Author: gracechurchfcp

Mastercard Launches Tool to Help Firms Trace Money Laundering

Mastercard is bringing its TRACE financial crime-fighting and anti-money-laundering tool to the Asia-Pacific region. TRACE uses “timely and large-scale payments data from multiple financial institutions” to provide intelligence beyond a “financial institution’s siloed view,” allowing financial crime tracing across payment networks, according to a Thursday (Feb. 13) news release. Consumers and businesses in APAC are increasingly using real-time payments to settle accounts within seconds rather than days, per the release. “However, this speed has also made it a target for money launderers and ‘mules,’ who try to evade detection by moving funds rapidly between multiple accounts,” the release said. “Oftentimes,…

Canadian Businessman Sentenced for Obstruction of Justice for Hiding and Laundering Millions After His 2020 Money Laundering Conviction

Firoz Patel, 50, of Montreal, Canada, was sentenced to 41 months in federal prison today in connection with his efforts to conceal and launder 450 Bitcoin, currently valued at over $43 million, that he hid from the U.S. District Court handling his 2020 conviction and sentencing for conspiring to operate an unlicensed money transmitting business and to commit money laundering. The sentence was announced by U.S. Attorney Edward R. Martin, Jr., HSI Acting Special Agent in Charge Kai Wah Chan of Homeland Security Investigation’s Washington, D.C., Field Office. Patel plead guilty on September 17, 2024, to one count of obstruction…

Guidance on the failure to prevent fraud offence (ECCTA 2023)

Section 199 of the UK’s Economic Crime and Corporate Transparency Act 2023 sets out a corporate criminal offence for failure to prevent fraud. UK Finance has developed financial services guidance on behalf of our members to supplement guidance issued by the Home Office under section 204 of the Act. This UK Finance sector-specific guidance is not statutory guidance and is advisory only. If there is a conflict between this sector-specific guidance and the Home Office guidance, the Home Office guidance will take priority. The document sets out sector-specific guidance for the purposes of interpretation of the failure to prevent fraud…

Former Bangladesh Securities Commission Chair Denied Bail in Corruption Case

A court in Bangladesh denied bail on Thursday to the former head of the country’s capital markets regulator, who is accused of money laundering and receiving $361,000 in bribes. Police arrested Shibli Rubayat ul Islam, the ex-chair of the Bangladesh Securities and Exchange Commission, on Tuesday. A court in the capital, Dhaka, has now ordered him to remain in jail to face further questioning. “The allegations made against him in the case file are baseless,” said Rubayat ul Islam’s lawyer, Borhan Uddin. “The money for which the case has been filed against him is not illegal money. There has been…

Former George W. Bush aide says an Uzbek businessman hired him to lobby for US sanctions on a local business rival

AU.S. political strategist says an Uzbek businessman asked him to lobby for sanctions against a huge cement manufacturer owned by a political and business rival over the business’s alleged Russia links. Stephen Payne, a top partner in Texas lobbying firm Linden Strategies, says that at his Uzbek client’s behest, he briefed Congressman Wesley Hunt, a Texas Republican, last year about possible sanctions violations by the Uzbek cement company, known as the United Cement Group. Payne, a one-time aide to former President George W. Bush, said he and his staff didn’t urge any specific action, but left it to Hunt and…

PNG Central Bank Chief Appointed Amid Money Laundering Investigation

The acting head of Papua New Guinea’s central bank was the subject of a police investigation for suspected money laundering when she was permanently appointed to the position in early 2024, according to court documents obtained by OCCRP. Officers from the country’s National Fraud and Anti-Corruption Director executed a series of searches on the offices of the Bank of PNG (BPNG) in August and September of 2023 as part of inquiries into its then-acting governor, Elizabeth Genia. The documents, from PNG’s National Court, show that Genia lodged a legal challenge later that year that managed to temporarily freeze the probe.…

Romania: EPPO arrests ringleader of €100 million fraud scheme with mafia ties

(Luxembourg, 10 February 2025) – A suspected ringleader of a €100 million subsidy fraud was arrested last week, following an investigation by the European Public Prosecutor’s Office (EPPO) in Bucharest (Romania) into a criminal organisation believed to have mafia ties. According to the investigation, the suspect, an Italian citizen, operated a criminal group dedicated to systematic fraud involving EU funding. He was detained on Tuesday, 4 February 2025, in Bucharest “Henri Coanda” International Airport while trying to flee Romania, and placed in pre-trial detention by the Bucharest Tribunal, on EPPO’s request. Two other suspected members of the criminal organisation were…

