{"id":1818,"date":"2021-12-28T18:11:13","date_gmt":"2021-12-28T22:11:13","guid":{"rendered":"http:\/\/ielrblog.com\/?p=1818"},"modified":"2021-12-28T18:11:13","modified_gmt":"2021-12-28T22:11:13","slug":"2021-holiday-retrospective","status":"publish","type":"post","link":"https:\/\/ielrblog.com\/index.php\/2021\/12\/28\/2021-holiday-retrospective\/","title":{"rendered":"2021 Holiday Retrospective"},"content":{"rendered":"

We at the IELR send you the best wishes for a warm and joyous holiday season. \u00a02021 was momentous for the international enforcement community, and we are grateful to have had you following along with our coverage during our 37th<\/sup> year of discussing international enforcement developments.<\/p>\n

Contributors<\/em><\/p>\n

We are grateful for the continuing long partnership with Professor Michael Plachta and for contributions from practitioners and professors, including Dr. Ted Bromund, Frederick T. Davis, Michele Estlund, Dr. Scott MacDonald, Dennis Boyle, Konstantinos Magliveras, Yuriy Nemets, Spencer A. Hill, Peter D. Hardy, Kateryna Boguslavska, Matteo Formaggi, and Linda Friedman Ramirez. Miranda Bannister finished her tenure as assistant editor in February.\u00a0 Marwah Adhoob, who specialized in criminology as an undergrad, energetically replaced her.\u00a0 Our legal assistants Sara Kaufman and Emma Byrne ably contributed articles. Our interns, Mitchell Beebe, Elena Botts, Kayla DeAlto, Austin Max Scherer, Teddy David, Jamie Jang, Kenneth Boggess, and Julia V. Brock, contributed some great pieces.<\/p>\n

The following is a highlight of some of the articles we covered.<\/p>\n

International Criminal Court<\/em><\/p>\n

The International Criminal Court<\/em> was prominent in our coverage. Plachta discussed the territorial jurisdiction of the ICC in the Palestine\/Israel Case as well as the ICC Prosecutor closing a preliminary examination in Colombia and concluding an agreement with the Colombian government. K. DeAlto discussed the Central African Republic\u2019s surrender of Said Abdel Kani to the ICC.\u00a0 M. Beebe and Zagaris wrote articles about the U.S. District Courts\u2019 blocking President Trump\u2019s executive order, sanctioning ICC officials. Zagaris discussed President Biden\u2019s revocation of the Trump executive order.<\/p>\n

War Crimes and Crimes against Humanity<\/em><\/p>\n

On war crimes and crimes against humanity<\/em>, Brock discussed the reversal by the South Korean court of the 2018 on \u201ccomfort women\u201d and ordered Japan to pay reparations to the families of 12 women forced to work as sex slaves. Plachta discussed the ECHR\u2019s decision on German responsibility for an air strike in Afghanistan.\u00a0 David and Kaufman respectively discussed German courts\u2019 convictions of a former Syrian secret police officer and a Syrian military doctor for crimes against humanity and Adhoob discussed a German court\u2019s conviction of a woman for crimes against humanity in the death of a Yazdi girl in Syria.\u00a0 Likewise, Adhoob detailed the enforcement actions of the UN with regards to genocide, such as UN\u2019s opening of an inquiry into Sri Lanka\u2019s alleged war crimes during its civil war as well as the UN investigation team\u2019s conclusion that ISIL\u2019s crimes against Yazidis constitute genocide.\u00a0 Adhoob discussed a report by a U.S. law firm, finding France responsible for the Rwandan genocide.\u00a0 Zagaris and Adhoob wrote about the UN Human Rights Council\u2019s adoption of a resolution to start a Commission of Inquiry on the latest Israel-Palestine conduct. Jang discussed the African Union\u2019s starting of a Commission of Inquiry on the war in Ethiopia. David wrote about the conviction in a Swiss court of a Liberian warlord, putting the spotlight on universal jurisdiction and Liberian accountability.\u00a0 Zagaris covered the French Supreme Court\u2019s overturning of the dismissal of complicity for crimes against humanity against multinational enterprise Lafarge for its conduct in Syria. Boggess discussed the UN Human Rights Council\u2019s Independent Fact-Finding Mission renewing its mandate as a UN report warns of war crimes and crimes against humanity. Ramirez wrote about a judgment of the Inter-American Court of Human Rights, finding Colombia responsible for a journalist\u2019s abduction twenty years before.<\/p>\n

