On April 26, 2023, the Financial Crimes Enforcement Network (FinCEN) and The Kingdom Trust Company (Kingdom Trust) entered into a consent order, imposing a civil money penalty and requiring Kingdom Trust to take actions to remediate its deficiencies.[1]

On April 26, 2023, Frank’s  International, which is now Expro Group Holdings N.V., entered into  a cease-and-desist order and agreed to pay disgorgement of $4,176,858, prejudgment interest of $821,863, and a civil money penalty in the amount of $3 million to the Securities and Exchange Commission in settlement of the administrative charges against it.  The matter concerns violations of the anti-bribery, books and records, and internal accounting controls provisions of the Foreign corrupt Practices Act (“FCPA”) by Frank’s.[1]

Former Peruvian President Alejandro Toledo, who served in that role from 2001 to 2006, has been extradited from the U.S. to Peru due to his alleged involvement in a corruption scandal relating to public works contracts for Brazilian conglomerate Odebrecht.  Peruvian authorities allege that Toledo received millions of dollars in kickbacks from Odebrecht in exchange for awarding them a public works contract.

On April 18, 2023, at the end of a two-day meeting in Trinidad and Tobago on crime, the Caribbean Community (CARICOM) heads of government agreed to enact legislation in their countries to forbid the presence and use of assault-style weapons.  The bulk of these weapons originate in the United States.[1]  This article discusses the initiative of the CARICOM heads of government, efforts to hold U.S. gun manufacturers and distributors accountable, and the initiative of the Government of Mexico in the Inter-American Human Rights Commission.

On April 18, 2023, a federal grand jury in Tampa, Florida, returned a superseding indictment charging four U.S. citizens and three Russian nationals with acting on behalf of the Russian governments and in conjunction with the Russian Federal Security Service (FSB) to conduct a multi-year foreign malign influence campaign in the United States.[1]

On April 11, the U.S., Panama, and Columbia released a trilateral joint statement to undertake a 60-day campaign to stem the flow of illegal migration through the Darien Gap, an isthmus along the Colombia-Panamanian border that connects North and South America.  The United Nations reported in 2021 that the Gap saw 133,000 migrant crossings in 2021, an estimated 250,000 in 2022, and in the first three months of 2023, there have been 88,000 illegal crossings according official Panama migration data, six times the number logged in the same period last year.^[1]

In January the Reporter published my short comment on a case then pending in the Supreme Court, Halkbank v. United States, in which oral argument had been heard on January 23, 2023.[1]  The matter raised an important question: Are sovereign owned enterprises (“SOEs”) – that is, commercial entities majority owned by foreign States – immune from criminal prosecution under the Foreign Sovereign Immunities Act of 1976 (“FSIA”).   On April 19, 2023, the Court ruled that the FSIA does not provide any immunity against criminal prosecutions because it only applies to civil matters.  It left open the possibility that immunity could still be established under “common law,” and remanded to the United States Court of Appeals for the Second Circuit to explore this question.   This decision leaves open a number of perplexing questions.

On April 3, 2023, the United Kingdom’s National Crime Agency announced the formation of a specialist new unit to lead the UK’s work on international crime.  Called the Joint International Crime Center (JICC), it will consolidate and increase the UK’s capabilities around international law enforcement cooperation and coordination.[1]

On April 17, 2023,  the U.S. Attorney’s Office for the Eastern District of New York unsealed two criminal complaints, charging 44 defendants with various crimes related to efforts by the national police of the  People’s Republic of China (PRC) – the Ministry of Public Security (MPS) – to harass Chinese nationals residing in the New York metropolitan area and elsewhere in the U.S.[1]

On April 3, 2023, Europol and Eurojust Assisted a coordinated action against a fraudulent online investment platform, which is responsible for a loss of an estimated €89 million to at least 33,000 victims.  Working with German authorities, two action days occurred in March, during which law enforcement arrested five suspects.  In addition, law enforcement searched 15 locations in Bulgaria, Romania, and Israel, including five illegal call centers.[1]