EXCLUSIVE: Montenegro Will Extradite Convicted Money Launderer to China

Montenegro will extradite a man convicted in one of Asia’s largest-ever money laundering cases to his native country of China, where he is wanted for allegedly running illegal gambling operations. Wang Shuiming has lost his appeal against extradition from Montenegro, a court in the capital of Podgorica told OCCRP’s local member center, MANS. “The defendant’s attorney filed an appeal against the aforementioned decision, which was rejected as unfounded,” said Ivana Vukmirović, a spokesperson for the Podgorica High Court, in an email. Wang Shuiming was arrested in Singapore in August 2023 for his role in a money laundering syndicate that cleaned…

Germany: EPPO arrests suspect and carries out searches and seizures in €5.8 million VAT fraud involving luxury cars

(Luxembourg, 7 February 2025) – In a VAT fraud probe led by the European Public Prosecutor’s Office (EPPO) in Cologne (Germany), tax and police investigators have carried out six searches, and have seized 40 luxury cars worth around €1.2 million, real estate and €40 000 in cash yesterday. One person was arrested. The investigation, codenamed ´Dutch Windmill`, was initiated in September 2024, based on findings of an ongoing investigation into the sales of used vehicles by the EPPO office in Rotterdam (Netherlands). The total fraudulent turnover of the group behind the scheme is estimated at over €30 million, and the…

Crackdown on Narcos Reveals Alleged Lithuanian Trafficking Group

Key Findings A leaked memo from the Colombian prosecutor’s office reveals an international police operation targeting a drug trafficking ring allegedly spearheaded by Rokas Karpis, who was previously sentenced in New Zealand for drug offences, and another Lithuanian named Virginijus Labutis.The leaked memo reveals law enforcement in Australia and Colombia believed the Lithuanian pair had led a failed operation to smuggle almost 1.5 tons of cocaine across the Pacific on a small sailboat seized in 2017.Labutis was arrested in Colombia in September last year and extradited to Lithuania, then sanctioned — alongside Karpis — by the U.S. three months later.OCCRP…

What Happens When the Fight Against Corruption Hits Pause? The White House Halts FCPA Enforcement

Key Takeaways Executive Order Impact: President Trump’s February 2025 executive order pauses FCPA enforcement for 180 days, giving the DOJ time to review and adjust its approach to tackling international corruption.Business Implications: While the core of the FCPA remains unchanged, the temporary pause could benefit U.S. companies by reducing immediate enforcement risks, though it leaves uncertainty around pending cases.Foreign Competition: Foreign companies, especially those in countries with weaker anti-corruption laws, could benefit from the pause as U.S. competitors receive temporary relief. However, the DOJ may still target foreign firms in key sectors.Compliance and Risk: Businesses should not let the pause…

The Ancient Egyptian Treasures of a German Sailor Who May Not Have Existed

Just after the turn of the 19th century, a German naval officer named Johannes Behrens set off on a winding voyage around the Mediterranean, and beyond. The Bremen-born sailor wasn’t just a military man. He seems to have had an uncanny eye for high-quality antiquities. As he traveled, he bought up remarkable treasures: an intricate Roman silver bowl, exquisite Ancient Egyptian carvings, an ornate Greek mask of bronze. Several were so impressive that they ended up displayed in some of the world’s most prestigious museums. From the Metropolitan Museum of Art in New York to the Louvre Abu Dhabi, spectacular…

Barclays Under Investigation for Gaps in Money-Laundering Oversight

Key TakeawaysFCA Investigation: Barclays is under investigation by the U.K.’s Financial Conduct Authority (FCA) over its money-laundering controls, with the probe focusing on the management of higher-risk customers.Civil Enforcement: The investigation is classified as a civil enforcement action, a common procedure for high-profile institutions, though details about the probe’s scope remain limited.Transparency and Cooperation: Barclays has confirmed full cooperation with the FCA and highlighted its transparency by submitting an annual report to the National Storage Mechanism, offering further public insight into the investigation.Deep DiveBarclays has found itself in the midst of an investigation by the U.K.’s Financial Conduct Authority (FCA)…

Belgium Blocked $270B Due To Russian Sanctions. Much of It Belongs to Unsanctioned Investors.

