COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – OCTOBER 31

Had a look around a newly refurbished hotel in the city centre today. Having avoided the Covid crisis, when much of the work was carried out, it opened a week ago – just in time for the disruption and cancelled bookings caused by the protests. As an illustration of the difficulties, the pleasant young guy showing us around, who only lived a little way from the hotel, was living in, to avoid the protests.

The Real News Network has published a quite balanced video report on the current protests – https://www.youtube.com/watch?v=eV6_LeIUtF8

Meanwhile, the Tribunal Electroal warns that it might not be practically or legally possible to hold the referendum announced by the President.

31 OCTOBER 2023

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FATF REPORT: CROWDFUNDING FOR TERRORISM FINANCING

On 31 October, FATF published this report saying that events around the world have demonstrated that crowdfunding can also be exploited for illegal purposes.  This includes terrorists and terrorist groups who can exploit fundraising platforms and crowdfunding activities on social media to seek funding for their terrorist cause from a global audience.  This FATF report analyses how terrorists misuse crowdfunding platforms; draws on experiences from the FATF Global Network, industry experts, academia and civil society and examines the challenges faced in detecting and preventing terrorist financing through the crowdfunding ecosphere. Challenges include the complexity of crowdfunding operations, the use of anonymising techniques, and lack of training and terrorist financing expertise within the crowdfunding industry to detect suspicious activity. The report highlights good practices, starting with the inclusion of crowdfunding in national terrorist financing risk assessments, outreach to the crowdfunding sector, and strong domestic and international information sharing mechanisms; and provides a list of risk indicators.

https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Crowdfunding-Terrorism-Financing.pdf.coredownload.inline.pdf

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UK: 1 EXISTING ENTRY ON RUSSIA SANCTIONS LIST AMENDED

On 31 October, HM Treasury advised that the existing entry for Veniamin Ivanovich KONDRATYEV, Governor of Krasnodar Territory, had been corrected.

https://assets.publishing.service.gov.uk/media/6540e4ca46532b000d67f5f5/Notice_Russia_311023.pdf

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UK ADDS 5 INDIVIDUALS AND 1 ENTITY TO BURMA/MYANMAR SANCTIONS LISTS

On 31 October, a Notice from HM Treasury advised that (in coordination with the US and Canada), the UK had added 6 names to its sanctions list.

https://assets.publishing.service.gov.uk/media/6540e45246532b001467f5e7/Notice_Myanmar_311023.pdf

https://www.europeansanctions.com/2023/10/us-uk-and-canada-designate-burmese-individuals-entities/

The Isle of Man mirrored the additions made by the UK –

https://www.gov.im/news/2023/oct/31/financial-sanctions-myanmar/

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OFAC PROHIBITS FINANCIAL SERVICES WITH MYANMA OIL AND GAS ENTERPRISE AND IMPOSES ADDITIONAL SANCTIONS ON BURMA MILITARY REGIME OFFICIALS AND SUPPORTERS

On 31 October, OFAC advised that it had published a new directive that prohibits certain financial services by US persons to or for the benefit of Myanma Oil and Gas Enterprise (MOGE). Additionally, OFAC designated 3 entities and 5 individuals connected to Burma’s military regime. These actions are occurring in alignment with designations by both the UK and Canada.

https://ofac.treasury.gov/faqs/added/2023-10-31

https://home.treasury.gov/news/press-releases/jy1856

https://ofac.treasury.gov/recent-actions/20231031

https://www.europeansanctions.com/2023/10/us-uk-and-canada-designate-burmese-individuals-entities/

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DIRTY MONEY AND THE DESTRUCTION OF THE AMAZON: UNCOVERING THE US ROLE IN ILLICIT FINANCIAL FLOWS FROM ENVIRONMENTAL CRIMES IN PERU AND COLOMBIA

A report from the FACT Coalition said that environmental crimes, seen as “low-risk, high-reward”, such as illegal mining and logging, are the third-largest type of criminal activity in the world, yielding as much as $281 billion in proceeds every year.  The report draws on interviews with local and regional activists, indigenous leaders, anti-money laundering experts, and government officials in Peru, Colombia, and the US to show how financial secrecy contributes to facilitating these crimes. The report lays out a comprehensive US reform agenda. 

