The International Enforcement Law Reporter

The International Enforcement Law Reporter is a monthly print and online journal covering news and trends in international enforcement law.

Since September 1985, the International Enforcement Law Reporter has analyzed the premier developments in both the substantive and procedural aspects of international enforcement law. Read by practitioners, academics, and politicians, the IELR is a valuable guide to the difficult and dynamic field of international law.

Two batches of Ukrainian artifacts recovered after attempted trafficking to Spain and the U.S.

Friday, November 10, 2023
Author: 
Jack Crovitz
Volume: 
39
Issue: 
12
Abstract: 

On October 23, 2023, the National Police of Spain and the Security Service of Ukraine announced that officers had seized gold artifacts belonging to Ukraine, worth more than €60 million ($64 million), in Madrid. Three Spaniards and two Ukrainians, accused of illegally trafficking these objects out of Ukraine in May 2016, have been arrested for money laundering. The 11 pieces were displayed in Kyiv museums in 2009-2013 as millennia-old artifacts from ancient Greco-Scythian culture, although recently some experts have suggested that the pieces are fakes.

Georgia Extradites Serbian Leader of $70M Cryptocurrency and Binary Options Fraud to the U.S.

Friday, November 10, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
12
Abstract: 

On November 3, 2023, the United States Department of Justice announced that Georgian authorities extradited Kristijan Krstic, 48, a Serbian national to the U.S., where he is charged with two separate federal indictments in the Northern District of Texas and the Eastern District of New York for his alleged participation in cryptocurrency and binary options schemes.

U.S. Treasury Imposes New Round of Sanctions on Hamas and FinCEN Issues An Alert on Hamas

Friday, November 3, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
12
Abstract: 

On October 27, 2023, the U.S. Department of the Treasury’s Office of Financial Assets Control (OFAC) imposed a second round of sanctions on key Hamas-linked officials and financial networks.  The sanctions follow the October 7 attacks on Israel.  As set forth in OFAC’s press release and designations, the new round of sanctions targets additional assets in Hamas’s investment portfolio and individuals who are facilitating sanctions evasion by Hamas-affiliated companies.

U.S. Brings Civil Forfeiture Complaint against $300M Superyacht of Russian Oligarch

Friday, November 3, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
12
Abstract: 

On October 23, 2023, the United Staes Department of Justice brought a civil forfeiture complaint in the U.S. District Court for the Southern District of New York against the motor yacht Amadea, a 348-foot luxury vessel reportedly worth more than $300 million whose beneficial owner is the sanctioned Russian oligarch Suleiman Kerimov.  In 2022, the Fiji government seized it at the request of the U.S.



 

 

D.C. Grand Jury Indicts Haitian Gang Leader with Hostage Taking and Death of U.S. Citizen

Friday, November 3, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
12
Abstract: 

On October 24, 2023, the Department of Justice announced the unsealing of a grand jury indictment filed in the U.S. District Court for the District of Colombia, charging Vitel’homme Innocent, a Haitian national and leader of the Kraze Barye gang, for engaging in the October 2022 armed hostage taking, in Haiti, of two U.S. citizens, one of whom was killed during the event.

UN and EU React to the Terrorist Attack on Israel and the Israeli Military Actions

Friday, November 3, 2023
Author: 
Michael Plachta
Volume: 
39
Issue: 
12
Abstract: 

On October 27, 2023, by a recorded vote of 121 in favor to 14 against, with 44 abstentions, the UN General Assembly (GA or Assembly) adopted the resolution titled “Protection of civilians and upholding legal and humanitarian obligations”, demanding that all parties immediately and fully comply with their obligations under international law, including international humanitarian law.

 

 

FinCEN Renews and Expands Real Estate Geographic Targeting Orders

Friday, October 27, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
11
Abstract: 

On October 20, 2023, the Financial Crimes Enforcement Network (FinCEN) announced the renewal and expansion of its Geographic Targeting Orders that require title insurance companies to identify the natural persons behind companies employed in non-financed purchases of residential real estate.

U.S. Department of Justice and Fish and Wildlife Service Boost Enforcement of International Endangered Species Trafficking Laws

Friday, October 27, 2023
Author: 
Jack Crovitz
Volume: 
39
Issue: 
11
Abstract: 

On October 10, 2023, the U.S. Attorney for the Eastern District of New York unsealed a six-count indictment charging Charles Limner, 75, with internationally smuggling more than $200,000 worth of protected insect species. The next day, the U.S. Attorney for the Eastern District of New York unsealed an eight-count indictment charging John Waldrop, 74, and Tony Jones, 53, with conspiracy to smuggle hundreds of taxidermied protected birds and thousands of protected eggs.

 

 

FinCEN Proposes Special Rule under Sec. 311 for More Transparency in Convertible Virtual Currency Mixing

Friday, October 20, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
11
Abstract: 

On October 19, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM) that identifies international Convertible Virtual Currency Mixing (CVC mixing) as a class of transactions of primary money laundering concern.  The NPRM underscores the risks posed by the extensive use of CVC mixing services by a variety of illicit actors worldwide and proposes a rule to increase transparency around VC mixing to combat its use by malicious actors including Hamas, Palestinian Islamic Jihad, and the Democratic People’s Republic of Korea (FPRK).

Treasury Extends Filing Beneficial Ownership Reports and Contemplates Alternative Forms

Friday, October 20, 2023
Author: 
Bruce Zagaris
Volume: 
39
Issue: 
11
Abstract: 

On September 28, 2023, FinCEN proposed to amend the beneficial ownership information (BOI) reporting rule to extend the filing deadline for certain BOI reports.  On September 30, 2023, FinCEN issued a notice of information collection with respect to the Beneficial Ownership Information Reports (BOIRs) and have proposed a dropdown box for filers who are not able to obtain the required beneficial ownership information.

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