 June advised that Joseph A. Cipolletti, 47, the former vice-president of Discovery Tours Inc, a business located in Ohio that offered educational trips for grade school and high school students, had pleaded guilty in federal court to devising a scheme to take payments for trips and then using the funds for personal expenses.  As a result of Cipolletti’s actions and subsequent attempts to cover up the scheme, in May 2018, Discovery Tours abruptly ended operations and filed for bankruptcy.  

https://www.justice.gov/usao-ndoh/pr/former-vice-president-discovery-tours-pleads-guilty-fraud-and-money-laundering

SYNTHETIC OPIOIDS ARE AN EVERYTHING PROBLEM

On 9 June, the RAND Corporation in the US published this article saying that synthetic opioids are a supply chain, cybercrime, public health, national security, economic problem and homeland security for the US.  It says that fatal drug overdoses — primarily from illegally manufactured synthetic opioids — have increased sharply in recent years, and they’re not slowing down.  Potent and dangerous synthetic opioids affect a wide range of policy areas and require a comprehensive response, and it is time to meet this everything problem where it is: everywhere.  One point it makes is that the properties of some synthetic opioids make them ideal for illegal suppliers and the sudden shift toward illegally manufactured fentanyl in recent years has contributed to deadly results among those who use drugs. Unlike heroin, which comes from poppy fields that need time and space to mature for harvest, synthetic opioids can be made quickly, indoors, and with chemicals that can be easy to acquire.

https://www.rand.org/blog/articles/2022/06/synthetic-opioids-are-an-everything-problem.html

SEC PROPOSES REGULATIONS TO ADDRESS “GREENWASHING” BY INVESTMENT FUNDS

On 15 June, a post on the Compliance & Enforcement blog from the Program on Corporate Compliance and Enforcement at the New York University School of Law was concerned with 2 proposed rules intended to combat “greenwashing”.  It explains that the practice of “greenwashing” refers to when firms or companies claim they are abiding by ESG principles, especially environmental, when in fact they do not so comply.

https://wp.nyu.edu/compliance_enforcement/2022/06/15/sec-proposes-regulations-to-address-greenwashing-by-investment-funds/

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CULLEN COMMISSION – RCMP AND FINTRAC BLAMED IN LANDMARK REPORT ON MONEY-LAUNDERING

On 15 June, many sources contained details of the Cullen Commission report on money laundering involving the gambling sector and property in British Columbia.  It is said that it is impossible to know just how much criminal cash is laundered in the province every year, but that some estimates put the amount “in the billions”.  In additional to a new AML commission, Cullen recommended the creation of “a dedicated provincial money laundering intelligence and investigation unit with a robust intelligence division”.  The report criticised the RCMP for its “lack of attention to money laundering [that] has allowed for the unchecked growth of money laundering since at least 2012”.  Reports of drug traffickers and organised criminals laundering money through British Columbia casinos was one of the main reasons the Cullen Commission was established by Premier John Horgan in May 2019.

https://theprovince.com/news/crime/cullen-commission-makes-101-recommendations-to-tackle-money-laundering-in-b-c

https://www.thestar.com/news/canada/2022/06/15/canadas-anti-money-laundering-regime-is-broken-finds-bc-report.html

https://www.nytimes.com/2022/06/15/world/canada/canada-money-laundering.html

https://www.piquenewsmagazine.com/opinion/opinion-cullen-commission-on-bc-money-laundering-is-only-the-starting-point-of-a-long-road-5483420

The report itself is on the Cullen Commission website –

https://cullencommission.ca/

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FinCEN ISSUES ADVISORY ON ELDER FINANCIAL EXPLOITATION

On 15 June, FinCEN issued an Advisory to alert financial institutions to the rising trend of elder financial exploitation (EFE).  EFE involves the illegal or improper use of an older adult’s funds, property, or assets, and is often perpetrated either through theft or scams.  The Advisory highlights new EFE typologies and red flags since FinCEN issued its first advisory on the issue in 2011. 

https://www.fincen.gov/news/news-releases/fincen-issues-advisory-elder-financial-exploitation

https://www.fincen.gov/sites/default/files/advisory/2022-06-15/FinCEN%20Advisory%20Elder%20Financial%20Exploitation%20FINAL%20508.pdf

