OTHER THINGS YOU MAY HAVE MISSED – SEPTEMBER 22

Just to mention that in the news today it was reported that the Colón Free Zone (CFZ), the largest free zone in the Americas, has reported a turnover of $12.398 billion for the first 7 months of the year. This is apparently an increase of 20% over pre-Covid 2019.

In more good news (I think), the inflation rate, which was over 6% only a few weeks ago, is now said to only around 2.1% – due, it seems to fuel and other subsidies introduced recently.

22 SEPTEMBER 2022

UK: NATIONAL CRIME AGENCY CONFIRMS THAT LAWYERS WERE AMONGST THOSE ARRESTED IN A SANCTIONS-EVASION CRACKDOWN

In its Financial Crime Time newsletter of 20 September, law firm RPC reported that at least 10 individuals have been arrested on suspicion of assisting others to evade sanctions.  The arrests made are said to range from lawyers and solicitors through to those who are registered with the security industry association, and to include a variety of sectors, from private schools to estate agents to auction houses to solicitors.

https://www.rpc.co.uk/perspectives/regulatory-updates/financial-crime-time-your-update-from-rpc-2022-q3/#page=1

UK: MORE THAN 16,000 BUSINESSES THAT RECEIVED GOVERNMENT-BACKED COVID-19 BOUNCE BACK LOANS (BBLS) HAVE GONE BUST WITHOUT REPAYING THE MONEY

Also in the Financial Crime Time newsletter of 20 September, RPC reports a Freedom of Information request and a potential cost to the taxpayer of £500 million.  With to date, 260 directors having been disqualified with their companies still having loans outstanding, the prospect of the government being able to successfully recover these loans is slim.  Despite this, the Insolvency Service has only brought 1 prosecution to date – meanwhile, another entry on the newsletter warns of planned cuts to law enforcement in the UK.

https://www.rpc.co.uk/perspectives/regulatory-updates/financial-crime-time-your-update-from-rpc-2022-q3/#page=1

HOW TO MITIGATE AGAINST A FORCE MAJEURE EVENT

On 20 September, HFW reported that the Russian invasion of Ukraine has turned the spotlight onto 2 particular types of clause in commodities contracts: sanctions and force majeure, and that a large number of affected commercial parties triggered the force majeure clauses in their contracts.  A risk is that English courts and arbitration tribunals will interpret such clauses strictly and narrowly, against the party seeking to rely on them.  In English law, a party affected by a force majeure event generally has an obligation to mitigate the effect of that event.  Where the obligation begins and ends, however, has proved difficult to judge for commercial parties.  It says that a recent decision of the Commercial Court (unrelated to the Ukraine war) has attracted particular interest because it required first the arbitral tribunal and then the Commercial Court to interpret a force majeure provision in light of the application of sanctions, and offers some guidance on mitigation.

https://www.hfw.com/How-deep-do-you-need-to-dive-to-mitigate-against-a-FM-event-Sept-2022

GREENWASHING AND THE LAW IN THE UK

On 21 September, an article from Stewarts examined the existing regulatory landscape in the UK.  It notes that there is currently no specific anti-greenwashing legislation in the UK, and that consequently there is currently no legal definition of greenwashing in England and Wales.  However, businesses falsely advertising products as ‘green’ or sustainable may be caught by existing laws including for misrepresentation or consumer protection laws which prevent false advertising.

https://www.stewartslaw.com/news/greenwashing-and-the-law-in-the-uk/

SWITZERLAND: ADDITIONAL TRANSPARENCY OBLIGATIONS FROM OF 1 JANUARY

On 20 September, an article from Walder Wyss Ltd was concerned with new transparency requirements for “associations” (vereine) being introduced from 1 January.  It notes that certain charitable or non-profit associations will now be subject to mandatory registration in the Commercial Register.  Additionally, all associations subject to registration are obliged to keep a register of members and must be able to be represented by a person domiciled in Switzerland – although an 18-month transition period applies.

https://www.walderwyss.com/user_assets/publications/Newsletter-178_E_2022-09-20-073209_mmxy.pdf