An attempt by JPMorgan Chase & Co. to convince Belgian authorities to release about $2.4 billion blocked by Russian sanctions collapsed in court last year, according to the verdict obtained by reporters. The funds owed to JPMorgan, the largest bank in the U.S., remain blocked in Belgium. That’s because they are transactions with the Central Bank of the Russian Federation, which the European Union sanctioned in 2022. The court case, which has not previously been made public, highlights a glaring problem with the sanctions regime imposed by Western countries on Russia following its full-scale invasion of Ukraine. Much of the…

When child’s play turns to child’s pay: Almost one million British children were scammed online in the last year

The average financial loss per scam is £103 but the hidden emotional cost is far greater, with parents reporting young people became anxious and couldn’t stop worrying (69%), and nearly a quarter (24%) stopping doing the things they enjoy online.8-in-10 (81%) parents say their children faced long-lasting impacts like anxiety, depression and mood swings after being scammed online.4-in-10 young people say their biggest fear when going online is scammers stealing their personal information, identity or money, but 60% admit they’re not sure where to turn to for help.A fifth of the nation’s teachers have experienced their pupils being scammed online,…

Slapped With Sanctions, Georgian Oligarch Ivanishvili Brings Assets Home

In response to international sanctions, Bidzina Ivanishvili, the billionaire founder and honorary chair of Georgia’s ruling party, has transferred ownership of multiple companies from offshore jurisdictions to Georgia, shielding his assets from global economic exposure. In December, the U.S. sanctioned the powerful tycoon, who is widely seen as the country’s informal ruler, saying he was undermining Georgia’s democracy for the benefit of Russia. Critics accuse the governing Georgian Dream party of becoming increasingly authoritarian and aligned with Moscow, often pointing out that Ivanishvili made his fortune in Russia in the 1990s. On December 31 — just four days after he…

MONEYVAL calls on Guernsey to step up efforts against money laundering

The Council of Europe’s anti-money laundering body, MONEYVAL, has today published a report urging Guernsey to improve the investigation, prosecution and conviction of money laundering offences whilst also highlighting Guernsey’s good understanding of the risks of money laundering/terrorist financing and its highly effective application of targeted financial sanctions.The report commended Guernsey’s Financial Intelligence Unit for producing high-quality analytical products and strategic analysis, while acknowledging the limited extent to which they are used by law enforcement authorities to initiate investigations. The quality of suspicious activity reports also remains a concern.The Guernsey Financial Services Commission and the Alderney Gambling Control Commission have…

‘We Know No Borders’: How Kyrgyzstan Became a Hub for Sanctioned Car Exports to Russia

For a car dealership in a country under sweeping economic sanctions, Moscow-based Berg Auto Premium offers a surprisingly wide selection of luxury vehicles. A Rolls-Royce Cullinan, costing nearly $1 million? They’ve got it. A fresh Tesla Cybertruck? Also in stock. A prestigious Porsche Cayenne Coupé? No problem. “We know no borders,” proclaims the dealership’s website, which claims to have over 100 cars available, collectively worth nearly $17 million. In December, an undercover reporter from OCCRP’s partner IStories called the dealership to ask if she could buy a newly made Porsche 911 Turbo — a car that would presumably be hard…

A smokescreen for secrecy: Why the British Virgin Island’s corporate register reform plans fall flat

Last week, the British Virgin Islands (BVI) unveiled its long-awaited plan for granting access on the ultimate owners of companies registered there – a vital tool to prevent tax abuse and financial crime. Unfortunately, rather than enhancing corporate transparency the BVI’s proposal would effectively block journalists and NGOs from uncovering the true owners of companies, maintaining the region’s long-standing culture of financial secrecy. Despite the UK Parliament mandating UK Overseas Territories like the BVI to reveal the true owner of companies registered on their shores, their proposed register is designed to hinder scrutiny, effectively undermining global efforts to combat money…