Tax transparency and Enforcement<\/em><\/p>\n

With respect to tax transparency and enforcement<\/em>, Zagaris wrote about the EU Parliament\u2019s adoption of a resolution to toughen the tax haven blacklist, the OECD\u2019s call for action to disrupt, prevent, and prosecute criminal conduct by professional enablers, the OECD\u2019s new edition of fight tax crime, and the many cases against tax enablers, including the cum-ex dividend fraud cases, as well as a federal court\u2019s approval of a John Doe Summons for a Panamanian law firm dealing with U.S. clients.\u00a0 Scherer also wrote about how charges against professionals illustrate the shifting legal landscape for professional enablers. Zagaris also discussed the U.S. Tax Court decision against a constitutional challenge to passport denial for delinquent taxpayers and about a founder of a Russian bank pleading guilty to tax fraud, including falsifying his expatriation statement. \u00a0Zagaris discussed the Nigerian government\u2019s start of voluntary offshore assets London declaration facilities and its application to foreign enablers.\u00a0 Zagaris wrote about a CJEU decision mandating enforcement of tax information request even without the taxpayer\u2019s specific name and identity.<\/p>\n

Money Laundering, Bank Secrecy and Transparency<\/em><\/p>\n

On money laundering, bank secrecy and transparency<\/em>, Boguslavska discussed how the 10th<\/sup> Basel AML index highlights four worrying gaps in global AML efforts.\u00a0 Zagaris wrote several articles on the Anti-Money Laundering Act of 2020, as well as FinCEN\u2019s proposed regulations on beneficial ownership and the ANPRM on beneficial information on real estate purchases. MacDonald wrote about Suriname\u2019s corruption and money laundering challenges.\u00a0 Adhoob and Zagaris wrote about the FinCEN notice informing financial institutions of money laundering dangers from illicit art and antiquities trade. Plachta discussed the Council of Europe\u2019s adoption of a resolution and recommendation on strengthening FIUs.\u00a0 Zagaris discussed the Cayman AML regulator\u2019s crack down after the FATF greylisting. \u00a0\u00a0Scherer discussed how the Xizhi Li conviction showed an application of money laundering techniques for laundering drug proceeds on behalf of foreign drug-trafficking organizations. Zagaris discussed the implications of the Pandora Papers and the proposed new enforcement actions of the European Parliament in the wake of the Pandora Papers.<\/p>\n

Counter-terrorism, Economic Sanctions and Human Rights<\/em><\/p>\n

Counter-terrorism, economic sanctions and human rights<\/em> were continuing topics.\u00a0 Plachta discussed the adoption by the European Commission of a new counter-terrorism agenda and a proposal for amending Europol regulation.\u00a0 Adhoob discussed the ACLU\u2019s suit on alleged discrimination by the U.S. \u201cno-fly list\u201d against Arabs and Muslims.\u00a0 Zagaris covered China\u2019s adoption of blocking legislation and counter-sanctions. Bannister covered the Biden Administration\u2019s countering the Trump Administration\u2019s sanctions against the Houthi rebels in Yemen.\u00a0 Zagaris discussed the ruling of the EU Advocate General that a German telecom cannot cancel a contract with an Iranian bank without showing the cancellation was not due to U.S. sanctions.<\/p>\n

Counter-terrorism financing<\/em>,<\/p>\n

On counter-terrorism financing<\/em>, Adhoob discussed U.S. prosecution of a woman extradited by the Dutch for terrorist financing through a charity.\u00a0 Zagaris wrote about a French donor\u2019s financial contributions to the U.S. alt-right before the capitol assault and the need to apply counter-terrorism financial enforcement tools as well as a meeting between G7 and EU Security ministers on cooperation on countering racially and ethnically motivated extremism.<\/p>\n

