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.

U.S. Indicts Man in San Diego for Smuggling Potential Greenhouse Gases into the U.S.

Friday, March 8, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On March 4, 2024, the United States arrested Michael Hart of San Diego, charging him with smuggling potent greenhouse gases into the U.S. from Mexico and selling them for profit, in violation of regulations meant to curb the use of greenhouse gases and slow climate change.

Kenya and Haiti Sign Agreement, Allowing Deployment of Kenya Police

Friday, March 8, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On March 1, 2024, Kenya and Haiti signed a reciprocal agreement on police cooperation.  The agreement apparently will enable Kenya to send a contingent of 1,000 police officers to Haiti to lead a multinational mission to restore law and order in Haiti.[1]

 

Cybersecurity Firm Leak Exposes Chinese Government Hacking Practices and Process of Penetrating Domestic and Foreign Entities

Friday, March 8, 2024
Author: 
Kenneth Boggess
Volume: 
40
Issue: 
3
Abstract: 

A series of documents that leaked from the Sichuan branch of Shanghai Anxun Information Technology Co., Ltd. (“I-Soon”) in mid-February 2024 have revealed crucial details about the manner in which the Chinese government outsources the hacking of domestic and foreign entities.  The firm’s leaked records reveal it to be one of hundreds of private enterprises contracted to conduct state-sponsored hacking in an effort by the Chinese government to leverage private sector cybersecurity talent for state goals.[1]



[1]               Keith Bradsher, Aaron Krolik, John Liu, and Paul Mozur, Leaked Files Show the Secret World of China’s Hackers for Hire, N.Y. Times, Feb. 22, 2024, https://www.nytimes.com/2024/02/22/business/china-leaked-files.html.

 

FATF Plenary Makes New Guidance for Beneficial Ownership of Legal Arrangements, Will Release Consultation on Wire Transfers, Non-Profit Organizations, and Virtual Asset Jurisdictions

Friday, March 1, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On February 23, the Financial Action Task Force concluded the fifth plenary under the Presidency of T. Raja Kumar of Singapore. 

New Guidance for R. 25 on Beneficial Ownership and Transparency of Legal Arrangements

FATF’s issuance of new risk-based guidance for the implementation of Recommendation 25 on the beneficial ownership and transparency of legal arrangements finishes FATF’s work to strengthen the transparency of beneficial ownership internationally. 

 

International Law Enforcement Coalition Takes Down LockBit Ransomware Gang

Friday, March 1, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On February 20, 2024, the National Crime Agency (NCA) in the United Kingdom, the U.S. Department of Justice (DOJ), and nine other law enforcement agencies announced they have taken control of computers and software at the core of the LockBit ransomware gang, the world’s most prolific ransomware group.  The takedown gives victims hope that they will not be forced to make ransom payments to recover data stolen from their computer systems.[1]



[1]    Joseph Menn and Leo Sands, 11-nation operation takes down world’s most prolific ransomware group, Wash. Post, Feb. 21, 2024, at A16, col. 1.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               

 

Czech Republic Extradites Person Charged with Iranian Murder Plot against Journalist in the U.S.

Friday, March 1, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On February 21, 2024, the U.S. Department of Justice announced the extradition by the Czech Republic of Polad Omarov, a/k/a “Araz Aliyev,” a/k/a “Polad Qaqa,” a/k/a “Haci Qaqa,” on murder-for-hire and money laundering charges in a Superseding Indictment in the Southern District of New York.  The Czech Republic arrested Omarov on January 4, 2023.[1]



[1]    U.S. Attorney S.D.N.Y., U.S. Attorney Announces Extradition Of Organized Crime Leader Charged With A Murder Plot Directed From Iran Targeting a Journalist,  Press Rel. 24-062, Feb. 21, 2024.

 

SFO Charges Two Former Petrofac Executives with Bribery in Follow Up to Company’s Conviction

Friday, March 1, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
3
Abstract: 

On February 16, 2024, the Serious Fraud Office (SFO) charged two former Petrofac senior executives Marwan Chedid and George Salibi, with bribery.[1] Both Chedid and Salibi served in various senior roles within the Petrofac Group in the United Arab Emirates (UAE).



[1]    SFO, SFO charges two former Petrofac senior executives with bribery, Feb. 16, 2024.

 

European Union Adopts New Directive to Strengthen Protection Environment Through Criminal Law

Friday, March 1, 2024
Author: 
Michael Plachta
Volume: 
40
Issue: 
3
Abstract: 

On February 27, 2024, the European Parliament approved new rules on environmental crimes and related sanctions. The new directive was adopted with 499 votes in favor, 100 against and 23 abstentions. It contains an updated list of criminal offences including illegal timber trade, depletion of water resources, serious breaches of EU chemicals legislation and pollution caused by ships.

U.S. Treasury Publishes 2024 National Risk Assessments for ML, TF, and PF

Thursday, February 22, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
2
Abstract: 

                On February 7, 2024, the U.S. Department of the Treasury published the 2024 National Risk Assessments on Money Laundering, Terrorist Financing, and Proliferation Financing (NRAML).  The report highlights the most significant illicit finance threats, vulnerabilities, and risks confronting the U.S.[1]



[1]    U.S. Department of Treasury, Treasury Publishes 2024 National Risk Assessments for Money Laundering, Terrorist Financing and Proliferation Financing, Press Rel., Feb. 7, 2024.

 

GAO Highlights U.S. Agencies’ Efforts to Mitigate Risks Posed to Economic Sanctions by Digital Assets

Thursday, February 22, 2024
Author: 
Bruce Zagaris
Volume: 
40
Issue: 
2
Abstract: 

                On December 13, 2024, the Government Accountability Office (GAO) released a report on the Use of Digital Assets to Evade U.S. Sanctions.  The GAO found that digital assets and other virtual currencies pose risks to implementing and enforcing U.S. sanctions.  A principal element of digital assets is that they enable their users to quickly transfer value worldwide.  On the one hand, many digital assets are recorded on a public ledger, which may enable U.S. agencies and analytics firms to trace transactions and potentially identify illicit actors.  However, digital asset owners also use the anonymizing features of some digital assets or other techniques that obscure their identities in an effort to evade sanctions.

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