THINGS YOU MAY HAVE MISSED – NOVEMBER 26

As before, the apology for any oversights, duplications etc etc…at least I saw flying fish today!

26 November 2022

CENTRAL BANK OF NIGERIA (CBN) NEW GUIDELINES FOR THE LICENSING OF BANKS AND OTHER FINANCIAL INSTITUTIONS ON IMPLEMENTATION AML/CFT/ CPF REGULATIONS

On 26 November, the New Telegraph and others reported on what the new guidelines are for and what they cover.

https://www.newtelegraphng.com/cbn-releases-anti-money-laundering-guidelines-for-licensing-of-banks-others/

US: SOUTH KOREA’S SHINHAN FINANCIAL ORDERED TO IMPROVE AML OVERSIGHT

 On 25 November, the Wall Street Journal reported that the financial group has agreed to bolster the oversight of its AML program as part of a settlement with the Federal Deposit Insurance Corp (FDIC).  The FDIC in 2021 found deficiencies and weaknesses, according to an FDIC order issued in October.

https://www.wsj.com/articles/shinhan-financials-u-s-unit-ordered-to-beef-up-money-laundering-oversight-11669417664

US: CISA, NSA, AND ODNI RELEASE GUIDANCE FOR CUSTOMERS ON SECURING THE SOFTWARE SUPPLY CHAIN

On 18 November, Homeland Security Today reported that the 3 agencies had published the third of a 3-part series on securing the software supply chain.  It and the accompanying factsheet provides recommended practices for software customers to ensure the integrity and security of software during the procuring and deployment phases.  The previous Parts were for developers and customers.

https://www.cisa.gov/uscert/ncas/current-activity/2022/11/17/cisa-nsa-and-odni-release-guidance-customers-securing-software

https://www.linkedin.com/posts/pietro-odorisio-30ab009a_criminals-launder-illegaactivities-activity-7002290060003835904-8pWr

https://twitter.com/conflictarm

DISSECTING IRANIAN DRONES EMPLOYED BY RUSSIA IN UKRAINE

Conflict Arms Research has issued a report saying that its investigators physically documented a number of UAV in Ukraine in November 2022 and are conducting a detailed dissection of their design characteristics and key components, comparing them with CAR’s previous documentations of similar technology used in conflicts in the Middle East.  It confirms that the UAV originate in Iran, and that they include many recently manufactured components produced by companies mostly based in the US, which raises important questions regarding the effectiveness of existing sanction regimes.

https://storymaps.arcgis.com/stories/7a394153c87947d8a602c3927609f572

EMERGING MISSILE TRENDS TO WATCH OUT FOR – ANALYSIS

On 26 November, Eurasia Review provided this analysis, saying that traditionally, much of the focus on missiles has been on those capable of delivery of WMD.  But new missile trends are emerging. Modern missiles have registered huge advances in speed, range, navigation, use of advanced materials, and endurance. Earlier, when accuracy was not easy to achieve, missiles were seen to have a strategic effect only when carrying a nuclear warhead.  Not anymore. 

https://www.eurasiareview.com/26112022-emerging-missile-trends-to-watch-out-for-analysis/

INTEGRITY AND COMPLIANCE TASKFORCE REPORT CONTAINING SEVERAL POLICY RECOMMENDATIONS ON INTEGRITY AND COMPLIANCE

On 22 November, the Global Coalition to Fight Financial Crime published this report which provides several recommendations such as promoting sustainable governance while supporting ESG initiatives by optimising sustainable governance compliance disclosures and monitoring.  Other main recommendation areas are fostering Collective Action to be better protected against integrity risks, fostering agility in counteract measures to combat money laundering and strengthening governance to mitigate cybercrime risks.  It says that these recommendations should aide business in notably supporting the UN targets in achieving the Sustainable Development Goals (SDG) and contributing to the achievement of the 3 priorities of the Indonesian G20 Presidency, namely global health architecture, digital transformation, and sustainable energy transition.

https://www.gcffc.org/wp-content/uploads/2022/11/Integrity-and-Compliance-Taskforce-Paper.pdf

OFAC: VENEZUELA-RELATED GENERAL LICENSES AND FAQ

On 26 November, OFAC advised the issue of 2 General Licenses and 2 related FAQ.  The General Licenses are for authorising certain transactions related to Chevron Corporation’s joint ventures in Venezuela and authorising transactions involving Petróleos de Venezuela, SA (PdVSA) necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities.