Transnational Corruption and Asset Forfeiture<\/em><\/p>\n

With respect to transnational corruption and asset forfeiture<\/em>, Zagaris discussed the Justice Department\u2019s civil forfeiture suit against two alleged Ukrainian kleptocrats, a settlement by Deutsche bank of an FCPA and commodities case.\u00a0 Bannister and Adhoob covered in separate articles the fishrot scandal in Namibia, where Icelandic Samherji employees allegedly paid bribes to Namibian government officials for rights to fish for horse-maskerel. Boyle discussed the Biden Administration\u2019s policy toward Central America and the challenges posed by corruption. Zagaris contributed a piece on U.S.-N. Triangle Enhanced Engagement Act setting the stage for new U.S. policy. Zagaris discussed the British Commission on Inquiry\u2019s investigation of alleged corruption in the BVI as well as the Biden memorandum declaring anti-corruption a core U.S. national security interest.\u00a0 Zagaris wrote about the Dutch court\u2019s agreement with a report calling the Santos-linked Angolan energy deal corrupt.\u00a0 Zagaris discussed the Amec Foster Wheeler\u2019s global corruption settlement with the U.S., U.K., and Brazil.\u00a0 Zagaris discussed the return by the U.S. government of an additional $452 million in forfeited 1MDB funds to Malaysia as well as the DOJ\u2019s return of over $32m in forfeited funds to FIFA victims.<\/p>\n

Illegal Production and Use of Weapons<\/em><\/p>\n

With respect to the illegal production and use of weapons<\/em>, Zagaris discussed a suit by the Mexican government against U.S. arms manufacturers for illicit trafficking in arms as well as the guilty plea in the U.S. in the first successful prosecution of exportation and manufacturing of firearms to the Mexican Cartels. Adhoob discussed the U.K. and U.S. sanctions on seven Russian agents and entities over the Alexi Navalny poisoning. Zagaris discussed a ECtHR\u2019s decision finding Russia responsible for the assassination of Litvinenko and Britain naming a third Russian suspect in the poisoning of Skripal.<\/p>\n

Extraterritorial Jurisdiction<\/em><\/p>\n

Extraterritorial jurisdiction<\/em> remained controversial.\u00a0 Fred Davis discussed the Second Circuit\u2019s decision, opening the door a bit to non-citizen defendants challenging a court\u2019s jurisdiction in criminal cases and also the partial clarification by the Second Circuit of the procedures applicable to prosecution of foreign sovereign owned enterprises.\u00a0 Zagaris discussed Bahrain\u2019s return of a U.S. citizen to the U.S. to face charges of murdering his mother in Bahrain as well as an Italian court\u2019s ordering four Egyptians to stand trial in the kidnapping and killing of an Italian student in Egypt. Zagaris wrote about a Spanish court\u2019s ordering Banco de Chile to set aside $103 million for its role in money laundering from the Pinochet expropriations and about the EU Commission proposals for major revisions in its AML\/CFT laws.<\/p>\n

Recovery and Return of Cultural Property<\/em><\/p>\n

On the recovery and return of cultural property<\/em>, Zagaris discussed the German-Nigeria agreement on the return of Benin bronzes as well as the DOJ forfeiture action for 10th<\/sup> century statute looted from Cambodia, and the return by U.S. Homeland Security of hundreds of looted artifacts to Mali.\u00a0 Adhoob covered the U.S. return of looted artifacts to Iraq stolen after the U.S. invasion as well as the discussion between Met officials and U.S. investigators of returning to Cambodia artifacts stolen from ancient sites.<\/p>\n

Transnational Organized Crime<\/em><\/p>\n

On transnational organized crime,<\/em> Plachta discussed the consequences and prospects for the UN (Palermo) Convention against Transnational Organized Crime on its 20th anniversary.\u00a0 Adhoob discussed the arrest by Italian police of suspected Black Axe members for fraud and other serious crimes.\u00a0 Boggess covered the international dark web bust operation DarkHunTOR following the dark market seizure by U.S. and EU law enforcement.<\/p>\n