Brazilian Cop-Turned-Banker Arrested in Major Money Laundering Bust

Brazilian authorities have arrested a police officer who owns a fintech allegedly used to launder money for the powerful criminal group First Capital Command (PCC). The case highlights the infiltration of organized crime into state structures and exposes regulatory gaps that have allowed fintechs to operate with minimal oversight, facilitating large-scale money laundering. Brazilian authorities said they have detained a police officer who also owned a bank believed to be one of the financial institutions laundering money for a major criminal organization. Brazil’s Federal Police and the Special Action Group for Combating Organized Crime (GAECO) of the São Paulo Public…

OFSI Threat Assessment Reports

The reports listed here are published as part of a series of sector-specific assessments addressing threats and vulnerabilities relating to UK financial sanctions. This follows OFSI’s commitment under the Economic Crime Plan 2 to publish sectoral sanctions threat assessments, intended to assist stakeholders in key UK sectors as part of a broader risk-based approach to sanctions compliance. Financial Services Threat Assessment Report Article Credit: https://www.gov.uk/government/publications/ofsi-threat-assessment-reports

CPI 2024: Highlights and insights

Two of the biggest challenges humanity faces are strongly intertwined: corruption and the climate crisis. While billions of people around the world face the daily consequences of climate change, resources for adaptation and mitigation remain woefully inadequate. Corruption intensifies these challenges, posing additional threats to vulnerable communities. A lack of adequate transparency and accountability mechanisms increases the risk that climate funds may be misused or embezzled. What is more, climate corruption can also take the form of undue influence on decision-makers by polluting industries, and politicians having conflicts of interest because they own shares in oil and gas companies or…

As the Azerbaijani Laundromat scandal reaches German court, will there finally be some accountability?

For an autocracy, maintaining a clean reputation is a Sisyphean task. While the international news cycle moves quickly from one scandal to the next, some stains are not easily erased. Silencing members of the opposition, journalists, academics and other independent voices can provide temporary relief. Regimes that imprison or intimidate dissidents effectively kill two birds with one stone: from behind bars or under serious threat, it is much harder to raise awareness or criticise the wrongdoings of public officials, while at the same time there are fewer people left to tell the stories of those who have been imprisoned for…

Block Faces $175 Million CFPB Order Over Fraud Failures, Following $80 Million State-Led Crackdown

In a world where swiping right or transferring money can be done in seconds, trust is the bedrock of our digital lives. For Cash App users, that trust has been shaken—and regulators are stepping in with a forceful reminder that convenience can’t come at the cost of consumer protection. Today, the Consumer Financial Protection Bureau (CFPB) announced a $175 million settlement with Block, Inc., the parent company of Cash App. The headline is grim: $120 million is set aside to refund users burned by fraud and mishandled disputes, with another $55 million going to a victims relief fund. But the…

Countering Russian sanctions evasion – guidance for exporters

This guidance is intended to support UK exporters in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions. While every effort has been made to ensure the accuracy of the information in this guidance, it does not constitute legal advice and cannot be relied upon as such. It remains the responsibility of UK businesses to fully determine the extent of their specific sanctions risk exposure, and to develop an appropriate set of safeguards and controls tailored to their particular circumstances.  Consulting the external screening databases indicated in this document…

U.S. Transfers $50M in Forfeited Assets to the Republic of Estonia in Recognition of Assistance in the Danske Bank Prosecution and Forfeiture

The Justice Department announced today that it entered into an agreement to share $50 million in forfeited assets with the Republic of Estonia (Estonia) in recognition of Estonia’s assistance in the successful prosecution of Danske Bank and related forfeiture. “Coordinating with our foreign law enforcement counterparts is critical in the fight against complex financial crime — which now, more than ever before, is transnational in nature,” said Principal Deputy Assistant Attorney General Brent S. Wible, head of the Justice Department’s Criminal Division. “Today’s agreement to share $50 million in forfeited funds with Estonia recognizes Estonia’s valuable contribution to the successful…

UK to launch world first sanctions regime to snare people smugglers travelling upstreamhttnce-danske-bank

The UK will develop a new sanctions regime to cripple people smuggling crime rings and starve them of illicit finance fuelling their operations.  The UK will develop a new sanctions regime to cripple people smuggling crime rings and starve them of illicit finance fuelling their operations.  In a major speech tomorrow, the Foreign Secretary will reveal plans to bring forward legislation for a new sanctions regime targeting irregular migration and organised immigration crime to secure UK borders in a decade of national renewal.    As the world’s first standalone sanctions regime dedicated to targeting irregular migration and organised immigration crime,…