COLOMBIA: THE NAVY IS TAKING ON GANGS IN THE COUNTRY’S BIGGEST PORT

On 16 September, Dryad Global reported on the situation in Buenaventura, Colombia’s biggest port, where 40% of the country’s international trade takes place and said to be the departure point of most of the cocaine destined for the US.  It is said that 2 gangs have been fighting for months over control of Buenaventura’s drug trafficking trade, and other illegal activities such as micro-trafficking, extortion and kidnappings, making it one of the most violent cities in the country.  The article reports that the military has tried to assert some state control by coming out in force in several neighbourhoods. 

https://channel16.dryadglobal.com/navy-taking-on-gangs-in-colombias-biggest-port

IMPUNITY FOLLOWS OFFSHORE ATTACKS IN MEXICO

On 19 September, Dryad Global reported on the apparent impunity with which criminal gangs have acted re thefts from shallow-water oil platforms and support vessels involved in Mexico’s offshore oil and gas industry.  The number of attacks on offshore platforms and services vessels has doubled this year to 22, compared with 11 last year, with 4 attacks carried out on a single night in June – although, following a peak of 273 incidents in 2017, attacks have declined since 2020.  While criminals previously targeted remote and minimally-staffed platforms, recent attacks have included larger complexes, as well as the newly-launched Ichalkil field operated by Lukoil.

https://channel16.dryadglobal.com/impunity-follows-offshore-attacks-in-mexico

AUSTRALIA: SRI LANKAN FISHERMEN AND PEOPLE SMUGGLING

On 21 September, ABC News carried an article saying that key Australian government tool to combat people smuggling from Sri Lanka can be easily dodged by perpetrators, with the GPS trackers provided to the Sri Lankan government to monitor fishing trawlers being easily removed.  June saw the highest number of illegal boat interceptions by Australian Border Force since 2013, and all were from Sri Lanka, and more than 1,000 Sri Lankans have tried to reach Australia by boat this year.  It is also reported that official sources have told ABC that they are investigating the brother of a Sri Lankan government MP over allegations of people smuggling to Australia.

https://www.abc.net.au/news/2022-09-22/sri-lankan-people-smugglers-find-ways-around-australian-trackers/101419172

FAT LEONARD: MALAYSIAN CRIMINAL IN US NAVY SCANDAL RECAPTURED

On 22 September, the BBC reported that a Malaysian businessman who scammed the US Navy in its biggest fraud scandal ever has been recaptured after he escaped house arrest.  Leonard Glenn Francis, aka “Fat Leonard”, was captured in Venezuela attempting to board a flight to Russia.  Interpol says he entered the country from Mexico via a stopover in Cuba and he is due to be extradited back to the US.

https://www.bbc.com/news/world-us-canada-62976844

WIRECARD: REPORTER WARNS OF LACK OF EQUALITY OF ARMS AGAINST COMPANIES WITH PRACTICALLY UNLIMITED RESOURCES

On 22 September, the Press Gazette carried an interview with Dan McCrum, who led the Financial Times reporting on the Wirecard scandal, who said that said he hoped publishers realised the “brand benefit” of investigative journalism, and that the 6-year Wirecard saga demonstrated the importance of editors.

https://pressgazette.co.uk/dan-mccrum-financial-times-wirecard/

A FRESH APPROACH TO COUNTERING ILLICIT FINANCIAL FLOWS IS NEEDED TO COUNTER NEW AND EMERGING THREATS

On 22 September, a Policy Brief from RUSI said that a taskforce had developed a set of principles and actions that US and UK governments must implement to better detect and disrupt illicit finance linked to corruption and kleptocracy.  These are said to be grounded in 3 underlying principles which should be the foundation of any future transatlantic response to illicit finance: honesty; cross-border collaboration; and ambition.

https://rusi.org/explore-our-research/publications/policy-briefs/illicit-finance-threat-democracies-transatlantic-response

UK: WITNESSES CAN GIVE EVIDENCE IN CRIMINAL TRIALS FROM OUTSIDE THE UK VIA WHATSAPP WHEN IT IS ‘IN THE INTERESTS OF JUSTICE’

On 21 September, the Law Society Gazette reported that the Court of Appeal has said that the messaging platform, which uses end-to-end encryption, is ‘capable of being regarded as sufficiently secure’ for giving evidence in open court.  The use of WhatsApp is permissible under temporary provisions contained in the Coronavirus Act 2020 and also under the new regime of ‘expanded powers’ in the Police, Crime, Sentencing and Courts Act 2022.