On international narcotics enforcement, transnational organized crime and corruption<\/em>, Zagaris wrote about Mexico exonerating its ex-defense chief and enacting a law pausing enforcement cooperation with the U.S.\u00a0 Bannister wrote about the UN Commission on Narcotic Drugs\u2019 vote to remove cannabis from the list of Schedule IV narcotics. \u00a0Zagaris wrote about the U.S. detention of the wife of \u201cEl Chapo\u201d and the guilty plea to violating the Kingpin Act by the daughter of the head of the Cartel Jalisco Nueva Generaci\u00f3n. \u00a0Hill and Hardy discussed a UN report targeting corruption and illicit cross-border finance.\u00a0 Kaufman covered ANOM, a global covert investigation conducted by law enforcement worldwide through an encrypted App, yielding 800 arrests. Zagaris wrote about Mexico\u2019s suit in U.S. court in Florida to recover assets from former security chief linked to the Sinaloa cartel.\u00a0 Adhoob discussed the Italian police\u2019s dismantlement of an international drug trafficking ring operated by the \u2018Ndrangheta mafia clan.<\/p>\n

International Environmental Enforcement<\/em><\/p>\n

With respect to international environmental enforcement<\/em>, Zagaris covered Kenya\u2019s extradition of its citizen for trafficking rhino horns, elephant ivory, and heroin. Byrne discussed illicit ivory trafficking from Angola to Vietnam.\u00a0 Adhoob wrote about the S. African arrest of a hunter for illegal possession of rhino horns. \u00a0Zagaris discussed how U.S. prosecutions of three wildlife trafficking violations show the rising incidence of these crimes.<\/p>\n

Migration Enforcement<\/em><\/p>\n

Migration enforcement<\/em> received significant focus.\u00a0 Byrne discussed the INTERPOL operation targeting human trafficking and migrant smuggling in approximately 24 countries.\u00a0 Adhoob covered the U.S. State Department\u2019s 2021 trafficking in persons report and the impact of misinformation and Covid-19 on human trafficking. Adhoob also discussed a State Department\u2019s lawyer\u2019s resignation due to a Biden Administration policy on asylum Kaufman discussed the 5th Circuit\u2019s decision rejecting the Biden Administration\u2019s efforts to end Migration Protections Protocols.\u00a0 Plachta wrote about the EU\u2019s responses to human smuggling in the Belarus border crisis.<\/p>\n

International human rights and enforcement,<\/em><\/p>\n

With respect to international human rights and enforcement, <\/em>Plachta discussed the EU adoption of Magnitsky-type global human rights sanctions regime. <\/em>\u00a0Magliveras discussed the first application of sanctions under the EU\u2019S Magnitsky Act on Russia. <\/em>Zagaris wrote about Turkey\u2019s arrest of an Iranian dissident\u2019s coinciding with Freedom House\u2019s transnational repression report as well as about the signing by 58 nations of a declaration against arbitrary detention of foreign and dual nationals. Botts wrote about OFAC\u2019s naming three Bulgarians under the Global Magnitsky Act for corruption.\u00a0 Kaufman discussed how events in Haiti and C.A.R. show the threats posed by mercenaries to international peacekeeping.\u00a0 Adhoob covered ECOWAS\u2019 demanding answers in the alleged detention of Mali\u2019s former interim leaders as well as Qatar\u2019s imprisoning a Kenyan for blogging about low-income Kenyan migrants work conditions in Qatar.<\/p>\n

Extradition and Extradition Alternatives<\/em><\/p>\n

Developments on extradition and extradition alternatives<\/em> remained critical.\u00a0 Ramirez and Boggess wrote articles about the extradition of Venezuelan diplomat Alex Saab to the U.S., notwithstanding his claims of diplomatic immunity.\u00a0 Zagaris wrote several articles about the Assange extradition decisions by U.K. courts and the U.S. extradition of the father and son for helping Carlos Ghosn escape from Japan.\u00a0 Zagaris covered the S. African court\u2019s overruling the Justice Minister in ruling the former Mozambique Finance Minister will be extradited to the U.S. rather than Mozambique.<\/p>\n

Nemets discussed how the U.S. Immigration court\u2019s handling of INTERPOL Red Notices<\/em> and diffusions suggests a uniform approach.\u00a0 Estlund and Bromund summarized and assessed the 2019 changes in INTERPOL\u2019s rules on the processing of data.\u00a0 Zagaris discussed the CJEU decision against detention for INTERPOL Red Notice due to ne bis in idem<\/em> (dual criminality).<\/p>\n

International Evidence Gathering<\/em><\/p>\n

With respect to international evidence gathering<\/em>, Jang discussed how the Gupta brothers\u2019 corruption scandal invoked the ratification of a new mutual legal assistance and extradition treaty between S. Africa and the UAE.\u00a0 Adhoob covered the Netherlands\u2019 funding the Iraq UNITAD witness protection program to promote accountability for crimes committed by ISIL.<\/p>\n

