On 25 January, FinCEN advised that it had issued an Alert to financial institutions regarding potential investments in the US commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and the entities through which they act. It lists red flags and typologies involving potential sanctions evasion in the commercial real estate sector. The new Alert builds on that from March 2022t identifying real estate, luxury goods, and other high value assets involving sanctions Russian and elites, is the fourth alert issued by FinCEN on potential Russian illicit financial activity since Russia’s invasion of Ukraine in February 2022.
Day: January 25, 2023
SURINAME: AML/CFT MUTUAL EVALUATION REPORT
On 25 January, the FATF-style regional body, CFATF, published this MER, adopted at a Plenary in November. The report analyses the level of compliance with the FATF 40 Recommendations, the level of effectiveness of Suriname’s AML/CFT system and provides recommendations on how the system could be strengthened. The on-site visit took place in February/March 2022.
AN INTERNATIONAL COUNTER-RANSOMWARE TASK FORCE ANNOUNCED AT A WHITE HOUSE EVENT IN NOVEMBER HAS OFFICIALLY COMMENCED OPERATIONS
On 23 January, The Record reported that the International Counter Ransomware Task Force’s (ICRTF) operations are intended to drive collaboration among a coalition of 36 member states and the EU to counter the spread and impact of ransomware which, despite typically being a criminal rather than state-based activity, has become a significant national security threat in recent years.
https://therecord.media/international-counter-ransomware-task-force-kicks-off/
FAQ: WHAT’S A PROXY? USING RELATIVES, SHELL COMPANIES, AND OTHER STAND-INS TO HIDE ILLICIT WEALTH
On 24 January, OCCRP published this FAQ saying that proxies are people that form a crucial part of a sophisticated secrecy industry that undermines the global financial system by letting dirty money flow undetected, unchecked, and uninterrupted around the world. The article sets out to provide everything you need to know about how sanctioned oligarchs, crime bosses, and corrupt politicians, often abetted by financial industry professionals, are able to rely on friends, family, and business associates to disguise and protect their interests.
FREEZING ORDERS, SEARCH AND IMAGING ORDERS AND DISCLOSURE ORDERS
On 25 January, this article from Fried Frank in its Distilling Disputes series provides an overview and insights into the pre-emptive remedies available in the English Courts. These are of particular relevance in the context of the pursuit of fraud claims, and this article highlights the toolbox of remedies available to potential claimants, including Freezing Orders, Disclosure Orders and Search and Imaging Orders, and other ancillary powers available to the English Courts.
https://www.friedfrank.com/uploads/documents/94ca1a1c782f7f75382149e36b06a301.pdf
US ISSUES SANCTIONS LICENCE TO TRINIDAD AND TOBAGO TO DEVELOP VENEZUELA OFFSHORE GAS FIELD
On 25 January, EurActiv reported that the US has granted a licence to Trinidad and Tobago to develop a major gas field located in Venezuelan territorial waters, marking a further easing of some sanctions on Venezuela.
THE COMMISSIONER OF POLICE OF THE CAYMAN ISLANDS: A SIGNIFICANT AMOUNT OF MONEY LAUNDERING IS LINKED TO GAMBLING
On 24 January, the Loop website reported that during a Select Committee hearing, the Commissioner of Police of the Cayman Islands, said that “illicit proceeds of illegal gambling in the Cayman Islands are somewhere between 30 million and 50 million Cayman dollars per annum” and that “illegal gambling is an organised criminal activity by criminal enterprise” with international links.
https://cayman.loopnews.com/content/byrne-significant-amount-money-laundering-linked-gambling
AML/CFT ASSESSMENT REPORT: ESTONIA MUST STEP UP LAW ENFORCEMENT AML EFFORTS
On 25 January, ERR reported the Council of Europe’s FATF-style regional body MONEYVAL encourages Estonia to further strengthen measures to combat money laundering and the financing of terrorism, among others by reinforcing the private sector’s capacities and performance as well as improving its law enforcement efforts in this field. The mutual evaluation report follows an on-site visit took place in April/May 2022.
https://www.fin.ee/en/news/moneyval-publishes-mutual-evaluation-report-estonia
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