https://www.lawgazette.co.uk/news/witnesses-can-give-evidence-by-whatsapp-court-of-appeal-rules/5113719.article

NIGERIAN AUTHORITIES RAID CYBERCRIME TRAINING CENTRES

On 22 September, OCCRP reported that Nigerian authorities raided several schools which specialised in teaching internet fraud and arrested 2 owners and 7 students.  Cybercrime, known in Nigeria as ‘yahoo-yahoo’, is a flourishing industry that attracts many young people who are looking for any kind of jobs in a country with a 33.3% unemployment rate.

https://www.occrp.org/en/daily/16791-nigerian-authorities-raid-cybercrime-training-centers

NIGERIA SEIZES RECORD 1.8 TONNES OF COCAINE

On 22 September, OCCRP reported that Nigeria’s law enforcement snatched 1.8 tonnes of cocaine in what officials described as the biggest seizure in the history of the country’s anti-drug agency.  The drug was discovered in a warehouse in a quiet estate in Lagos’ Ikorodu neighbourhood.

https://www.occrp.org/en/daily/16789-nigeria-seizes-record-1-8t-of-cocaine

NEW REFORMS TO ENSURE UK RETAINS POSITION AS A LEADER IN INTERNATIONAL ARBITRATION

On 22 September, the Law Commission in the UK has published a consultation paper which contains provisional law reform proposals to ensure that the Arbitration Act 1996 remains state of the art.  Arbitration is a major area of activity, and the Chartered Institute of Arbitrators, headquartered in London, has more than 17,000 members across 149 countries.  Industry estimates suggest that international arbitration has grown by about 26% between 2016 and 2020, with London the world’s most popular seat.  The Arbitration Act 1996 provides a framework for arbitration in England and Wales and Northern Ireland, and it has been 25 years since the Act came into force. The Commission says that this anniversary presents a good opportunity to revisit the Act, to ensure that it remains state of the art, so that it provides an excellent basis for domestic arbitration, and continues to support London’s world-leading role in international arbitration. 

https://www.lawcom.gov.uk/project/review-of-the-arbitration-act-1996/

AN ACCUSED MEXICAN DRUG TRAFFICKER SUING NETFLIX AND TELEMUNDO FOR ROYALTIES OVER PORTRAYALS OF DRUG TRAFFICKERS ON TV

On 21 September, Insight Crime reported that Sandra Ávila Beltrán, once dubbed Mexico’s “Queen of the Pacific”, is demanding the streaming platform and TV channel pay her 40% of the royalties for the Spanish-language show “Queen of the South,” co-produced by Netflix and Telemundo, marking the latest legal battle surrounding portrayals of drug traffickers on TV.

https://insightcrime.org/news/drug-traffickers-royalties-narco-series/

FATCA LEGISLATION AND ITS APPLICATION AT INTERNATIONAL AND EU LEVEL

On 22 September, a briefing from the EU Parliament Research Service provides in-depth analysis which updates a previous report commissioned by the European Parliament’s Policy Department for Citizens’ Rights and Constitutional Affairs and describes the most relevant developments in the period 2018-2022 in chronological order and then draws conclusions which include a systemic view of the current institutional dynamics, a provisional legal analysis on the basis of existing rules and policy suggestions.  FACTA is the Foreign Account Tax Compliance Act and a previous report considered the unilateral extraterritorial reach of FATCA legislation of the US, and the chief concern of the reports is how FACTA interacts with EU data protection laws.

https://www.europarl.europa.eu/RegData/etudes/IDAN/2022/734765/IPOL_IDA(2022)734765_EN.pdf

MORE QUESTIONS THAN ANSWERS?  THE EU NEW AML AUTHORITY

On 22 September, a post from the LSE said that the EU is set to establish a new Anti-Money Laundering Authority next year.  The post says that while the new authority is a step in the right direction, there remain more questions than answers over how it will function and where it will be based.  The new Anti-Money Laundering Authority (AMLA) is now supposed to be established by 1 January, although it is only expected to be operational by the beginning of 2024, to be fully staffed by 2025, and to directly supervise financial institutions as of 2026.  As a result, it is said, a number of key questions remain.

https://blogs.lse.ac.uk/europpblog/2022/09/22/more-questions-than-answers-the-eus-new-anti-money-laundering-authority/