Chancellor Rachel Reeves could use £5billion of Bitcoin seized from money-laundering probe into Chinese fraudster to plug economic black hole

Rachel Reeves is sitting on a £5billion windfall of Bitcoin seized from organised criminals that could now be used to plug the huge black hole in her budget. The Mail on Sunday has learnt the Government has amassed an astonishing stash of crypto-currency after a money-laundering probe into a Chinese fraud led to one the world’s biggest ever seizures. Valued at an estimated £5.2billion, the seized Bitcoin was last night described as a ‘get out of jail free card’ for the embattled Chancellor amid fears that Britain faces an ‘economic doom loop’. Crucially, the sum is worth more than the…

France deepens probe into Binance over alleged ML

French authorities have announced their decision to extend the 2023 investigation into Binance, over alleged money laundering accusations. Following this announcement, the French authorities have deepened their investigation into Binance on suspicion that a large cryptocurrency exchange broke European money laundering and terrorist financing laws. The public prosecutor also mentioned that it had opened a judicial investigation into Binance as it was likely to have assisted in habitual money laundering, in particular drug trafficking and tax fraud. The potential offenses were committed in the region of France, but also in all countries of the European Union. France deepens probe into…

Biggest fraud crackdown in a generation

Welfare fraudsters who cheated the taxpayer out of £7 billion last year could be banned from driving if they repeatedly fail to reimburse the public and repay their debt.  Welfare fraudsters who cheated the taxpayer out of £7 billion last year could be banned from driving if they repeatedly fail to reimburse the public and repay their debt. As part of new legislation set to be introduced in Parliament today to deliver the biggest fraud crackdown in a generation, benefit cheats could be disqualified from driving for periods of up to two years if they refuse all opportunities to repay…

£1 million fraud at Aberdeen City Council sends a warning across local government

All Scottish councils must learn from the weaknesses that allowed an Aberdeen City Council employee’s £1.1 million fraud go undetected over 17 years. Between 2006 and 2023, the employee transferred 655 council tax refund payments totalling £1.109m into his own bank account. Another staff member acted swiftly and alerted senior colleagues when they became suspicious in September 2023. The council expects to be able to recover the lost funds, with no loss to the taxpayers whose accounts were affected. But the Accounts Commission is concerned that whilst the council had a system of controls in place, these were not adhered…

Two Robinhood Broker-Dealers to Pay $45 Million in Combined Penalties for Violating More Than 10 Separate Securities Law Provisions

Washington D.C., Jan. 13, 2025 —  The Securities and Exchange Commission today announced that broker-dealers Robinhood Securities LLC and Robinhood Financial LLC (collectively, Robinhood) have agreed to pay $45 million in combined civil penalties to settle a range of SEC charges arising from their brokerage operations. “It is essential to the Commission’s broader efforts to protect investors and promote the integrity and fairness of our markets that broker-dealers satisfy their legal obligations when carrying out their various market functions,” said Sanjay Wadhwa, Acting Director of the SEC’s Division of Enforcement. “Today’s order finds that two Robinhood firms failed to observe…

Global Cryptocurrency Exchange BitMEX Fined $100 Million For Violating Bank Secrecy Act

Company Willfully Flouted U.S. Anti-Money Laundering Laws to Boost Revenue Matthew Podolsky, Attorney for the United States, Acting under Authority Conferred by 28 U.S.C. § 515, announced that HDR GLOBAL TRADING LTD., a/k/a “BITMEX”, was sentenced today to a fine of $100 million for violating the Bank Secrecy Act by willfully failing to establish, implement, and maintain an adequate anti-money laundering (“AML”) and know-your-customer (“KYC”) program. Attorney for the United States Matthew Podolsky said: “Anti-money laundering and know-your-customer rules protect Americans from fraud, combat money laundering, and prevent the financing of terrorist activity. It is critical that all financial institutions,…

Greentube Alderney Limited to pay £1m for regulatory failures

Online gambling business Greentube Alderney Limited, trading as Admiral Casino, is to pay £1 million after a Commission investigation revealed social responsibility and anti-money laundering failures. The operator, which runs admiralcasino.co.uk, will pay the money to socially responsible causes as part of a settlement with the Commission. Social responsibility failures included: Anti-money laundering failures included: This is the second time Greentube has faced regulatory action – in 2021 the operator paid out £685,000 after a Commission investigation revealed social responsibility and money laundering failures. John Pierce, Commission Director of Enforcement, said:  “This case arose from a follow-up compliance assessment designed to ensure the operator…

