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Sanctions and Stables: Public Records Show Recently Sanctioned Horse Trainer Controls Companies in the U.S. and UK
A recently sanctioned UAE-based horse trainer maintains a network of previously unreported companies within the U.S. and UK. The network, which also has ties to Gulf-based Arab elites, highlights a unique case of risk within an industry not regularly subject to...
How Iran’s National Shipping Company Used Offshore Companies to Dodge U.S. Sanctions
Iran’s national maritime carrier used front companies in Cyprus, Hong Kong, China, and Turkey to hide its ownership and management of four sanctioned vessels, according to public records. Our investigation demonstrates the richness of data from offshore jurisdictions,...
How to Identify Military-Civil Fusion Companies in China Using Public Records
This is a follow-up to our previous posts on the highest risk entities owned by “Chinese Communist Military Companies,” the Section 1237 designations, and China’s Military-Civil Fusion strategy. Participation in Military-Civil Fusion can be identified in public...
Inclusion of Tranche 4 Military-Affiliated Companies Under Section 1237
We have updated our previous dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s inclusion of four additional entities (Tranche 4) on December 3. This updated dataset...
Emiratis for Hire: The Role of Nominee Shareholders in Sanctioned Iranian Networks
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned key players in Iran's oil industry in October for providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). In the official press release, OFAC claims that the...
Public Records Indicate Lebanese PEP May Have Used Corrupt Assets to Build Real Estate Empire
The Middle East can be a lucrative business environment due to the continued liberalization of foreign investment laws and its relatively large and young working-age population. Unfortunately, the region suffers from a dangerous combination of public corruption and...
The World’s Largest Shareholders: Understanding China’s National and Regional SASACs
Anyone investigating China’s state-owned enterprises (SOEs) will eventually come across their primary owner, one of the State-owned Assets Supervision and Administration Commissions (SASAC). There are multiple commissions at every level of government in China, from...
Identifying High-Risk Entities Owned By “Chinese Military Companies” on Section 1237 & E.O. 13959 List
13th Recent U.S. regulations have targeted the risks posed by Chinese military companies, including 31 companies designated by the Department of Defense under Section 1237 of the National Defense Authorization Act of 1999 and later named in Executive Order 13959...
Peru’s Fishing Industry Involved in Laundering Money through GTO-Covered Miami Beach
An alleged money laundering scheme carried out by a family network based in Peru underscores how the Peruvian fishing industry has become a viable channel to clean illicit proceeds from a variety of predicate crimes. The network — composed of several immediate family...
U.S. Import Ban on Xinjiang Cotton Could Impact More Than 2,400 Chinese Firms
U.S. Customs and Border Protection (CBP) announced last Wednesday that shipments of cotton and cotton products from China’s Xinjiang Production and Construction Corps (XPCC) will be detained at all U.S. ports of entry. CBP’s Withhold Release Order (WRO) applies to...
U.S. Adds SMIC and other Chinese Entities to List of Military Companies
The U.S. Department of Defense will add four entities to its list of Chinese military companies barred from U.S. investment, according to Reuters. The announcement comes amidst repeated U.S. actions to highlight the risks posed by Chinese military entities. President...
Chinese Mining Company Affected by Protests in Kyrgyzstan Has Ties to Major SOE
Work came to a halt last month at Full Gold Mining LLC, a Chinese-owned mining company located in Kyrgyzstan after protesters stormed its facilities following the country’s October 4 parliamentary elections. Full Gold Mining has connections to a large Chinese...
“Chinese Military Companies” Under China’s Military-Civil Fusion Strategy
The U.S. Department of Commerce is considering designating 89 Chinese companies as “military end users,” Reuters reported yesterday. This is the latest in a series of U.S. actions targeting Chinese companies with military ties. On November 12, President Trump issued...
Chinese Social Credit Blacklists: A Trove of Public Data Hiding in Plain Sight
China’s development of the social credit system has led to a rich outpour of official documents and publicly available databases that shed light on corporate compliance and reputational issues. This data, which includes hundreds of blacklists for a variety of types of...
The Russian National Reinsurance Company — Reinsurance’s Answer to Sanctions
Western insurers in Russia may be at risk of funding reinsurance payouts for liabilities exposed to sanctions, due to a 2017 piece of Russian legislation. In addition, the legislation may have presented new ways for investigators to identify which insurers in Russia...
Public Records Connect Additional Associates of Berkshire Hathaway Turkish Subsidiary Fined for Iran Sanctions Violation
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently fined Berkshire Hathaway, Inc. $4.2 million after a subsidiary based in Turkey knowingly violated sanctions against Iran. Public records in Turkey indicate additional connections among the...