INDIA: THE ABG SHIPYARD MONEY LAUNDERING CASE

On 22 September, Business Standard provided an update on the case, saying that the Enforcement Directorate had attached (restrained) assets involving dockyards, agricultural lands, commercial properties and bank deposits.  The case involves alleged bank loan fraud linked to money laundering, and the latest action comes a day after the CBI arrested the founder of the company, Rishi Kamlesh Agarwal.

https://www.business-standard.com/article/companies/abg-shipyard-ed-attaches-assets-worth-rs-2-747-cr-in-money-laundering-case-122092200620_1.html

US DoJ FORMS NATIONAL NETWORK OF PROSECUTORS FOCUSED ON CRYPTO CRIME

On 16 September, the Wall Street Journal reported that the DoJ is to use more than 150 federal prosecutors across the country to bolster law enforcement’s efforts to combat the rise in crypto crime.  The Digital Asset Coordinators Network is intended to designate subject-matter experts in US Attorneys’ offices on the complex technical and legal complications posed by cryptocurrency cases.

https://www.wsj.com/articles/justice-department-forms-national-network-of-prosecutors-focused-on-crypto-crime-11663322407

US: CLOTHING WHOLESALER AGREES TO PLEAD GUILTY TO VIOLATING DRUG TRAFFICKING LAW AND COMMITTING $6.4 MILLION CUSTOMS FRAUD

A news release from US DoJ on 20 September advised that a clothing wholesale company, Ghacham Inc, which does business under the “Platini” brand name,  has agreed to plead guilty to federal criminal charges for undervaluing imported garments in a scheme to avoid paying almost $6.4 million in customs duties and for doing business with a woman in Mexico who has ties to the Sinaloa drug cartel.  According to court documents, Ghacham Inc. imported clothing from China and submitted fraudulent invoices to US Customs and Border Protection that undervalued the shipments, allowing it to avoid paying the full amount of tariffs owed on the imports.

https://www.justice.gov/usao-cdca/pr/clothing-wholesaler-agrees-plead-guilty-violating-us-drug-trafficking-sanctions-and

CAMBODIA SCAMS: LURED AND TRAPPED INTO FRAUD FACTORY SLAVERY IN SOUTH-EAST ASIA

On 21 September, the BBC reported on thousands of workers who have fallen prey to human traffickers running job scams in SE Asia, with governments across Asia – including Indonesia, Vietnam, Malaysia, Hong Kong and Taiwan – issuing warnings.  Lured by adverts promising easy work and extravagant perks, many are tricked into travelling to Cambodia, Myanmar and Thailand.  Once they arrive, they are held prisoner and forced to work in online scam centres known as “fraud factories”.

https://www.bbc.com/news/world-asia-62792875

CANADA: LUXURY CARS SEIZED FROM 23-YEAR-OLD ‘CRYPTO KING’ AS INVESTORS TRY TO RECOUP MILLIONS

On 21 September, CBC reported that Tw2o McLarens, 2 BMWs and a Lamborghini make up just a few of the $2 million worth of assets seized from a 23-year-old from Whitby, Ont., as his investors try to recoup millions of dollars they handed over to the self-described “Crypto King”.  Creditors are working to unravel where at least $35 million provided to Pleterski and his company AP Private Equity Limited for cryptocurrency and foreign exchange investments ended up.

https://www.cbc.ca/news/canada/toronto/luxury-cars-seized-crypto-king-investors-try-recoup-millions-1.6583982

US: DoJ CLARIFIES AND REFINES ITS POLICIES FOR CORPORATE CRIMINAL ENFORCEMENT

On 22 September, a post from the Compliance and Enforcement blog from the Program on Corporate Compliance and Enforcement at the New York University School of Law reacted to a speech by Deputy Attorney General Lisa O Monaco detailing significant changes to the Department of Justice’s corporate prosecution policies.

https://wp.nyu.edu/compliance_enforcement/2022/09/21/doj-clarifies-and-refines-its-policies-for-corporate-criminal-enforcement/

INDONESIA’S ELECTRIC VEHICLE BATTERIES DREAM HAS A DIRTY NICKEL PROBLEM

A post from the Brookings Institution on 21 September says that the country is the world’s largest nickel miner, and is making moves to become a key player in the electric vehicle supply chain.  It says that for EV manufacturers struggling to source nickel in a tight market, Indonesia has become a key supplier in the past year.  However, its production is particularly carbon intensive and environmentally damaging, which creates an awkward challenge for EV manufacturers.

