Month: September 2022

On 30 September, KPMG reported that the Bureau of Industry and Security (BIS) of the US Commerce Department advised that 56 of the entities will be listed on the entity list under the destination of Russia and 1 will be listed under the destination of the Crimea region of Ukraine.  Being placed on the Entity List Entities means the entity is subject to licence requirements for the export or transfer of specified items, such as some US technologies.

https://home.kpmg/us/en/home/insights/2022/09/tnf-us-additions-ear-entity-list.html

https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3146-2022-09-30-bis-press-release-bis-adds-57-to-entity-list-final/file

https://www.steptoeinternationalcomplianceblog.com/2022/09/us-implements-subtle-but-significant-expansions-of-export-controls-on-russia-belarus-and-other-countries/

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On 30 September, OFAC issued this guidance which emphasises the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks.   This guidance also encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.

https://home.treasury.gov/system/files/126/instant_payment_systems_compliance_guidance_brochure.pdf

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On 30 September, OFAC announced a settlement with Tango Card Inc to settle its potential civil liability for 27,720 apparent violations of multiple US sanctions programs, said to be caused by deficient geolocation identification processes.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220930_33

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On 30 September, HM Treasury announced new moves to implement services sanctions and export ban that target Russian economic vulnerabilities in response to Putin’s illegal annexation of Ukrainian regions.  It says that the UK is moving in lockstep with international partners to target key sectors of the Russian economy. The new measures will ramp up economic pressure on the Russian regime by targeting vulnerabilities and disrupting crucial supply chains.  On 30 September, specifically, it designated Elvira Sakhipzadovna NABIULLINA, Governor of the Central Bank of the Russian Federation.  The existing entries for Alexey Ivanovich ISAYKIN and Alexander Dmitrievich KHARICHEV are also amended.

https://www.gov.uk/government/news/sanctions-in-response-to-putins-illegal-annexation-of-ukrainian-regions

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1108510/Notice_Russia_300922.pdf

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On 30 September, OFAC announced the addition of a large number of new individuals and entities on its Russia sanctions list, with a number of others amended, plus new FAQ 1091.  The new names comprise 14 persons in Russia’s military-industrial complex, including 2 international suppliers, 3 key leaders of Russia’s financial infrastructure, immediate family members of some of senior Russian officials; and 278 members of Russia’s legislature.  OFAC also warned of the heightened sanctions risk that international actors outside of Russia would face for providing political or economic support to Russia as a result of its illegal attempts to change the status of Ukrainian territory. 

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1091

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220930

https://home.treasury.gov/news/press-releases/jy0981

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On 28 September, the Wildlife Justice Commission published a report on the rise and fall of one of Vietnam’s biggest wildlife traffickers, Nguyen Van Nam (referred to in the report as Ah Nam).  He was arrested in Hanoi on 30 September 2019 in connection with the illegal trade of ivory; on 16 July 2020 he was convicted and sentenced to 11 years in prison.   Now that the investigation into one of his connections has been concluded, the full extent of efforts to bring Ah Nam to justice can be disclosed.

https://wildlifejustice.org/publications/ah-nam-the-downfall-of-vietnams-wolf-of-wall-street/

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On 29 September, a news release from US DoJ confirmed the indictment of Oleg Deripaska and 3 others.

https://www.justice.gov/opa/pr/russian-oligarch-oleg-vladimirovich-deripaska-and-associates-indicted-sanctions-evasion-and

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On 28 September, a news release from FINTRAC advised of the latest Operational Alert, Laundering of Proceeds from Illicit Cannabis, in support of Project Legion.  This Operational Alert is meant to assist businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act in better identifying and reporting to FINTRAC financial transactions related to the laundering of proceeds from illicit cannabis activities.  It was developed in collaboration with law enforcement and Canada’s largest banks to advance and facilitate Project Legion, Canada’s most recent public-private partnership.  The Alert includes an overview of FINTRAC’s analysis of suspicious transaction reports related to illicit cannabis; “red flags” in indicators of illicit cannabis in relation to online unlicensed dispensaries; and possibly related to illicit cannabis in relation to the cultivation, processing and preparation

https://fintrac-canafe.canada.ca/intel/operation/cannabis-eng

https://fintrac-canafe.canada.ca/new-neuf/nr/2022-09-28-eng

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On 30 September, an Insight from RUSI asks if ‘failure to prevent’ offences had an impact on the criminal liability for corporate entities?  It explains that the basis of a failure to prevent offence is simple – to have any defence, an organisation needs to prove that it had ‘reasonable’ or ‘adequate’ procedures in place to prevent an individual associated with it from carrying out a criminal activity.  The first failure to prevent offence was introduced in relation to bribery in 2010; 2 further failure to prevent offences followed in the Criminal Finances Act 2017 related to the facilitation of tax evasion.

https://static.rusi.org/340_EI_Corporate%20Criminal%20Liability_Westmore_web_final.pdf

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On 29 September, the Guardian reported that Oleg Deripaska, 54, one of Russia’s most powerful oligarchs, who previously had deep links to British establishment figures, has been indicted by the US DoJ for criminal sanctions violations.  The allegations include an elaborate and failed attempt by Deripaska and his associates to shuttle his pregnant girlfriend to the US so that she could give birth there and secure American citizenship for their second child.  It is alleged that Deripaska evaded sanctions in a variety of ways, using corporate shell companies to hide his activities. 

https://www.theguardian.com/world/2022/sep/29/us-charges-russian-billionaire-oleg-deripaska-sanctions

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