https://thefactcoalition.org/wp-content/uploads/2023/10/Dirty-Money-and-the-Destruction-of-the-Amazon-Full.pdf

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COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – OCTOBER 30

Well, despite the President offering a referendum on the mining contract, and banning any further mining concessions, the protests continue. Today the teachers’ union has announced an “indefinite” strike – said to be until Law 406 of 20 October 20, which approved the new mining contract. This comes as, unsurprisingly, tourism unions are said to be concerned about the ‘devastating impact’ of protests and street closures on their sector. As I have said before, unless you are travelling around, or live in the interior (or Colón), you might be hard-pressed to really notice the protests. I thought today that the traffic on the city streets seemed rather busier than last week, but then I also noticed many businesses on Via Espania downtown had protective wooden boardings over their windows.

A friend is due to visit Panama next month, at the start and end of a Caribbean cruise, hoping to see the Canal, ride on the railway etc. If the protests persist, and with November likely to have heightened feelings, due the independence days’ that fall in the month, I imagine that the cruise line will not be offering or encouraging much in the way of shore excursions, particularly as it would be from the cruise terminal in Colón.

Meanwhile, it is reported that shares in the parent Canadian mining company experienced their worst fall in 26 years, being reduced in value by 20%, after President Cortizo’s announcement of a referendum.

In other, unsurprising if disappointing, news, the the Universal Postal Union has reported that Latin America has amongst the worst postal services in the world, with Panama scoring only 3 out of 10 and being said to have “some postal difficulties”, which could be resolved, provided that there is sufficient investment. We have a postbox (there are no domestic deliveries and one has to go to the post office to mail anything), but it is used little – anything urgent or of value goes by courier service. Mail from the UK can take 6-8 weeks to arrive (if it does arrive)… There is a good number of services that offer collection and onward delivery of things ordered from the US, your order from e-Bay, Amazon or whoever being despatched to an address in Florida and sent on from there. My experience of these has been highly satisfactory.

30 OCTOBER 2023

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NCA: SARS IN ACTION NEWSLETTER – MONEY MULE SPECIAL EDITION

The latest edition of the NCA newsletter focuses on money mules and includes a list of many of the common indicators that may suggest money mule activity in accounts, transactions and other financial activity.  It also says that mule networks are using social media more to recruit mules as they are able to anonymously reach a wide range of potential recruits.  Criminals can then operate internationally with minimal risk of their identity being discovered.

https://www.nationalcrimeagency.gov.uk/who-we-are/publications/675-sars-in-action-issue-22/file

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FATF CONFIRMS GIBRALTAR MEETS ACTION PLAN

On 27 October, a news release advised that the President of FATF had confirmed that Gibraltar has satisfied its action plan and is now programmed, subject to an on-site inspection, to be removed from the FATF Grey list at its next Plenary session scheduled to take place in February 2024.

https://www.gibraltar.gov.gi/press-releases/fatf-confirms-gibraltar-meets-action-plan-next-step-removal-from-grey-list-7372023-9333

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COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – OCTOBER 29

The Chamber of Commerce, Industries, Agriculture of Panama (CCIAP) has said that the discontent of the population goes beyond the mining issue, as it covers claims against corruption. It may be true about the underlying triggers of the protests, but, if correct, this could cause greater problems in resolving the situation.

Meanwhile, it is reported that Panamanians living around the world, including Barcelona, New York, London, Paris, Dublin and Toronto, had also protested. one photo showed a quite large group people outside the embassy in London, which I found a little surprising, as when I visited there seemed such a shortage of Panamanians available that I was invited to the independence day party (and managed to then mistake the Ambassador for a security guard…).

So far the Canal has been unaffected, but it is reported that the Union of Pilots of the Panama Canal have urged the Supreme Court of Justice to give “priority” to the claims of unconstitutionality against the contract.

29 OCTOBER 2023

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