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US SANCTIONS MEMBERS OF RUSSIAN VIOLENT EXTREMIST GROUP – THE RUSSIAN IMPERIAL MOVEMENT (RIM) – AND SWEDISH NATIONAL

On 15 June, OFAC designated 2 key supporters of the ethnically motivated violent extremist group known as the Russian Imperial Movement (RIM) pursuant to Executive Order (EO) 13224.  RIM itself was previously designated by the Department of State as a Specially Designated Global Terrorist (SDGT) organisation on 7 April 2020 for having provided training for acts of terrorism.  Stanislav Shevchuk is a Europe-based representative of RIM, and Alexander Zhuchkovsky is a Russia-based supporter of RIM.  At the same time Swedish national Anton Thulinis designatedfor his continued pursuit of terrorist training, even after serving his prison sentence for 2017 attacks in Sweden, which demonstrates that he continues to be a terrorism threat.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220615

https://home.treasury.gov/news/press-releases/jy0817

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IRAN’S SEIZURE OF 2 GREEK-FLAGGED VESSELS: AN INTERNATIONAL LAW PERSPECTIVE

On 15 June, a post from the European Journal of International Law by a Researcher at the Athens Public International Law Centre considers the retaliatory seizure of 2 Greek oil tankers in international waters for Greece’s seizure of an Iranian oil tanker in Greek water.

https://www.ejiltalk.org/irans-seizure-of-the-two-greek-flagged-vessels-an-international-law-perspective/

INDUSTRY RELEASABLE THREAT BULLETIN (IRTB) FOLLOWING SEIZURE OF 2 GREEK TANKERS IN GULF

Following the recent incidents where 2 Greek-Flagged ships were seized by Iranian forces, the Combined Maritime Force (CMF) and the EU’s Naval Force (EUNAVFOR) have issued an Industry Releasable Threat Bulletin (IRTB) on the incident.

https://www.ukpandi.com/media/files/uk-p-and-i-club/articles/2022/20220527-irtb-31.pdf

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UK SANCTIONS CHANGES – RUSSIA, ISIL/AL-QAIDA, IRAN

On 14 June, 3 Notices from HM Treasury advised of changes to UK sanctions lists. 

Russia – 3 entries corrected and 39 others amended.

ISIL/Al-Qaida – 6 entries relating to individuals amended.

IRAN – the entry relating to Parvis FATAH was amended.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1082659/Notice_Russia_140622.pdf

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1082654/Notice_ISIL__Da_esh__and_Al-Qaida_140622.pdf

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1082661/Notice_Iran__Nuclear__140622.pdf

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UK: RESPONSE TO CONSULTATION ON PROPOSED CHANGES TO THE MONEY LAUNDERING REGULATIONS

On 15 June, HM Treasury published the Government response to a consultation held between 22 July and 14 October 2021.  The response to the consultation summarises views from responses to the consultation and sets out the findings and the decisions the government has taken as a result.

https://www.gov.uk/government/consultations/amendments-to-the-money-laundering-terrorist-financing-and-transfer-of-funds-information-on-the-payer-regulations-2017-statutory-instrument-2022

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FROM 15 JUNE THE UK SANCTIONS REGIME MOVES TO A STRICT LIABILITY TEST

On 14 June, an article from Hogan Lovells was concerned with changes to the enforcement of UK sanctions laws that parallel enforcement powers of OFAC in the US.  The 2 major developments introduced by the Act include the introduction of a strict liability test and the publication of breaches.

https://www.engage.hoganlovells.com/knowledgeservices/news/from-15-june-the-uk-sanctions-regime-will-be-moving-to-a-strict-liability-test

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EXPORT CONTROLS: ENFORCEMENT AGENCIES SHOULD BETTER LEVERAGE INFORMATION TO TARGET EFFORTS INVOLVING US UNIVERSITIES

A report from the Governmental Accountability Office on 14 June says that millions of foreign students and scholars study at US universities, and many contribute to US research – but there’s a risk that some may illegally access and share sensitive information, such as data or technology, with their home countries.  The GAO recommends that agencies determine which universities are at greater risk for such transfers and target outreach and education to them.

https://www.gao.gov/products/gao-22-105727

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