‘MOST-WANTED’ CHILEAN ARMS DEALER CONCEALED TIES TO COMPANIES WITH HELP FROM PANAMA’S OFFSHORE INDUSTRY

On 14 September, ICIJ published an article about how Chilean arms dealer Carlos Cardoen sold cluster bombs to Saddam Hussein, and how leaked documents detail how an elite Panamanian firm chose to stick with the notorious former arms merchant.  He was indicted by a federal grand jury in Miami in 1993, charged with illegally importing a metal called zirconium from the US to make cluster bombs sold to Saddam Hussein’s regime in Iraq.  Soon after, Interpol, the international law enforcement agency, issued a “red notice”.  This, the article says, didn’t prevent Arias, Fàbrega & Fàbrega, a prominent Panamanian law firm and offshore service provider, from representing his offshore companies for years after Interpol issued the red notice, leaked documents show.  Cardoen, 80, is still fighting to have Interpol’s notice lifted, and the US didn’t formally file a request for extradition until March 2019.  In March 2020, the Chilean Supreme Court rejected the extradition request, saying that too many years had passed since Cardoen was charged and that the crimes he was accused of have no equivalent under Chilean law.  He is now awaiting the decision on an application for diplomatic immunity.

https://www.icij.org/inside-icij/2022/09/most-wanted-chilean-arms-dealer-concealed-ties-to-companies-with-help-from-panamas-offshore-industry

https://www.prensa.com/mundo/investigacion-de-icij-chileno-acusado-por-estados-unidos-de-trafico-de-armas-registro-empresas-en-panama/

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OFAC ADDS 10 INDIVIDUALS AND 2 ENTITIES TO IRAN SANCTIONS FOR ROLES IN RANSOMWARE ACTIVITY

On 14 September, OFAC announced that 14 new individuals, the AFKAR SYSTEM YAZD COMPANY and the NAJEE TECHNOLOGY HOOSHMAND FATER LLC have been added to its sanctions lists.  The individuals and entities designated today are all affiliated with Iran’s Islamic Revolutionary Guard Corps (IRGC).  This action continues the series of OFAC designations that aim to protect U.S. persons from ransomware and its facilitators, and other cybercrime.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220914

https://home.treasury.gov/news/press-releases/jy0948

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50 MILLION PEOPLE WORLDWIDE IN MODERN SLAVERY

On 12 September, the International Labour Organization reported that the latest estimates show that forced labour and forced marriage have increased significantly in the last 5 years.  10 million more people were in modern slavery in 2021 compared to 2016 global estimates.  Women and children remain disproportionately vulnerable.  Migrant workers are more than 3 times more likely to be in forced labour than non-migrant adult workers. 

https://www.ilo.org/wcmsp5/groups/public/—ed_norm/—ipec/documents/publication/wcms_854733.pdf

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UAE: DUE DILIGENCE REGULATIONS FOR RESPONSIBLE SOURCING OF GOLD

The UAE Ministry of Economy has published this guidance which applies to all Regulated Entities established and/or operating in the territory of the UAE and all commercial free zones and the members of their boards of directors, management and employees. Specifically, and without prejudice to the definition of a DNFBP, the relevant regulations are applicable to all such natural and legal persons involved in the activity of refining.

https://www.moec.gov.ae/documents/20121/296716/MOE_Due+Diligince+Regulations+V9_EN.pdf

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ADDRESSING THE LINKAGES BETWEEN ILLICIT ARMS, ORGANIZED CRIME AND ARMED CONFLICT

The UN Institute for Disarmament Research and the UN Office on Drugs and Crime have published this report which says that linkage between illicit arms, organised crime, and armed conflict can reinforce one another while also escalating and prolonging violence and eroding governance.  Financial gains from crime can lengthen or intensify armed conflicts by creating revenue streams for non-State armed groups.  Illicit arms and ammunition clearly link conflict to crime as well as crime to conflict. Illicit arms can both enable and fuel an armed conflict, while different conflict phases provide opportunities for the diversion of arms and a potentially lucrative income source for organised arms trafficking networks. 

https://www.unodc.org/documents/firearms-protocol/2022/UNIDIR-UNODC_Adressing_the_linkages_between_illict_arms_organized_crime_and_armed_conflict.pdf

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ORGANISED CRIME IN WEST AFRICA DRIVES INSTABILITY AND VIOLENCE

On 14 September, OCCRP said that a new report from the Global Initiative Against Transnational Organized Crime and Corruption, which says that illicit economies, most notably arms trafficking, cattle rustling and kidnapping for ransom, are a major factor behind West Africa’s growing instability. 

https://www.occrp.org/en/daily/16763-report-organized-crime-in-west-africa-drives-instability-and-violence

https://globalinitiative.net/analysis/west-africa-illicit-hub-mapping/

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EU COMMISSION PROPOSES TO PROHIBIT PRODUCTS MADE WITH FORCED LABOUR ON THE EU MARKET

On 14 September, a news release advised that the proposal covers all products, namely those made in the EU for domestic consumption and exports, and imported goods, without targeting specific companies or industries.  National authorities in the Member States will implement the prohibition through a robust, risk-based enforcement approach.  The proposal now needs to be discussed and agreed by the European Parliament and the Council of the European Union before it can enter into force, and will apply 24 months after its entry into force.

https://ec.europa.eu/commission/presscorner/detail/en/IP_22_5415

https://ec.europa.eu/commission/presscorner/detail/en/QANDA_22_5416

https://ec.europa.eu/commission/presscorner/api/files/attachment/873492/SOTEU_factsheet%20FORCED%20LABOUR_EN.pdf.pdf

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EU: RUSSIA SANCTIONS – CONSOLIDATED FAQ

On 8 September, the EU issued updated consolidated FAQ with 9 additional intellectual property FAQ.

https://finance.ec.europa.eu/system/files/2022-09/faqs-sanctions-russia-consolidated_en.pdf

https://finance.ec.europa.eu/system/files/2022-09/faqs-sanctions-russia-ipr_en.pdf

https://www.europeansanctions.com/2022/09/eu-commission-publishes-updated-consolidated-ip-russia-faqs/

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