On 25 November, OCCRP published this article saying that that criminals, sanctions dodgers, and corrupt politicians are also able to filter billions in tainted cash through the conventional banking system using nothing more than standard money transfers.
https://www.occrp.org/en/troikalaundromat/faq-what-is-correspondent-banking
On 22 November, OFAC advised it had issued –
https://home.treasury.gov/system/files/126/determination_11222022_eo14071.pdf
https://home.treasury.gov/system/files/126/price_cap_policy_guidance_11222022.pdf
https://home.treasury.gov/system/files/126/russia_gl55.pdf
https://home.treasury.gov/system/files/126/russia_gl56.pdf
On 22 November, a release on Mondo Visione advised that the European Banking Authority (EBA) has published its final Guidelines on the use of remote customer onboarding solutions. These Guidelines set out the steps credit and financial institutions should take to ensure safe and effective remote customer onboarding practices in line with applicable AML/CFT legislation and the EU’s data protection framework. The Guidelines apply to all credit and financial institutions that are within the scope of the Anti-money Laundering Directive (AMLD).
A news release from the EU Court of Justice of the EU on 22 November advised about a Luxembourg case involving its Register of Beneficial Ownership where some information is accessible to the general public, in particular through the Internet. The Court has held that due to the Charter of Fundamental Rights of the EU the general public’s access to information on beneficial ownership constitutes a serious interference with the fundamental rights to respect for private life and to the protection of personal data.
https://curia.europa.eu/jcms/upload/docs/application/pdf/2022-11/cp220188en.pdf
On 21 November, the Department for Business, Energy & Industrial Strategy issued guidance which sets out the implementation of the Russian oil import ban and how businesses should navigate the prohibitions and requirements introduced in the UK’s sanctions legislation.
https://www.gov.uk/government/publications/uk-ban-on-russian-oil-and-oil-products
On 15 November, a report from Human Rights First says that leading human rights organisations have issued the first-ever multilateral report calling for the more effective use of the human rights and anti-corruption accountability tools. A new report details many of the current gaps in the implementation of these sanctions programs, which can undermine their impact and effectiveness.
A report from the Global Initiative Against Transnational Organised Crime on 18 November says that artisanal and small-scale gold mining in eastern and southern Africa provides economic opportunities to a wide range of actors that cuts across the formal, informal and illicit spheres. It can involve everything from highly vulnerable individuals panning for gold on a subsistence basis to small-scale, semi-industrial operations illegally generating millions of dollars’ worth of gold. It is intended to be a tool for those who wish to intervene or engage with the ASGM sector and illicit gold markets, including policymakers, government agents, development interventions, civil society, and businesses. Although this policy guidance is designed for eastern and southern Africa, it can be adapted for other regions.
On 18 November, OFAC advised that it had sanctioned 1 Russian national, Dmitry Kudryakov, and 1 Belarusian national, Iryna Litviniuk, for their role in exploiting the Guatemalan mining sector, as well as three associated entities connected with their corruption schemes. Kudryakov and Litviniuk are designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of corruption, including the misappropriation of state assets, corruption related to government contracts, or the extraction of natural resources, or bribery.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20221118
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