https://home.treasury.gov/system/files/126/venezuela_gl41.pdf

https://home.treasury.gov/system/files/126/venezuela_gl8k.pdf

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-11-26

US: CISA, NSA, AND ODNI RELEASE GUIDANCE FOR CUSTOMERS ON SECURING THE SOFTWARE SUPPLY CHAIN

On 18 November, Homeland Security Today reported that the 3 agencies had published the third of a 3-part series on securing the software supply chain.  It and the accompanying factsheet provides recommended practices for software customers to ensure the integrity and security of software during the procuring and deployment phases.  The previous Parts were for developers and customers.

https://www.cisa.gov/uscert/ncas/current-activity/2022/11/17/cisa-nsa-and-odni-release-guidance-customers-securing-software

https://www.linkedin.com/posts/pietro-odorisio-30ab009a_criminals-launder-illegaactivities-activity-7002290060003835904-8pWr

DISSECTING IRANIAN DRONES EMPLOYED BY RUSSIA IN UKRAINE

Conflict Arms Research has issued a report saying that its investigators physically documented a number of UAV in Ukraine in November 2022 and are conducting a detailed dissection of their design characteristics and key components, comparing them with CAR’s previous documentations of similar technology used in conflicts in the Middle East.  It confirms that the UAV originate in Iran, and that they include many recently manufactured components produced by companies mostly based in the US, which raises important questions regarding the effectiveness of existing sanction regimes.

https://storymaps.arcgis.com/stories/7a394153c87947d8a602c3927609f572

https://twitter.com/conflictarm

THINGS YOU MAY HAVE MISSED – NOVEMBER 25

Apologies for any duplication, oversights and so on…but greetings from Colombia!

Meanwhile, back in Panama it has been announced that, with the rise in Covid cases, face masks are to be made mandatory once more in all public and private schools.

25 NOVEMBER 2022

TURKISH GOVERNMENT CALLS OUT “DEMEANING” HALKBANK PROSECUTION

On 25 November, Global Investigation Review reported that the Turkish government said the DoJ prosecution of Halkbank has strained political ties between the 2 countries, describing the US criminal case as “a demeaning move against Türkiye’s dignity”.

https://globalinvestigationsreview.com/just-sanctions/article/turkish-government-calls-out-demeaning-halkbank-prosecution

Q&A: RUSSIAN EU SANCTIONS AND SHIPPING INSURANCE BAN

On 23 November, Vortexa issued this Q&A that attempts to shed light on 10 key questions and distil the determinants that could influence the new environment of Russian operations in shipping and trading.

https://www.vortexa.com/insights/freight/qa-russian-eu-sanctions-and-shipping-insurance-ban

UK: COURT OF APPEAL ON RUSSIA SANCTIONS AND A FORCE MAJEURE CLAUSE IN A SHIPPING CONTRACT

On 25 November, the EU Sanctions blog reported on a case where a shipowner sought to rely on the clause to suspend its obligation to load a cargo when its parent company became subject to US sanctions in 2018 so there were difficulties making payment in US dollars which was contractually required.

https://www.europeansanctions.com/2022/11/uk-court-of-appeal-judgment-on-us-sanctions-force-majeure-clause-mur-shipping/

BELGIUM AND THE RUSSIAN DIAMONDS

https://www.statista.com/chart/28815/import-value-of-diamonds-from-russia-to-belgium

THE DARK SIDE OF FOOTBALL: AFRICAN PLAYERS SMUGGLED FOR CASH

On 25 November, All Africa and others reported that many players from West and Central Africa are increasingly embarking on dangerous journeys through North Africa to Europe, where they are sold lofty dreams of superstardom. In the quest to become the next Sadio Mané or Didier Drogba, the young players, usually naïve teenagers, are subjected to appalling conditions while trying to illegally cross the Mediterranean Sea.

https://allafrica.com/stories/202211250005.html

CYPRUS: AML/CFT ASSESSMENT FOLLOW-UP REPORT

On 25 November, MONEYVAL released its second enhanced follow-up report on Cyprus, saying that it has made some progress in improving its level of compliance with FATF standards.  The report examines a range of legislative, regulatory and institutional measures taken by the Cypriot authorities concerning risk assessment and monitoring of its non-profit sector, the powers available to investigative authorities to intercept communications and apply controlled delivery techniques to cash and bearer negotiable instruments, as well as virtual assets related services and supervision thereof.