https://www.brookings.edu/blog/up-front/2022/09/21/indonesias-electric-vehicle-batteries-dream-has-a-dirty-nickel-problem

OFAC DETERMINATIONS TARGET RUSSIAN QUANTUM COMPUTING

On 22 September, the EU Sanctions blog reported on 2 Determinations issued by OFAC that allow for sanctions to be imposed on any person/entity determined to operate or have operated in the quantum computing sector of the Russian economy; and prohibit the export, reexport, sale or supply (directly or indirectly) from the US or by a US person/entity, wherever located, of quantum computing services to any person/entity located in Russia.

https://www.europeansanctions.com/2022/09/ofac-imposes-restrictions-on-russia-quantum-computing-sector-issues-2-gls/

SCIENTISTS AT AMERICA’S TOP NUCLEAR LAB WERE RECRUITED BY CHINA TO DESIGN MISSILES AND DRONES, REPORT SAYS

On 21 September, NBC News reported that at least 154 Chinese scientists who worked on government-sponsored research at the US foremost national security laboratory over the last 2 decades have been recruited to do scientific work in China — some of which helped advance military technology that threatens US national security — according to a new intelligence report it has obtained.  It is said to describe what it calls a systemic effort by the government of China to place Chinese scientists at Los Alamos National Laboratory, where nuclear weapons were first developed.  

https://www.nbcnews.com/news/world/scientists-americas-top-nuclear-lab-recruited-china-design-missiles-dr-rcna48834

MYSTERY DRONE BOAT WASHES UP NEAR HOME OF RUSSIA’S BLACK SEA FLEET

On 21 September, The Drive reported that Russian authorities on the occupied Crimean Peninsula claimed to have destroyed an unmanned surface vessel, or USV, near the city of Sevastopol.  Pictures showing what could be the maritime drone in question, which has a number of features that could point to being an uncrewed explosive-laden suicide boat, washed up on a beach have emerged on social media.

https://www.thedrive.com/the-war-zone/mystery-drone-boat-washes-up-near-home-of-russias-black-sea-fleet

UK SANCTIONS ON RUSSIA: INSURANCE AND OTHER SERVICES FOR RUSSIAN OIL SHIPMENTS

On 22 September, Field Fisher published a briefing saying that services affected would include technical assistance, financial services – notably including insurance and re-insurance – and brokering services. The measure will also prohibit the shipping of Russian oil by UK ships.  It is said that the UK is working closely with the US, EU and G7 partners to align their respective measures to reduce the compliance burden on industry.  The exact timing of the introduction of these measures is unclear and will depend on further progress in ongoing consultations between the G7 and oil importing countries on the operation of the price cap. But they are expected to come into force before the end of the year.

https://www.fieldfisher.com/en/insights/uk-sanctions-on-russia-insurance-and-other-services-for-russian-oil-shipments

SPANISH COURT OF AUDITORS CITES PANAMANIAN FUGITIVE WHO EMBEZZLED $5.1 MILLION

On 22 September, La Estrella de Panama reported that the Tribunal de Cuentas in Spain has cited a Panamanian accountant, Omar Antonio Guevara Barrios, who allegedly used his position to embezzle $ 5.1 million from la oficina técnica de cooperación de España en Panamá.  He has been a fugitive for more than 2 years.  Currently Guevara Barrios is described as one of the 100 most wanted Panamanians.

https://www.laestrella.com.pa/internacional/mundo/220922/tribunal-cuentas-espana-cita-panameno-profugo-desfalco-5-1-millones

 

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UK: FACTSHEET – ECONOMIC CRIME AND CORPORATE TRANSPARENCY (ECCT) BILL

)n 22 September, the Home Office blog carried a post containing this factsheet, saying that the UK  Government committed to bringing forward this further Bill to deliver a suite of wider-ranging reforms to tackle economic crime and improve the transparency of corporate entities.  The new Bill would involve –

