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.
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.

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.
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.
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.
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.
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.
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.
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.
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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