Public Records, FinCEN Files Show Kaloti Network Poses Risk of Sourcing Illicit Gold and Money Laundering
The illicit gold trade continues to challenge global anti-money laundering (AML) efforts, as shown in “the FinCEN Files,” a collection of more than 2,100 leaked Suspicious Activity Reports (SARs) filed by financial institutions with the U.S. Treasury’s Financial...
Corporate Data Shows 30+ Companies List Address Inside Sanctioned Paraguayan Shopping Mall
Almost fifteen years have passed since the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Paraguayan shopping mall Galeria Page for allegedly serving as a key financial support center for Hezbollah in South America. At the time of...
Public Records Reveal UAE Network Behind Alleged Supplier of Iranian Ballistic Missile Equipment
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iranian conglomerate Mammut Industries and its subsidiary Mammut Diesel last month for allegedly providing military-grade, dual-use goods to an entity involved in Iran’s ballistic missile program....
Lebanese Distributors Possible Re-Exporting US Products to Sanctioned Jurisdictions
The Lebanese Ministry of Economy and Trade maintains a publicly available, electronic database documenting contracts between international companies and Lebanese third-party distributors. Details show that some Lebanese distributors are possibly re-exporting American...
Identifying the XPCC’s Highest-Risk Entities
Last month, we reported on the sprawling holdings of the OFAC-sanctioned Xinjiang Production and Construction Corps (XPCC), a massive Chinese conglomerate with hybrid paramilitary-corporate structure. The XPCC was sanctioned for its alleged involvement in human rights...
Tracing Trade Patterns of Alleged Wildlife Traffickers: The Wu Criminal Organization
A transnational network engaged in wildlife trafficking, shark finning, drug trafficking, and money laundering was dismantled by federal and local law enforcement earlier this month, according to a United States Department of Justice (DOJ) announcement. The Wu...
U.S. Restricts Imports from Select Xinjiang Entities, While Considering Legal Implications of Wider Import Bans
U.S. Customs and Border Protection (CBP) announced on Monday it would delay an industry-wide ban of tomato and cotton produced in Xinjiang, a region in Northwest China. Our research shows that if such a ban were enacted, over 2,600 Chinese entities could be barred...
Analysis Uncovers Additional Companies in Fraud & Money Laundering Network Not Included in DOJ Indictment
A clothing importer based in the Los Angeles Fashion District recently agreed to plead guilty to charges related to his company’s tax fraud scheme, money laundering, and customs violations, resulting in nearly $118 million in fines. The company owner, Sang Bum “Ed”...
U.S. Import Restrictions on Xinjiang Cotton and Tomatoes Could Impact At Least 2,600 Chinese Firms
U.S. Customs and Border Protection (CBP) intends to impose restrictions on cotton and tomato imports from China’s Xinjiang Uighur Autonomous Region (XUAR), according to Reuters. We found over 2,400 companies in Xinjiang linked to cotton and over 240 companies linked...
Operation Car Wash: Messer’s Money Laundering Network Involves a Web of Investment Companies in the US and Across Latin America
A federal court in Rio de Janeiro recently approved the cooperation agreement of one of Brazil’s most prominent money launderers — Dario Messer. While the deal may signal the end of Messer’s criminal case in Brazil, the extent of his money laundering network — which...
Historic Counterfeit Cigarette Case Highlights Vulnerabilities in Middle East Tobacco Markets
Jordan is witnessing the largest corruption trial in its history, known locally as Qadhiiyat Al-Dukhan (the smoke case). The trial began in the summer of 2018 amidst major protests and the arrival of a new prime minister, Omar Al-Razzaz. This trial has now become a...
Hong Kong-Based Shipping Company Tied to North Korea-Flagged Coal Smuggling Vessel Also Owns UN-Sanctioned Vessel
A joint investigation by NK Pro and the Royal United Services Institute’s (RUSI) Project Sandstone revealed in July that North Korean-flagged vessels have returned to pre-pandemic levels of coal smuggling activities using a busy maritime route between the Democratic...
Bahrain Sentences Three Central Bank of Iran Officials for Money Laundering
Bahrain’s High Criminal Court charged three bank officials last week to five years in prison, respectively, for their involvement in a money laundering case tied to the Central Bank of Iran and other Iranian banks, according to the Bahrain News Agency. The Court also...
The Dark Side of Beauty: An Overview of the Counterfeit Cosmetics Industry
The rapid expansion of counterfeit cosmetics internationally and in the U.S. poses a public health risk for consumers and threatens the bottom lines of countless makeup companies. The global cosmetics industry is valued at approximately $523 billion and is expected...