OTHER THINGS YOU MAY HAVE MISSED – SEPTEMBER 21

US: 24 REPUBLICAN STATE ATTORNEYS GENERAL WARN CREDIT COMPANIES OVER PLAN TO IDENTIFY GUN SALES

On 20 September, the Wall Street Journal reported that Visa nad Mastercard have been warned against introduced a new code to identify when purchases are made at firearms retailers.  They argue that categorising the constitutionally-protected right to purchase firearms unfairly singles out law-abiding merchants and consumers alike.  Such merchant codes generally don’t identify the product a card user is buying, they describe the type of store where a purchase was made.  That means transactions with the gun-shop code might involve gun purchases, hunting gear or a gun safe, among other things.

https://www.wsj.com/articles/visa-mastercard-amex-face-calls-from-gop-attorneys-general-to-abandon-gun-shop-code-11663674954

CONTRACTUAL WAIVERS OF FOREIGN SOVEREIGN IMMUNITY

On 20 September, a post on the Transnational Law Blog explains that under FISA foreign states are immune from suit in the US unless an exception applies.  An important and long-standing exception is consent (the more common term in international practice) or waiver (the term used in the US).  The post discusses express contractual waivers of sovereign immunity, and then several other contractual provisions that may function as implied waivers of that immunity.

https://tlblog.org/contractual-waivers-of-foreign-sovereign-immunity

MONEY LAUNDERING TECHNIQUES #6 – TRADE-BASED MONEY LAUNDERING (TBML), THE ART MARKET & CUCKOO SMURFING

On 21 September, the latest in a series of post on money laundering techniques was published.

https://www.linkedin.com/pulse/money-laundering-techniques-5-trade-based-tbml-art-baptiste-/?trackingId=55ukonheRvuYYXwbEgR5sg%3D%3D

ACMA BLOCKS MORE SITES FOR ILLEGAL ONLINE GAMBLING IN AUSTRALIA

On 21 September. iGB reported that, following the latest action, and since the ACMA made its first blocking request in November of 2019, a total of 614 illegal gambling and affiliate websites have been blocked in Australia, while more than 180 illegal services have pulled out of the country since the ACMA began enforcing new illegal offshore gambling rules in 2017.

https://igamingbusiness.com/legal-compliance/acma-blocks-more-sites-for-illegal-online-gambling-in-australia

PHILIPPINE POLICE RESCUE 40 FOREIGN WORKERS FROM ILLEGAL POGO OPERATION

On 20 September, iGB reported that the Philippines Amusement and Gaming Corporation (Pagcor) warned the future of the entire Philippines Offshore Gaming Operator (POGO) sector may be in doubt, following the rescue of 40 migrant workers who it said had been kidnapped by an illegal POGO.

https://igamingbusiness.com/legal-compliance/legal/philippine-police-rescue-40-foreign-workers-from-illegal-pogo-operation

EU CONFIRM THAT CERTAIN SANCTIONS-AFFECTED GOODS MAY BE TRANSFERRED TO THIRD COUNTRIES

On 21 September, the EU Sanctions blog referred to updated FAQ from the EU and questions concerning the transfer of listed goods listed to third countries and the scope of the prohibition on relevant services.  These stress that the EU is committed to avoiding that its sanctions impact food and energy security of third countries around the globe, in particular of the least developed ones.

https://www.europeansanctions.com/2022/09/eu-confirms-certain-goods-listed-under-russia-sanctions-may-be-transferred-to-third-countries/

SMUGGLED PLASTIC IS TRASHING CAMEROON’S ENVIRONMENT

On 21 September, the Institute for Strategic Studies published an article saying that the steady flow of illegal non-biodegradable plastic into the country harms the environment, economy and public health.

https://issafrica.org/iss-today/smuggled-plastic-is-trashing-cameroons-environment

GERMAN CUSTOMS: A TRAIL OF SLIME LED US TO SMUGGLED GIANT AFRICAN SNAILS

On 20 September, IOLA Register reported that customs officials in Dusseldorf followed a trail of slime that led to a almost 100 giant African snails and other items hidden in bags at the airport.

https://www.iolaregister.com/news/world-news/trail-of-slime-leads-to-crime

VERSTAPPEN’S PERSONAL SPONSOR REPORTEDLY INVOLVED IN MONEY LAUNDERING SCANDAL

On 21 September, News 24 reported that a prominent and long-time personal sponsor of world champion Formula 1 Max Verstappen – Jumbo CEO and owner Frits van Eerd – is at the centre of a major scandal in the Netherlands.

https://www.news24.com/sport/motorsport/formulaone/verstappens-personal-sponsor-reportedly-involved-in-money-laundering-scandal-20220921