https://www.coe.int/en/web/human-rights-rule-of-law/-/moneyval-report-on-cyprus-improvements-on-measures-to-combat-money-laundering-and-the-financing-of-terrorism

https://rm.coe.int/moneyval-2022-17-fur-cy/1680a92582

EMBASSIES AND ELEPHANTS: NORTH KOREA’S INVOLVEMENT IN THE ILLEGAL WILDLIFE TRADE

On 25 November, RUSI published an Occasional Paper which examines North Korea’s involvement in aspects of the illegal wildlife trade (IWT), which it says has been recognised, but not accorded similar levels of scholarly attention. T his paper reviews the evidence on the regime’s engagement in the IWT.

https://rusi.org/explore-our-research/publications/occasional-papers/embassies-and-elephants-north-koreas-involvement-iwt 

UK: PSEUDONYMOUS CLAIMANT DEBARRED FROM PROCEEDINGS

On 25 November, the Law Society Gazette reported that the High Court has ruled that an operator and publisher of a website – the operator of the bitcoin.org website, which is believed to be based in the US – is not entitled to participate in court proceedings under a pseudonym – even with legal representation.  The case was a copyright infringement action involving Dr Craig Wright, an Australian computer scientist resident in Britain who has brought a series of legal actions over his claim to be the inventor of the bitcoin digital currency.

https://www.lawgazette.co.uk/law/pseudonymous-claimant-debarred-from-proceedings/5114415.article

UK NOTICE TO IMPORTERS 2953: RUSSIA IMPORT SANCTIONS

On 25 November, the Department for International Trade published Notice to Importers 2953 on the import prohibitions in force under the Russia Sanctions Regulations 2019, as amended, saying that it should be read alongside the statutory guidance.  First issued in March, it has been amended to reflect the change to the entry into force date of the UK ban on Russian oil and oil products to 5 December from the original date of 31 December.

https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions

NCA SECURES £50 MILLION IDENTIFIED BY BARCLAYS AS THE PROCEEDS OF CRIME

A news release from the NCA on 25 November advised that it has obtained a ruling from the High Court that allows Barclays to hand over criminal funds to the NCA in a first-of-its-kind civil recovery case.  The money was identified by the bank in a number of accounts and transferred to secure holding accounts.

https://www.nationalcrimeagency.gov.uk/news/nca-secures-50m-identified-by-barclays-as-the-proceeds-of-crime

FAQ: WHAT IS CORRESPONDENT BANKING?

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

GLOBAL CYBER REGULATIONS: WHAT IS KNOWN AND PREPARING FOR THE REST

On 24 November, Control Risks produced an article that asks what challenges do the changes create for organisations?  And what do they need to be aware of to stay ahead and thrive in this increasingly complex environment?  Proactively understanding the risks you face and drivers of regulation has never been more important. 

https://www.controlrisks.com/our-thinking/insights/global-cyber-regulations-what-we-know-and-preparing-for-what-we-dont

COCAINE BROKERS: THE ‘NDRANGHETA IN SOUTH AMERICA

On 23 November, an article from Insight Crime says that Italy’s ’Ndrangheta Mafia has capitalised on South America’s cocaine boom to secure its role as one of the most influential drug trafficking groups in the world.  Based in the southern Italian region of Calabria, this group has grown to become a multibillion-dollar enterprise with a presence that spans the globe.  In a 3-part series, InSight Crime explores the ‘Ndrangheta’s role in South America’s cocaine trade.

https://insightcrime.org/investigations/cocaine-brokers-ndrangheta-south-america/

LAO AUTHORITIES SEEM POWERLESS TO STOP CRIME IN GOLDEN TRIANGLE ECONOMIC ZONE

On 25 November, an article from RFA on the Golden Triangle Special Economic Zone in northern Laos says that it is a haven for criminal activities including prostitution, scamming and drug trafficking, but Lao authorities are essentially powerless to stop it.

https://www.rfa.org/english/news/laos/golden-triangle-11252022131629.html

EU: TRADE-RELATED POLICY OPTIONS OF A BAN ON FORCED LABOUR PRODUCTS

On 25 November, a briefing from the EU Parliament Research Service provided an in-depth analysis which explores how EU trade policy tools can effectively tackle the import and circulation of forced labour products in the European single market in order to help implement the Commission’s decent work worldwide initiative.  The report compares the option of an EU import ban on forced labour goods to the option of prohibiting the marketing of such products, in light of the Commission’s proposal for a Regulation on prohibiting products made with forced labour on the EU market published on 14 September.  The paper also analyses the likely economic and social impact of the proposed measures (in the EU and abroad), as well as the legal feasibility of these tools.

https://www.europarl.europa.eu/RegData/etudes/IDAN/2022/702570/EXPO_IDA(2022)702570_EN.pdf