UK anti-corruption minister resigns amid Bangladeshi corruption probe into her family

Britain’s anti-corruption minister resigned Tuesday following intense media scrutiny over whether she benefited financially from her relationship with her aunt, former Bangladeshi Prime Minister Sheikh Hasina, as well as a flurry of reporting about how London properties she lived in were paid for. Tulip Siddiq had served as the economic secretary to the U.K.’s Treasury after the Labour Party came to power last July. Hasina, whose government collapsed last August after mass student-led protests, is currently the subject of an ongoing embezzlement probe in Bangladesh. In December, Siddiq was named alongside her family in the inquiry and has denied wrongdoing.…

Crypto ‘Laundromat’ Tied to Russian Financial Sector and Cocaine Trade – Police

An international money-laundering ring run out of Moscow and Dubai has been moving billions in cryptocurrency and hard cash for criminal operations, ranging from Russian ransomware attacks to street-level drug deals in the U.K., Britain’s National Crime Agency (NCA) said Wednesday. Several alleged key figures in the money-laundering ring, which the NCA said had “multiple links to the Russian financial sector,” were sanctioned by the U.S. also on Wednesday. They included George Rossi, the Russian-born Ukrainian founder of the TGR group of companies, one of two “criminal enterprises” allegedly running the network. The other group, Smart, was led by Russian…

McKinsey Africa to Pay $122 Million Over Bribery Scheme Involving South African Officials

McKinsey & Company Africa (Pty) Ltd (McKinsey Africa) will pay $122 million to resolve charges of bribing South African government officials in a years-long scheme. The U.S. Department of Justice (DOJ) announced the settlement as part of a coordinated effort with South African authorities, underscoring the growing international push against corporate corruption. Between 2012 and 2016, McKinsey Africa partnered with South African consulting firms to pay bribes to officials at Transnet and Eskom, the state-owned entities responsible for managing South Africa’s infrastructure and energy. These bribes granted McKinsey Africa access to confidential information, helping the firm secure lucrative consulting contracts.…

Senators Demand Accountability from TD Bank Executives as Insider Arrested for Money Laundering

Senators Ron Wyden (D., Ore.) and Elizabeth Warren (D., Mass.) are turning up the heat on TD Bank, demanding answers about what its executives and employees knew regarding a sprawling money-laundering operation. This operation, spearheaded by Da Ying Sze—a Queens-based individual—funneled more than $470 million from drug sales through the bank. The senators’ inquiry, detailed in a letter to TD Bank CEO Bharat Masrani, signals ongoing scrutiny despite October’s record-breaking $3 billion settlement with the Justice Department. The senators’ letter, obtained by The Wall Street Journal and dated Monday, presses TD Bank to disclose internal knowledge and accountability for the…

EBA Finds Gaps in Combating Money Laundering & Terrorist Financing, Despite Significant Progress

The European Banking Authority (EBA) has unveiled the results of its fourth and final round of reviews, examining how competent authorities across 30 EU/EEA member states are tackling the ever-present risks of money laundering and terrorist financing (ML/TF) in the banking sector. With this report, the EBA has completed its comprehensive assessment of the authorities responsible for AML/CFT supervision, offering a detailed snapshot of the progress made—and the work that remains. Authorities have come a long way since the first round of reviews in 2018. The EBA’s findings point to meaningful steps taken towards implementing a more risk-based approach to…

Violent Albanian criminal group linked to corruption disrupted via SKY ECC analysis

On 25 November, Albanian authorities, with the support of Europol, took enforcement actions against 21 individuals, including a former judge, a lawyer a police officer, and two investigative journalists as part of a corruption investigation linked to a high-risk criminal organisation. Over the course of the investigation, an arrest was made in Milan, Italy, thanks to swift operational coordination among the countries involved.The operation, supported by Europol, was launched after the analysis of encrypted communications from the SKY ECC communication platform revealed extensive evidence of corrupt practices, including organised and serious crimes. The suspects are alleged to have played key…