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U.S. AML Posture Tightening But Gaps Remain: Open, Connected Data Can Help Ease Challenges
The AML Act (“the Act”) enacted in January 2021 includes several measures to help financial institutions (FI) not only better understand their risks but also better mitigate their risks. However, gaps remain that raise important questions for FIs. In particular, quite...
Proliferation Financing: FATF Now Calls on Banks To Mitigate Risks
The Financial Action Task Force (FATF) in October 2020 adopted amendments expanding Recommendation 1 to include proliferation financing (PF) risk, in addition to money laundering and terrorist financing risks. Key PF typologies clearly demonstrate that certain open...
Tax Havens & Offshores: Public Registries & Network Analysis Can Mitigate Jurisdictional Challenges to KYC & Investigations
While the lack of corporate transparency in offshore jurisdictions poses a significant due diligence challenge, not all offshores are as opaque as they seem. Easily accessible public registries from offshore jurisdictions combined with creative analytical techniques...
Trademark and Tax Records Tie Multi-ton Cocaine Seizure in Hamburg to Paraguayan Paint Company
A multi-ton cocaine seizure in the city of Hamburg, Germany conducted earlier this month is connected to a company based in Paraguay, according to Paraguayan tax and trademark records. The seizure itself highlights the continued role of European ports in receiving...
UK Property and Corporate Records Highlight Real Estate Holdings of Gulf Elites
Major business leaders and political figures from the Gulf Cooperation Council (GCC) monarchies invest billions of dollars into the UK real estate market annually. UK property records show that some investors are members of or even lead these royal families. The UK...
Downstream Holdings of China’s HNA Group Vulnerable After Multi-Billion Dollar Embezzlement Scandal
Chinese aviation investment conglomerate HNA Group is facing bankruptcy proceedings that will result in restructuring for 500 of HNA’s subsidiaries, according to media sources. By combining public records with network analytics, we were able to find more than 5,000...
New BIS Guidance Calls for Enhanced Due Diligence of Military End Users in China
The U.S. Department of Commerce has tightened restrictions on exports to China, Russia, and Venezuela to counter the acquisition of U.S. technology for military use. Now, military end users in all three countries are subject to licensing requirements. Identifying...
Public Records And Network Analytics Enhance Investigations for More Useful SAR Narratives
Regulators and law enforcement have made it clear — financial institutions (FI) must do more to enable investigators to craft more useful Suspicious Activity Reports (SARs). Data from public records enhanced using automated graph technology can transform AML/financial...
Addition of Tranche 5 Military-Affiliated Companies Under Section 1237, E.O. 13959
We have updated our dataset of Chinese military companies identified under Section 1237 of the National Defense Authorization Act to reflect the U.S. Department of Defense’s addition of nine entities on January 14. The updated dataset also includes 34 entities we...
Corporate Records Provide Additional Insight into Companies and Individuals With Alleged Financial Ties to Mexico’s Jalisco Cartel
The freezing of nearly 2,000 bank accounts last year with alleged ties to Mexico’s Jalisco New Generation Cartel (Cártel Jalisco Nueva Generación, CJNG) suggests that Mexican authorities may be upping the pressure on the organization’s finances. Mexican corporate...
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 Possibly 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...