COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MARCH 28

Looks like I was lucky with my US visa – not only did I get my appointment and visa in only a few weeks, having applied in February (and not the average 270 weeks that has been quoted!), but the fee for a visa is to go up in May, from $160 to $185. Collected the passport with the new visa in today and, if I was still doing immigration work then the photo on the visa would be enough to have me banned from entry (why are passport and visa photos so awful?).

A new survey says that men here say they want to earn at least $1,058 a month, while women’s say that they require $1,019 on average. It also says that technology and systems positions are those with the highest salary expectation, with mechanical engineering having the average salary required by applicants being $1,146.

https://www.martesfinanciero.com/panel-principal-panama/cuanto-quieren-ganar-los-panamenos-de-salario-mensual/

28 MARCH 2023

https://www.buymeacoffee.com/KoIvM842y

SEA SHELLS: DEVELOPING BENEFICIAL OWNERSHIP TRANSPARENCY IN THE FISHING INDUSTRY

C4ADS has published this report which says that behind the 4 million commercial fishing vessels in the global fleet lies a complex onshore network of shell companies, frequently concealing the true beneficiaries of this industry.  It says that recent policy actions have shifted toward holding accountable ultimate beneficial owners (UBO), instead of, or in addition to, individual vessels for IUU fishing: the individuals who are responsible for and receive the greatest financial benefit from fishing operations.  The report explores how ultimate beneficial ownership information in the fishing industry is an important tool to address IUU fishing, improve transparency, and build accountability. It conducted the first full mapping of UBO for vessels flagged to Spain and Ecuador and map the trawler and purse seine fleets of the UK and Indonesia, respectively.  This analysis reveals barriers to investigating UBO and identifies opportunities to standardise and improve reporting requirements.  As an example, it provides snapshots, including one for the UK.

https://c4ads.org/wp-content/uploads/2023/03/SeaShellsBrief.pdf

https://www.buymeacoffee.com/KoIvM842y

UK SETS UP FAKE BOOTER SITES TO MUDDY DDoS MARKET

On 28 March, Krebs on security reported that the NCA has been busy setting up phony DDoS-for-hire websites that seek to collect information on users, remind them that launching DDoS attacks is illegal, and generally increase the level of paranoia for people looking to hire such services.  The websites, which have so far been accessed by several thousand people, have been created to look like they offer the tools and services that enable cyber criminals to execute these attacks.  Instead, users based in the UK will be contacted by the NCA or police and warned about engaging in cybercrime, and information relating to those based overseas is being passed to international law enforcement.

https://krebsonsecurity.com/2023/03/uk-sets-up-fake-booter-sites-to-muddy-ddos-market/

https://www.buymeacoffee.com/KoIvM842y

UK: DRAFT CODES OF PRACTICE ISSUED UNDER POCA 2002 AND THE TERRORISM ACT 2000

On 28 March, the Home Office advised that 3 existing codes of practice need to be updated and one new code of practice made to reflect possible changes made to the Proceeds of Crime Act 2002 (POCA) by the Economic Crime and Corporate Transparency Bill (ECCT Bill).  Consultation on the changes lasts until 20 June.

https://www.gov.uk/government/consultations/draft-codes-of-practice-issued-under-poca-2002-and-the-terrorism-act-2000

https://www.buymeacoffee.com/KoIvM842y

FRENCH AUTHORITIES SEARCH OFFICES OF SEVERAL LARGE BANKS ON SUSPICION OF MONEY LAUNDERING AND FISCAL FRAUD

On 28 March, France 24 reported that authorities had searched offices of several large banks, including Societe Generale, BNP Paribas and HSBC on the suspicion of money laundering and fiscal fraud.  A spokesperson said the probe was linked to dividend stripping and that were ongoing linked to so-called “cum-cum” practices, through which wealthy clients sought to evade taxes on dividends through complex legal structures.

https://www.france24.com/en/europe/20230328-french-financial-prosecutors-search-bank-offices-over-dividend-stripping

https://www.buymeacoffee.com/KoIvM842y

ISLE OF MAN AND UK CONFIRM REMOVAL OF INDIVIDUAL FROM IRAQ SANCTIONS LIST

On 28 March, both the Isle of Man and the UK confirmed that AMIR HAMUDI HASSAN AL-SA’DI had been removed from sanctions lists following the decision of the relevant UN Sanctions Committee.

https://www.gov.im/news/2023/mar/28/financial-sanctions-iraq/

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1146390/Notice_Iraq_280323.pdf

UK: LANDMARK SANCTIONS CHALLENGE FAILS

On 24 March, an article from MacFarlanes LLP in Ireland reported that a landmark challenge to a sanctions designation in the English courts has failed, but the case offers an interesting guide to both how sanctions are implemented in the UK and how they can be removed.  The judgment offers key insights into the exercise courts will undertake when considering a challenge to designation; and the case stands as a unique reference point for sanctions designation challenges in the UK and will inform sanctioned parties of the approach the judiciary is expected to take going forward.

https://www.macfarlanes.com/what-we-think/in-depth/2023/what-will-it-take-to-de-designate-a-landmark-sanctions-challenge-fails/

https://www.buymeacoffee.com/KoIvM842y

UK AND OFAC SANCTION SYRIAN REGIME AND LEBANESE ACTORS INVOLVED IN ILLICIT DRUG PRODUCTION AND TRAFFICKING 

On 28 March, OFAC announced that it had taken action in coordination with counterparts in the UK to designate key individuals supporting the regime of Syrian President Bashar al-Assad and the production or export of Captagon, a dangerous amphetamine.  The trade in Captagon is estimated to have become a billion-dollar illicit enterprise.  Those designated include the so-called “King of Captogon”, Hassan Muhammad Daqqou, a Lebanese-Syrian dual national.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20230328

https://home.treasury.gov/news/press-releases/jy1369

UK ALSO ADDS 11 INDIVIDUALS TO ITS SYRIAN SANCTIONS LISTS

On 28 March, HM Treasury issued a Notice listing 11 Lebanese and Syrian nationals that were being added to the Syria sanctions lists.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1146403/Notice_Syria_280323.pdf

https://www.gov.uk/government/news/tackling-the-illicit-drug-trade-fuelling-assads-war-machine

https://www.buymeacoffee.com/KoIvM842y

WILLIAM HILL GROUP TO PAY A RECORD £19.2 MILLION OVER A SERIES OF SOCIAL RESPONSIBILITY AND AML FAILURES

On 28 March, iGB reported that gambling operator WHG International, which runs Williamhill.com, will pay £12.5 million to the UK Gambling Commission, while Mr Green, operator of Mrgreen.com will pay £3.7 million. The William Hill Organization, which runs 1,344 land-based gambling premises across Britain, will also pay £3.0 million.  Specific failures noted included insufficient controls in place to protect new customers, and it failed to identify certain customers at risk of experiencing gambling-related harm and failing to carry out checks at an early stage in the customer’s journey.  From an AML perspective, among other things, the Commission noted that players were allowed to deposit large amounts without conducting appropriate checks.

https://igamingbusiness.com/legal-compliance/william-hill-group-to-pay-record-19-2m-over-failures

https://www.buymeacoffee.com/KoIvM842y