COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – FEBRUARY 27

Panama America reported today that former President Martinelli leads in a recnt Gallup poll, as he is seeking re-election as President in 2024 (in Panama, Presidents are limited to one 5-year term at a time). The result is despite all his well-known past, and continuing, travails… he is also said to have formalised his Presidential candidacy, on behalf of the Realizing Goals (RM) party. He was President in 2009-14 (I still have the Martinelli for President T-shirt I picked up at the time of the 2009 campaign – but don’t wear it outside of the house now, wearing it inside as, I maintain, an ironic genture…).

Further to the news about problems with the transporting of migrants (the bus service used has been suspended after a fatal crash and a non-fatal fire), it is reported that so far in 2023, 45,727 migrants have passed through Panama bound for the US, according to the Ministry of Public Security (Minseg). Of these, 16,113 were Haitian, 11,70 Ecuadorian and 7,875 Venezuelan.

27 FEBRUARY 2023

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OFAC: GUIDANCE RELATED TO THE PROVISION OF HUMANITARIAN ASSISTANCE BY NOT-FOR-PROFIT NGO

On 27 February, OFAC issued a humanitarian assistance fact sheet, which supplements its 2014 guidance on the same topic.  The fact sheet seeks to provide guidance on the reach of economic sanctions for persons involved in the conduct of humanitarian-related activities, including: the US government; international organisations and entities; non-governmental organisations (NGO); persons involved in the provision of food, other agricultural commodities, medicine, and medical devices; and financial institutions and other service providers who support or facilitate transactions for such persons.

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

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

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FINCEN ALERT ON NATIONWIDE SURGE IN MAIL THEFT-RELATED CHECK (CHEQUE) FRAUD SCHEMES TARGETING THE US MAIL

On 27 February, an Alert from FinCEN on mail theft-related check (cheque) fraud, which generally pertains to the fraudulent negotiation of cheques stolen from the US Mail.  It says this type of fraud is the largest source of illicit proceeds in the US and represents one of the most significant money laundering threats to the US, as highlighted in the US Treasury’s most recent national money laundering risk assessment.  The information contained in the Alert is derived from FinCEN’s analysis of BSA data, open-source reporting, and information provided by law enforcement partners.

https://www.fincen.gov/sites/default/files/shared/FinCEN%20Alert%20Mail%20Theft-Related%20Check%20Fraud%20FINAL%20508.pdf

https://www.fincen.gov/news/news-releases/fincen-alert-nationwide-surge-mail-theft-related-check-fraud-schemes-targeting

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EU TERRORISM SANCTIONS UPDATED AND RENWED

EU Regulation 2023/420/EU reissues the list of those subject to sanctions under Regulation (EC) No 2580/2001 following a review.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2023.061.01.0037.01.ENG&toc=OJ%3AL%3A2023%3A061%3ATOC

https://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=uriserv:OJ.L_.2023.061.01.0058.01.ENG&toc=OJ:L:2023:061:TOC

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EU AMENDS 23 ENTRIES ON BELARUS SANCTIONS LIST

EU Regulation 2023/419/EU amended entries relating to 21 natural and 2 legal persons included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EC) No 765/2006 are amended.

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2023.061.01.0020.01.ENG&toc=OJ%3AL%3A2023%3A061%3ATOC

https://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=uriserv:OJ.L_.2023.061.01.0041.01.ENG&toc=OJ:L:2023:061:TOC

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FATF: MONEY LAUNDERING AND TERRORIST FINANCING IN THE ART AND ANTIQUITIES MARKET

On 27 February, FATF issued this report which includes a list of risk indicators that can help public and private sector entities identify suspicious activities in the art and antiquities markets highlights the importance of rapidly identifying and tracing cultural objects involved in money laundering or terrorist financing.  The report includes some good practices that countries have taken to address the challenges they face, including the establishment of specialised units and access to relevant databases and cooperation with experts and archaeologists to help identify, trace, investigate and repatriate cultural objects.

https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-Terrorist-Financing-Art-Antiquities-Market.pdf.coredownload.pdf

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