KYC360 Weekly Roundup

Published on Apr 01, 2022

Spotlight on Trafficking and Modern Slavery

As sanctions continue to have an impact across the world, in this week’s AML Roundup we take a look at the impact they are having on their intended targets and report on how the institutions tasked with enforcing the rules are responding to the challenge.

We also explore the profoundly immoral and wicked trade in human trafficking and how criminal gangs are seeking to exploit the suffering of the vulnerable. Whether it be targeting refugees fleeing war-torn Ukraine or impoverished migrants seeking a better life.

To complete this week’s offering, we have summarised the very latest AML, fraud, and corruption stories from around the world.



How the Ukraine invasion is fuelling human trafficking

For decades, human trafficking rings have been heavily involved in in Ukraine and its neighbouring countries. The invasion has now forced over three and a half million people over the border; often with no place to go, they put their trust into the hands of complete strangers, sometimes with terrible consequences.

Further afield, around 72,000 Ukrainian refugees have reached Italy. Of these, over 31,000 are children with a sizeable number arriving unaccompanied. This has led to Italian aid agencies warning people against taking children through unofficial channels because of growing concerns about their potential for exploitation by criminal gangs.

Modern slavery and human trafficking can take on many guises

In the UK, a family of four have been jailed for coercing a Polish national into servitude. The woman in her 40s was brought to the UK with the promise of work, but was immediately enslaved and forced to work seven days a week without pay, in conditions which amounted to modern servitude.

The Pan American Health Organization (PAHO), an international body that promotes health initiatives in the Americas, is facing a lawsuit by Cuban doctors. They accuse it of helping arrange a program in which they were forced to work in Brazil against their will, thereby violating human trafficking laws.

In India, a baby was sold for ₹5 lakh (approx. GBP 5,000). The 27-day-old male infant who was allegedly sold by his parents to a man who took the baby and reportedly sold the baby again to some people, who in turn sold the baby to another couple. Thankfully, the newborn was rescued by police and the Women Development and Child Welfare (WD&CW) Department.

Human trafficking awareness launched campaign ahead of the 2022 Miami Formula 1 Grand Prix

Ahead of the Miami Formula 1 Grand Prix this coming May, officials have launched an awareness campaign about the dangers of human trafficking. Major tourist events are a magnet for criminal gangs looking to exploit vulnerable people as the city experienced when it hosted the Super Bowl in 2020.

Proposed legislation set to protect more victims of child sex trafficking

According to Save the Children over 27% of sex trafficking victims are children, so a US state is proposing a bill that seeks to provide better protection to the victims of child sex trafficking. The ‘Safe Harbor’ bill will prevent victims from being charged with prostitution and instead will focus on providing them with the services they need.

FATF reports on the money laundering and terrorist financing risks that arise from migrant smuggling

Every year, millions of migrants go in search of a better future and the proceeds generated by smugglers are now estimated to exceed USD10 billion per year. Yet many countries do not consider it a high-risk crime for money laundering and financial flows are rarely investigated. This new FATF report analyses the money laundering and terrorist financing risks migrant smuggling poses.


Financial_ServicesMoney Laundering, Fraud & Corruption

EU court rules against UK in £2.2bn import fraud case

The European Commission raised a claim against Britain for failing to crack down on importers who evaded paying the correct customs duties by undervaluing Chinese textiles and footwear. The EU estimates that the bloc lost out on a staggering €2.7bn (£2.2bn) between 2011 and 2017 as a result of inadequate customs checks and is demanding that Britain foots the bill.

UK fraud office head accused of serious and basic errors by lawmakers

Lisa Osofsky, the head of the UK Serious Fraud Office (SFO) has been accused by lawmakers of “very, very basic errors in litigation” and hiding behind a review into the agency’s failings. Refusing to answer questions, she said she was duty bound to wait for the recommendations of former High Court judge David Calvert-Smith before answering questions about how two convictions in the Unaoil bribery prosecution were quashed by the Court of Appeal.