Economic Integration and International Enforcement<\/em><\/p>\n

Plachta contributed many articles on economic integration and international enforcement<\/em>, including the European Parliament\u2019s call for improvement of implement and application of the European Arrest Warrant (EAW), and the EU Court of Justice\u2019s rejection of \u201cautomatic refusal\u201d of EAWs issued by Polish authorities. Zagaris discussed the Eurojust\u2019s new funding initiative for joint investigation teams.\u00a0 Scherer discussed the EU whistleblower protection directive the Jonathan Taylor extradition.\u00a0 Plachta covered the adoption by the Council of Europe of a resolution on political responsibility for corruption as well as the European Commission releases of three proposals to strengthen and enhance police cooperation across the EU.<\/p>\n

Maritime Piracy<\/em><\/p>\n

On maritime piracy<\/em>, Scherer discussed the shipping industry task force initiative against maritime piracy in the Gulf of Guinea. Adhoob discussed the Nigerian high court\u2019s sentencing of 10 pirates for the hijack of a Chinese vessel.<\/p>\n

International Tribunals<\/em><\/p>\n

With respect to international tribunals, <\/em>Zagaris discussed the affirmation by the Appeals Chamber of the International Residual Mechanism for Criminal Tribunals of the conviction of Ratko Mladi\u0107\u2019 for genocide, crimes against humanity and war crimes, as well as the closure of the Special Tribunal for Lebanon and how the closure raises questions about international tribunals.<\/p>\n

International Sex Trafficking<\/em><\/p>\n

Mr. Zagaris contributed articles on international sex trafficking, <\/em>especially the U.S. and Canadian charges against the Canadian fashion tycoon Peter J. Nygard.<\/em><\/p>\n

Online Child Sex Exploitation Abuse<\/em><\/p>\n

With respect to online child sex exploitation abuse, <\/em>Zagaris covered U.S. indictments and INTERPOL\u2019s pursuit of international enterprises and individuals involved in online sexual exploitation.\u00a0 He wrote about the EU Justice & Home Affairs Council initiatives on the digital dimension of child sexual abuse.<\/p>\n

Cybercrime<\/em><\/p>\n

Cybercrime <\/em>continued to grow exponentially. Zagaris discussed cooperation between the EU and eight countries in taking down dangerous the malware EMOTET, the DOJ\u2019s participation in global disruption of NetWalker ransomware, and Australia\u2019s extradition of two defendants in an auto-subscribing cyber fraud scheme. \u00a0Zagaris discussed the U.S. indictment against three N. Korean military hackers.\u00a0 Adhoob discussed the imposition by the Biden Administration of sanctions against Russia for alleged election interference and SolarWinds cyber hacks as well as the guilty plea of a crypto expert to assisting N. Korea evade sanctions.\u00a0 Zagaris covered U.S. sanctions against a Russian-owned crypto-exchange for ransomware activities as well as the U.S. indictment and sanctions against Iranians for cyber-enabled disinformation regarding the 2020 Presidential Campaign.\u00a0 Scherer wrote about cases involving the seizing illicit proceeds of and combating ransomware attacks.\u00a0 Zagaris covered the guilty plea by the director and promoter of BitConnect for its participative in a massive fraud conspiracy. Formaggi discussed China\u2019s declaration of all cryptocurrency transactions illegal while the U.S. and EU prepared further crypto regulation.\u00a0 Zagaris discussed the arrests and seizures by 17 countries of alleged ransomware extortionists.\u00a0 Plachta covered the adoption by the Council of Europe of the Second Protocol to the Cybercrime (\u201cBudapest\u201d) Convention.<\/p>\n

International Anti-trust Enforcement Cooperation<\/em><\/p>\n

On international anti-trust enforcement cooperation<\/em>, Zagaris discussed the DOJ\u2019s Antitrust Division summary of its 2020 international achievements.<\/p>\n

Export Control and Econom<\/em>ic Sanctions<\/em><\/p>\n

With respect to export control and econom<\/em>ic sanctions,<\/em>\u00a0Boggess discussed the CEO quitting after the U.S. Commerce Department blacklisted Israeli spyware firm NSO Group. Zagaris wrote about the Mashreqbank settlement with OFAC, the Federal Reserve and NYDFS for violating the Sudan sanctions.<\/p>\n