TAXATION OF THE INFORMAL ECONOMY IN THE EU

On 25 November, a briefing paper from the EU Parliament Research Service is concerned with a study that provides estimates of the size and development of the shadow economy in the EU up to 2022 and analyses the main factors that drive economic agents to enter the shadow economy activities (Part 1).  Moreover, the study reviews and elaborates on the main driving forces and the policy measures implemented to reduce the shadow economy in 6 EU countries (Germany, Austria, Italy, Denmark, Romania and Greece) (Part 2).

https://www.europarl.europa.eu/RegData/etudes/STUD/2022/734007/IPOL_STU(2022)734007_EN.pdf

GERMANY: HEIST OF ANCIENT CELTIC TREASURE TROVE THE WORK OF ORGANISED CRIME

On 24 November, an article from OCCRP reported that nearly 500 golden coins produced by an ancient Celtic culture in what is now southern Germany were stolen from the Celtic and Roman Museum in the Bavarian town of Manching, Germany; and there’s a suspicion that it involves organised crime.

https://www.occrp.org/en/daily/17080-germany-heist-of-ancient-celtic-treasure-trove-the-work-of-organized-crime

INTERNATIONAL SANCTIONS SEEK TO WEAKEN HAITI’S PATRONAGE SYSTEM BETWEEN POLITICIANS AND GANGS

On 24 November, an article from Insight Crime says that a raft of sanctions from the United States and Canada targeting senior Haitian politicians threatens to pull back the curtain on the country’s long history of patronage between political parties and violent gangs.

https://insightcrime.org/news/international-sanctions-seek-to-weaken-haitis-patronage-system-between-politicians-gangs/

WHY CASINOS ARE STILL FAILING TO CRACK DOWN ON MONEY LAUNDERING AND HOW THEY CAN TACKLE IT

On 24 November, a blog post from Finextra says that failings of the big gambling players to clamp down against money laundering not only contributes to the proliferation of criminal activity such as human trafficking and illicit arms dealings, but it also highlights how casinos now act as a platform for modern slavery. 

https://www.finextra.com/blogposting/23284/why-casinos-are-still-failing-to-crack-down-on-money-laundering-and-how-they-can-tackle-it

SLOVAKIA CENTRAL BANK GOVERNOR KAZIMIR FACES RENEWED BRIBERY CHARGES

On 24 November, the BBC says that the head of Slovakia’s central bank, Peter Kazimir, is facing bribery charges for a second time.  Prosecutors had earlier dropped charges over the alleged bribe, which goes back to when he was a finance minister. He has condemned the allegation and denies any wrongdoing.

https://www.bbc.com/news/world-europe-63744283

SANCTIONED CROATIAN BUSINESSMAN SECRETLY BANKROLLED CROATIAN TOURIST DEVELOPER

On 24 November, OCCRP reported claims that Mihajlo Perenčević, a Croatian businessman sanctioned due to his important strategic business in Russia, has extensive financial ties to a major Croatian tourism developer with a portfolio of property and assets worth some €200 million.

https://www.occrp.org/en/daily/17075-sanctioned-croatian-businessman-secretly-bankrolled-croatian-tourist-developer

HUMANITARIAN EXEMPTIONS IN UNILATERAL SANCTIONS REGIMES SAID TO BE INEFFECTIVE AND INEFFICIENT

On 23 November, an article from the UN Office for the Human Rights High Commissioner said that UN human rights experts have called on the international community to pay heed to the ineffectiveness, structural weaknesses and superficial character of the exemptions in relation to the multifaceted negative impact of unilateral coercive measures on the lives and rights of millions of people.

https://www.ohchr.org/en/statements/2022/11/humanitarian-exemptions-unilateral-sanctions-regimes-ineffective-and-inefficient

CYPRUS: AML/CFT ASSESSMENT FOLLOW-UP REPORT

On 25 November, MONEYVAL released its second enhanced follow-up report on Cyprus, saying that it has made some progress in improving its level of compliance with FATF standards.  The report examines a range of legislative, regulatory and institutional measures taken by the Cypriot authorities concerning risk assessment and monitoring of its non-profit sector, the powers available to investigative authorities to intercept communications and apply controlled delivery techniques to cash and bearer negotiable instruments, as well as virtual assets related services and supervision thereof.

https://www.coe.int/en/web/human-rights-rule-of-law/-/moneyval-report-on-cyprus-improvements-on-measures-to-combat-money-laundering-and-the-financing-of-terrorism

https://rm.coe.int/moneyval-2022-17-fur-cy/1680a92582