Australia risks being placed on the FATF’s grey list

Australia’s failure to bring lawyers and other professionals into the anti-money laundering and counter-terror finance (AML-CTF) regime could see it being placed on the FATF grey list of countries subject to increased monitoring. This would place it in group along with Syria, Myanmar and South Sudan.

New Zealand moves to crack down on corporate secrecy after Pandora Papers

A proposed law to establish a public beneficial ownership register would build on post-Panama Papers reforms to end use of the country as a tax haven. New Zealand moves to crack down on corporate secrecy after Pandora Papers. A proposed law to establish a public beneficial ownership register would build on post-Panama Papers reforms to end use of the country as a tax haven.

Angry shareholders sanction Ericsson chiefs over Iraq corruption scandal

Angry shareholders handed Ericsson’s chief executive Börje Ekholm an unexpected rebuke by voting to hold him accountable for the company’s mishandling of the Iraq bribery scandal and subsequent revelations about the possibility of payments being made to the Islamic State terror group.

EU seizes $130m assets linked to money laundering in Lebanon

According to the EU’s justice agency, France, Germany, and Luxembourg have seized properties and frozen assets worth 120 million euros ($130m) in an operation linked to money laundering in Lebanon. The operation was directed against five people who are suspected of embezzling more than $330m of public funds between 2002 and 2021.



A summary of Russia sanctions to date.

Over the last month numerous sanctions have been imposed on Russia in response to its invasion of Ukraine. Follows a list of all the sanctions imposed to date, together with Russia’s response

Jersey freezes £259 million worth of Russian assets

This week, the Jersey government announced that there have been more than 800 asset freezes with a total value of £259 million since sanctions were introduced.

The National Crime Agency is losing the fight against billionaire oligarchs due to underfunding

The NCA faces a losing battle in attempting to track down oligarchs’s wealth, operating on a “shoestring” budget against targets armed with unimaginable wealth.

Sweeping Companies House reforms to be fast tracked

The UK Government published a White Paper on Corporate transparency and register reforms setting out plans to tackle global economic crime and improve corporate transparency. The reforms will broaden the role of Companies House, to transform it from a passive recipient of information to a more active gatekeeper over the creation of companies and custodian of more reliable data.

How digital sanctions have become the new geopolitical battleground

Digital sanctions are playing an increasingly important role in international conflicts. With mission-critical business technology being able to be switched off remotely what impact will it have on Russia and for the future of global markets?

Half of Russia’s 20 richest billionaires not been sanctioned

The news is awash with stories about Russian oligarchs who have been sanctioned over the invasion of Ukraine. But why has one group of powerful billionaires been left free to operate in key global markets without any legal restrictions?

Turkey says sanctioned Russian oligarchs are welcome as tourists and investors

According to the country’s foreign minister, sanctioned Russian oligarchs are welcome in Turkey as tourists and investors, as long as their yachts remain outside the territorial waters of sanctioning countries. Yet western governments could press Ankara by imposing secondary sanctions to prevent Turkey from becoming a safe haven for the oligarchs.

Sanctions evasion: oligarchs’ safe havens shrink, but are far from disappearing

While sanctions are making it hard for Russian oligarchs to find safe havens for their assets, it would appear that greed has no bounds, nor boundaries for that matter.

Nokia has pulled out of Russia but left behind a vast surveillance system

When the Finnish company denounced the invasion and pulled out of Russia, it failed to mention what it had left behind. Namely, the equipment and software that helps power a vast surveillance system that is used to track supporters of the Russian opposition.

US lawmakers to investigate Credit Suisse over Russia sanctions compliance

US lawmakers have requested that the scandal-hit bank hand over all documents related to the financing of yachts and private jets owned by potentially sanctioned individuals. The probe comes after the FT reported that it had asked hedge funds and other investors to destroy documents relating to its richest clients’ yachts and private jets.

UK seizes first ever detention of a Russian superyacht in British waters

Officers from the UK National Crime Agency have detained a £38m superyacht owned by an unnamed Russian businessman. The vessel, Phi, is registered to a St Kitts and Nevis company and carried Maltese flags “to hide its origins”, the NCA said. It’s the first ever detention of a superyacht in UK waters.


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