US: THE LIFTING OF RESTRICTIONS ON THE EXPORT, RE-EXPORT AND TRANSFER OF DEFENCE ARTICLES TO CYPRUS

On 21 September, the EU Sanctions blog reported that the US State Department had lifted restrictions for FY 2023 after the country met the necessary conditions of cooperation under the Eastern Mediterranean Security and Energy Partnership Act 2019 and the National Defence Authorisation Act FY 2020.  An arms embargo was imposed on Cyprus in 1987 and was partially lifted in September 2020.

https://www.europeansanctions.com/2022/09/us-eases-cyprus-arms-embargo/

‘CON QUEEN OF HOLLYWOOD’ FRAUDSTER ARRESTED BY FBI IN MANCHESTER HOTEL

On 21 September, the Manchester Evening News reported that Hargobind Tahilramani, 42, a fraudster known as the ‘con Queen of Hollywood’ impersonated well-known figures to dupe more than 300 victims out of $1million by offering non-existent work in the film business.  She now faces extradition to the US.

https://www.manchestereveningnews.co.uk/news/greater-manchester-news/con-queen-of-hollywood-manchester-25072833

UK: SANCTIONS AGAINST RUSSIA

On 21 September, the House of Commons Library released an updated briefing.

https://researchbriefings.files.parliament.uk/documents/CBP-9481/CBP-9481.pdf

CONGO PRESIDENT ADVISER RESIGNS AFTER CAUGHT IN A BRIBERY TRAP

On 21 September, OCCRP reported that Vidiye Tshimanga, a special adviser to the Democratic Republic of the Congo’s President Felix Tshisekedi, resigned after a tape from an apparent sting operation, released by OCCRP, showed him negotiating a corrupt mining deal.

https://www.occrp.org/en/daily/16783-congo-president-adviser-resigns-after-caught-in-a-bribery-trap

SPAIN SEIZED IN 2021 NEARLY 100 TONNES OF DRUGS IN INTERNATIONAL WATERS

On 21 September, OCCRP reported that Spain seized nearly 100 tonnes of drugs last year in international waters around the Iberian Peninsula, which has for some time been a key point on the smuggling routes from Latin America and North Africa to Europe.

https://www.occrp.org/en/daily/16784-spain-seized-in-2021-nearly-100-tonnes-of-drugs-in-international-waters

SPANISH POLICE CARRY OUT LARGEST-EVER SEIZURE OF FAKE HIGH-END BRAND PRODUCTS IN EUROPE

On 20 September, Euro Weekly reported that more than 5 tonnes of fake products of high-end brands have been seized from a distribution network operating in the Canary Islands, by the Spanish National Police, in a joint operation with the Tax Agency’s Customs Surveillance.  It resulted in 17 arrests, the search of 14 bazaars, 4 warehouses and 3 homes, and the seizure of €70,000 in cash and 3 vehicles.

https://euroweeklynews.com/2022/09/20/spanish-police-carry-out-largest-ever-seizure-of-fake-high-end-brand-products-in-europe/

PODCAST: CREATING A CULTURE OF COMPLIANCE: JONATHAN DRIMMER

In the latest Trace podcast, Jonathan Drimmer of Paul Hastings describes how to create and sustain a culture of compliance. (This episode was originally published in 2019).

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

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EX-HONDURAS FIRST LADY SENTENCED TO PRISON FOR EMBEZZLEMENT

On 21 September, the Mail Online reported that a judge had sentenced former Honduran First Lady Rosa Elena Bonilla de Lobo to 14 years in prison on corruption charges, the second time Bonilla had been sentenced.  The first time Bonilla was convicted and sentenced to 58 years in prison, but the conviction was tossed out due to inconsistencies in the process.  She was re-tried in March and convicted of fraud and embezzlement.

https://www.dailymail.co.uk/wires/ap/article-11236771/Ex-Honduras-lady-sentenced-prison-embezzlement.html

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WAR CRIMES EVIDENCE GUIDE UNVEILED

On 21 September, EurActiv reported that the International Criminal Court and Europe’s judicial arm has issued a set of guidelines to help civil society workers record international atrocities including war crimes and crimes against humanity, specifically in Ukraine.   The guidelines give practical tips, including how to take statements from witnesses and how to store information for later use in ICC prosecutions.

https://www.euractiv.com/section/global-europe/news/war-crimes-evidence-guide-unveiled-in-nod-to-ukraine/

https://www.icc-cpi.int/news/icc-prosecutor-and-eurojust-launch-practical-guidelines-documenting-and-preserving-information

https://www.icc-cpi.int/sites/default/files/2022-09/2_Eurojust_ICC_CSOs_Guidelines_2-EN.pdf