  • Reforms to Companies House, including identity verification and broadening the powers of Companies House;  
  • Reforms to prevent the abuse of limited partnerships, including Scottish limited partnerships, to make them more transparent;
  • Additional powers to seize and recover suspected criminal cryptoassets;
  • Reforms to give businesses more confidence in sharing information to tackle money laundering and other economic crime, including by allowing certain businesses to directly share information more easily, that could be a third-party; and
  • New intelligence-gathering powers for law enforcement and removal of unnecessary burdens on business.

https://homeofficemedia.blog.gov.uk/2022/09/22/factsheet-economic-crime-and-corporate-transparency-ecct-bill/

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OFAC SANCTIONS IRAN’S MORALITY POLICE AND SENIOR SECURITY OFFICIALS FOR VIOLENCE AGAINST PROTESTERS AND THE DEATH OF MAHSA AMINI

On 22 September, the US Treasury announced that OFAC has designated Iran’s Morality Police for abuse and violence against Iranian women and the violation of the rights of peaceful Iranian protestors.  It is also targeting seven senior leaders of Iran’s security organizations: the Morality Police, Ministry of Intelligence and Security (MOIS), the Army’s Ground Forces, Basij Resistance Forces, and Law Enforcement Forces.  These officials oversee organisations that routinely employ violence to suppress peaceful protesters and members of Iranian civil society, political dissidents, women’s rights activists, and members of the Iranian Baha’i community.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220922

https://home.treasury.gov/news/press-releases/jy0969

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SOUTH AFRICA: STRATEGIC ORGANISED CRIME RISK ASSESSMENT

On 20 September, the Global Initiative Against Transnational Organised Crime says that a major study has resulted in this comprehensive Strategic Organized Crime Risk Assessment report that covers 15 interconnected illicit markets.

https://globalinitiative.net/wp-content/uploads/2022/09/GI-TOC-Strategic-Organized-Crime-Risk-Assessment-South-Africa.pdf

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EU TO CLAMP DOWN ON BOOMING LITIGATION FUNDING SECTOR

On 19 September, the Law Society Gazette reported that the EU is clamping down on what it sees as the worst elements of litigation funding, but UK funders say that those pushing for more regulation have failed to understand how the market works.  It warns that funders look set to fight any attempt by UK legislators to mirror a newly announced clampdown on the sector across the EU.  The EU is said to be planning to curb what it sees as the worst elements of litigation funding, with recommendations for a new system of regulation and a potential cap on fees that can be made on cases.  Other proposals include financial adequacy requirements and an obligation to pay adverse costs, and mandatory disclosure of any litigation funding agreement to all parties and the court.

https://www.lawgazette.co.uk/news-focus/news-focus-eu-to-clamp-down-on-booming-litigation-funding-sector/5113702.article

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AUSTRALIA: DYING MONEY LAUNDERING WHISTLEBLOWER SUED BY ClubsNSW

On 22 September, the Sydney Morning Herald reported on the case of a whistleblower who exposed lax money laundering compliance in New South Wales poker machine venues will spend the last months of his life defending a legal action brought by ClubsNSW.  Troy Stolz is the former head of AML/CFT at ClubsNSW.  ClubsNSW is also suing Stolz for disclosing confidential information, and has included in its action a claim against his wife, who will now be forced to continue fighting after he is gone.

https://www.smh.com.au/national/nsw/i-ve-nothing-to-lose-dying-whistleblower-sued-by-clubsnsw-20220921-p5bjsr.html

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EU U-TURNS ON GLOBAL TRANSFER RESTRICTIONS OF RUSSIAN COAL, FERTILISERS AND OTHER GOODS

On 21 September, Reed Smith reported on new FAQ on 19 September, which reverse the controversial expansion of restrictions imposed on certain coal, fertiliser and other Russian-origin goods on 10 August.  These FAQ clarify that restrictions on certain fertiliser and coal products (among others) do not include a ban on their transfer to third countries, and associated insurance and brokering arrangements.  It says that the EU has clarified that certain goods are now permitted to be transferred (including transported) to non-EU countries to mitigate food and energy insecurity.  The EU has also amended a FAQ to clarify that relevant services (such as financial assistance including brokering or insurance) tied to the transfer of the above-listed goods to third countries via EU operators or the EU territory are now permitted.

https://www.mondaq.com/uk/export-controls-trade-investment-sanctions/1232242/eu-u-turns-on-global-transfer-restrictions-of-russian-coal-fertilisers-and-other-goods-

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