On October 1, 2021, Oleg Tinkov, also known as Oleg Tinkoff, the founder of a Russian bank, pleaded guilty to filing a materially false tax return and agreed to pay more than $500 million  in taxes, interest, and penalties.

On October 3, 2021, the International Consortium of Investigative Journalists (ICIJ) released a new series of investigative stories and millions of leaked documents about political leaders, criminals, high-net-worth individuals, and the web of enablers who represented their clients in investing their funds in ways to keep confidential the identities of their clients and their assets.  These documents are known as the Pandora Papers.

On September 27, 2021, the U.S. District Court in Manhattan announced that a U.S. citizen pled guilty to conspiring to aid Democratic People’s Republic of Korea (North Korea) evade economic sanctions through the use of financial technology to hide illegal transactions. [1]

           Crypto expert, Virgil Griffith, 38, pled guilty to conspiracy to violate the International Emergency Economic Powers Act and Executive Order 13466, a law that prohibits U.S. citizens from “exporting any goods, services, or technology to the DPRK without a license from the Department of the Treasury, Office of Foreign Assets Control (“OFAC”).” Griffith allegedly violated that law by engaging with North Korean officials, advising them on how to evade sanctions.[2]

On September 24, 2021, Wanzhou Meng, 24, the Chief Financial Officer of Huawei Technologies Co. Ltd., entered into a deferred prosecution agreement (DPA) and was arraigned on charges of conspiracy to commit bank fraud and conspiracy to commit wire fraud bank fraud, and wire fraud   in U.S. District Court in the Eastern District of New York.[1]

On September 17, 2021, President Biden signed an executive order authorizing sanctions against the Ethiopian government, the Eritrean government, the Tigray People's Liberation Front, and the Amhara Regional Government, the parties that are allegedly involved in perpetrating the atrocities in the region.  While the U.S. did not immediately impose sanctions, the executive order is meant to alert the involved parties that the U.S. is prepared to take action.[1]

On September 17, 2021, U.S. District Judge Petrese B. Tucker, ruled that Moses Thomas, who had lived in Philadelphia since emigrating from Liberia in 2000, is liable under the Victim and Torture Protection Act (VTPA)[1] and the Alien Tort Statute[2] for the slaughter in 1990 of more than 600 civilians at a Lutheran church in Monrovia, Liberia.[3]

On September 21, 2021, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the first virtual currency exchange for laundering cyber ransoms and updated its ransomware advisory to encourage reporting of incident and ransomware payment to both Treasury and law enforcement.

The 10th Public Edition of the Basel AML Index was released on September 13, 2021. The Basel AML Index is an independent assessment and ranking of money laundering and terrorist financing (ML/TF) risks around the world, published by the Basel Institute on Governance since 2012 through its International Centre for Asset Recovery. The accompanying report questions whether jurisdictions are serious about tackling their ML/TF risks, given this year’s slight increase in the average global ML/TF risk score from 5.22 to 5.30 out of 10. It also highlights four specific areas of concern, relating to: virtual assets, beneficial ownership transparency, designated non-financial businesses and professions (DNFBPs), and preventive measures.

On September 8, 2021, Cape Verde’s Constitutional Court, the island nation’s highest judicial authority, approved the extradition to the U.S. of Colombian businessman Alex Saab, a Venezuelan emissary detained last year while refueling his private jet en route to Iran.^[1]  The decision to extradite Saab accompanies rising tensions between the U.S. and Maduro’s Venezuelan government and comes after a legal battle over the validity of Saab’s detainment and potential extradition. 

On September 8, 2021, United States law enforcement officials announced the unsealing in the Southern District of New York of an indictment, charging a former employee of the Swedish multinational telecommunications company Telefonaktiebolaget LM Ericsson (“Ericsson”) for his alleged role in a scheme to pay approximately $2.1 million in bribes to high-level government officials in the Republic of Djibouti and conspiring to launder funds.[1]