On October 26, 2021, agencies in the U.S. and European Union (EU) announced the seizure of cash, virtual currencies, and goods, in addition to the arrests of 150 alleged suspects, in a follow-up operation to the earlier takedown of dark web network DarkMarket.^[1]  The operation, entitled Operation DarkHunTOR, came from a series of coordinated actions from government and law enforcement agencies in Australia, Bulgaria, France, Germany, Italy, the Netherlands, Switzerland, the U.K., and the U.S.^[2]  The operation was carried out in the framework of the EU’s security initiative EMPACT, the European Multidisciplinary Platform Against Criminal Threats.^[3]

On October 21, 2021, the members of the European Parliament approved a resolution on the Pandora Papers: implications for the efforts to combat money laundering, tax evasion and tax avoidance, recommending new enforcement and prevention measures.[1]

On October 21, 2021, the Financial Action Task Force (FATF) issued a statement on the results of the fifth Plenary of the FATF under the German Presidency.

In October 2021, the Metropolitan Museum of Art (Met) in New York announced its collaboration with U.S. investigators from the U.S. Attorney’s office to determine if the artifacts in the museum were stolen from Cambodia.[1]

On October 22, 2021, the United States Court of Appeals for the Second Circuit issued an opinion in United States v. Halkbank, 20 Cr. 3499, directing that a criminal prosecution against sovereign-owned Halkbank for money-laundering and related charges could proceed.  The opinion surveyed several complex issues relating to prosecution of sovereign owned enterprises (SOEs) under the Foreign Sovereign Immunities Act (FSIA).  While it resolved some of these questions, it carefully avoided addressing others; as a result, several questions still lurk in this complex and important area.

On September 21, 2021, the Mexican government on behalf of its Financial Intelligence Unit (UIF) filed a 141-page complaint in the Florida state court against former security chief Genero Garcia Luna and a series of companies operated by him and his associates, in order to recover illegally obtained assets.[1]

On September 21, 2021, the European Human Rights Court’s Chamber overwhelmingly held Russia responsible for the poisoning of Aleksandr Litvinenko.[1]  On the same day, the British government named Denis Sergeev as a suspect in the Novichok poisoning of former Russian spy, Sergei V. Skripal and his daughter Yulia.[2]

On October 16, 2021, Cape Verde extradited Alex Nain Saab Moran (Saab) to the United States to answer an indictment charging him with laundering the proceeds of violations of the Foreign Corrupt Practices Act (FCPA) in connection with a scheme to pay bribes to take advantage of Venezuela’s government-controlled exchange rate.[1]

An October 4, 2021 report published by the U.N. Human Rights Council’s Independent Fact-Finding Mission on Libya (“Mission”) warned of the likelihood of war crimes and crimes against humanity committed in the country by multiple conflicting parties since the beginning of 2016.  The report, which the Mission presented on October 5, 2021, examines nine areas of focus for violations, abuses, and crimes under international human rights, humanitarian, and criminal law.^[1]  Categories range from deprivation of liberty to extrajudicial killings and gender-based violence.  In response, the U.N. Human Rights Council renewed the Mission’s timeline for an additional nine months to conduct further investigation and assemble information in greater detail.^[2]

On October 7-8, 2021, the European Justice and Home Affairs Council met and agreed to take several initiatives on international enforcement matters.[1]