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TYPOLOGY REPORTS: A NEW WEAPON IN THE FIGHT AGAINST THE ONLINE ILLEGAL WILDLIFE TRADE

On 20 September, the Global Initiative Against Transnational Organised Crime has published this report, saying that for several decades, crime typology reports have been successfully applied in the financial industry to assist bank analysts and law enforcement agencies with recognising incidences of money laundering and terror financing.  Research analysed common characteristics among social media posts advertising exotic pets and illegal wildlife parts to determine if typologies could be developed to assist law enforcement, tech firms, the financial industry and other civil society organisations in detecting and tackling wildlife trade offenders in the online sphere and specifically on social media platforms.

https://globalinitiative.net/wp-content/uploads/2022/09/MMFU-ExpandingTheArsenal-web-v4.pdf

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GERMAN POLICE RAID ON PROPERTIES BELONGING TO SANCTIONED RUSSIAN OLIGARCH ALISHER USMANOV

On 21 September, OCCRP reported that the police were searching for evidence of alleged tax evasion and money laundering.  The properties are on the shore of Lake Tegernsee in southern Bavaria.

https://www.occrp.org/en/asset-tracker/german-police-raid-residence-of-russian-oligarch-alisher-usmanov-tax-evasion-and-money-laundering-suspected

https://www.theguardian.com/business/2022/sep/21/german-police-raid-villa-linked-to-russian-oligarch-alisher-usmanov

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EU AMENDS CENTRAL AFRICAN REPUBLIC SANCTIONS

EU Regulation 2022/1624/EU on 20 September amended the current EU sanctions regime following the UN Security Council having adopted Resolution 2648 (2022), which extends the measures and amends the exceptions to the arms embargo.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2022.244.01.0001.01.ENG&toc=OJ%3AL%3A2022%3A244%3ATOC

https://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=uriserv:OJ.L_.2022.244.01.0017.01.ENG&toc=OJ:L:2022:244:TOC

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UK: OFSI UPDATES RUSSIAN SANCTIONS GUIDANCE

On 21 September, OFSI advised that it has updated its guidance adding 3 new questions. Questions 24 to 26 further clarify how to use the food security licensing provision in the relevant regulations, particularly with regard to providing insurance.  

https://www.gov.uk/government/publications/financial-sanctions-faqs

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MALAYSIA: 2020 NATIONAL RISK ASSESSMENT REPORT

On 21 September, the Malay Mail reported on the 2020 NRA, saying that it has identified 5 types of major crimes that contribute to the high threat of money laundering activities in Malaysia.  The 5 are fraud, including fraud in an illegal investment scheme; trafficking of illicit drugs; corruption and smuggling offences; customs and excise duty evasion; and organised crime.

https://www.malaymail.com/news/malaysia/2022/09/21/2020-national-risk-assessment-report-five-types-of-crimes-contribute-to-high-threat-of-money-laundering-activities/29386

https://www.bnm.gov.my/documents/20124/6458991/ar2021_en_wb5.pdf

https://amlcft.bnm.gov.my/documents/6312201/6322748/BNM+%5BNRA2020%5D+Assessment+Report.pdf

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BILLIONAIRE LEV LEVIEV, ACCUSED OF DIAMOND SMUGGLING, TO BE QUESTIONED BY ISRAELI POLICE

On 21 September, the Times of Israel reported that Russian-Israeli billionaire businessman Lev Leviev had arrived in Israel in order to be questioned by police regarding the diamond-smuggling case in which he is a suspect.  Police suspect a company, LLD Diamonds, used couriers to smuggle diamonds into Israel via Ben Gurion International Airport for 16 years.  When police began investigating the scheme, several senior officials at the company were arrested, including the billionaire’s son and former CEO of LLD.

https://www.haaretz.com/israel-news/2022-09-21/ty-article/.premium/billionaire-lev-leviev-accused-of-diamond-smuggling-to-be-questioned-by-israeli-police/00000183-5f39-d533-a3b3-dffd7b9c0000

https://www.timesofisrael.com/diamond-tycoon-lev-leviev-to-be-questioned-in-smuggling-case-after-landing-in-israel/

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US: 47 CHARGED IN $250 MILLION OVER FRAUD IN FEDERAL CHILD NUTRITION PROGRAM DURING THE PANDEMIC

On 20 September, the Minnesota reformer reported that federal criminal charges were filed against 47 people in Minnesota who allegedly participated in a $250 million scheme to exploit a federal child nutrition program during the pandemic.  It is alleged that the defendants falsely claimed to serve more than 125 million meals, with some claiming they served up to 6,000 meals to needy children per day.

https://minnesotareformer.com/2022/09/20/feds-charge-47-in-250-million-feeding-our-future-fraud/

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