Illegal, Unregulated, and Unreported Fishing<\/em><\/p>\n

With respect to illegal, unregulated, and unreported fishing<\/em>, Adhoob wrote about Bolivia\u2019s signing an MOU to strengthen compliance\/transparency in the fishing industry.<\/p>\n","protected":false},"excerpt":{"rendered":"

We at the IELR send you the best wishes for a warm and joyous holiday season. \u00a02021 was momentous for the international enforcement community, and we are grateful to have had you following along with our coverage during our 37th year of discussing international enforcement developments. Contributors We are grateful for the continuing long partnership […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_genesis_hide_title":false,"_genesis_hide_breadcrumbs":false,"_genesis_hide_singular_image":false,"_genesis_hide_footer_widgets":false,"_genesis_custom_body_class":"","_genesis_custom_post_class":"","_genesis_layout":"","jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2}},"categories":[247,248,107,79,8,125,23,92,15,33,45,162,71,34,6,70,24,18,78,66,165,102,36,98,62,140,19,60,93,7,153,27,20,12,5,86,88,84,85,21,44,17,75,65,96,9,4,100,115,262,233,83,26,99,46,101,267,3,11,76,82,95],"tags":[],"class_list":{"0":"post-1818","1":"post","2":"type-post","3":"status-publish","4":"format-standard","6":"category-comparativecriminallaw","7":"category-comparativecriminalprocedure","8":"category-convention-on-international-trade-in-endangered-species","9":"category-corruption","10":"category-counterterrorism-and-international-human-rights","11":"category-counterterrorism-enforcement","12":"category-crimes-against-humanity","13":"category-criminology","14":"category-cultural-property-theft","15":"category-cybercrime","16":"category-cybercrime-and-cryptocurrency","17":"category-department-of-justice","18":"category-diplomatic-immunity","19":"category-drug-trafficking","20":"category-economic-sanctions","21":"category-economicintegration","22":"category-election-interference","23":"category-entity-transparency","24":"category-environmental-law","25":"category-europeanhumanrightscourt","26":"category-europol","27":"category-expatriation","28":"category-extradition","29":"category-extraterritorial-jurisdiction","30":"category-foreign-agents-registration-act","31":"category-fraud","32":"category-gatekeeper-obligations","33":"category-genocide","34":"category-human-rights","35":"category-human-trafficking-migration-smuggling","36":"category-illicitfinancing","37":"category-immigration","38":"category-immigration-enforcement","39":"category-international-criminal-court","40":"category-international-tax-enforcement-cooperation","41":"category-international-arms-trade","42":"category-international-cooperation","43":"category-international-evidence-gathering","44":"category-international-human-rights-and-magnitsky-act","45":"category-international-organizations","46":"category-international-tax-regime","47":"category-international-wildlife-trafficking","48":"category-internationalhumanitarianlaw","49":"category-internationalhumanrights","50":"category-interpol","51":"category-law-of-war-and-post-conflict-transitions","52":"category-money-laundering-and-bank-secrecy","53":"category-offshore-voluntary-disclosure-program","54":"category-ounterterrorism-financial-enforcement","55":"category-production-and-use-of-illicit-chemical-weapons","56":"category-ransomware","57":"category-sanctions","58":"category-small-arms-trade","59":"category-tax-controversy","60":"category-tax-crime-enablers","61":"category-tax-expatriation","62":"category-tax-transparency","63":"category-transnational-corruption-money-laundering-and-asset-forfeiture","64":"category-transnational-organized-crime-cybercrime-narcotics","65":"category-universal-jurisdiction","66":"category-war-crimes","67":"category-wildlife","68":"entry"},"yoast_head":"\n2021 Holiday Retrospective | IELR Blog<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/ielrblog.com\/index.php\/2021\/12\/28\/2021-holiday-retrospective\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"2021 Holiday Retrospective | IELR Blog\" \/>\n<meta property=\"og:description\" content=\"We at the IELR send you the best wishes for a warm and joyous holiday season. \u00a02021 was momentous for the international enforcement community, and we are grateful to have had you following along with our coverage during our 37th year of discussing international enforcement developments. 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