Author: gracechurchfcp

Half of crypto ads on Facebook are scams or violate Meta’s policies, consumer regulator alleges

More than half of cryptocurrency-related ads on Facebook analysed by Australia’s consumer regulator were scams or violated Meta’s policies, a court has heard. The Australian Competition and Consumer Commission (ACCC) took Meta to court over celebrity scam ads in 2022, alleging the company had engaged in false, misleading or deceptive conduct in publishing the ads, and aiding and abetting the false conduct by the advertisers. In a ruling issued last week, it was revealed the ACCC has alleged that, since at least January 2018, “Meta has been aware that a significant proportion of cryptocurrency advertisements on the Facebook platform have…

Eurojust supports large-scale anti-mafia operation leading to arrest and freezing of EUR 50 million

An investigation lasting over two years has uncovered an intricate money laundering scheme run by a mafia family from Palermo. The total value of their profits is estimated at over EUR 500 million. They reinvested the profits of their crimes in multiple companies in Brazil. Cooperation between Italian, Brazilian and Swiss authorities led to the arrest of a member of the organised crime group (OCG) during an action day on 13 August, as well as the freezing of financial assets worth EUR 50 million during several searches in Italy, Brazil and Switzerland.To support other major mafia families, the OCG was…

Unraveling the Web: Money Laundering through E-Payments from Russia to the UK

Experts from Transparency International Russia (in exile) have conducted an in-depth analysis of illegal money transfers from Russia to the UK through e-payments over the past decade.This research examines the sophisticated trade of verified business bank accounts, often exploited by criminals to obscure large-scale financial transfers. The investigation highlights significant regulatory gaps and the use of dark web marketplaces where these accounts are sold, often registered under false identities with genuine documents. The study reveals that high-risk profiles, including politically exposed persons (PEPs and complex corporate structures exacerbate these risks.The report identifies several e-payment platforms, which have been exploited for…

Man charged over €6.5m cryptocurrency seizure in Dublin

A man has appeared in court following the seizure of €6.5m (£5.6m) worth of cryptocurrency in County Dublin.The seizure was part of an investigation into the sale of illegal material on darknet markets and money laundering.The 23-year-old man is facing three counts of money laundering.Two other people arrested as part of the police investigation, a 49-year-old man and a 32-year-old woman, have been released from custody. As part of the investigation, the Garda National Cyber Crime Bureau (GNCCB) said they seized “substantial assets” including Bitcoin and Monero, along with watches worth €120,000 (£100,000) and two vehicles valued at €220,000 (£190,000).Kevin…

Illinois judge orders $120 million payment in crypto fraud case

An Illinois district judge has ruled in favor of the U.S. Commodity Futures Trading Commission (CFTC), ordering Oregon resident Sam Ikkurty and his company Jafia, LLC to pay over $120 million, partly in restitution, to victims of what the CFTC described as a “Ponzi”-like scheme. Judge Mary Rowland of the U.S. District Court for the Northern District of Illinois issued the opinion on Monday, which was posted by the CFTC on Wednesday. The ruling stated that Ikkurty and Jafia made “material misrepresentations” and engaged in fraud without proper registration. In a notable part of the order, Judge Rowland classified cryptocurrencies…

SEC hands out $37 million to whistleblower

The Securities and Exchange Commission has awarded a whistleblower with $37 million for providing new and critical information that led to the success of an enforcement action. According to the agency’s order, one whistleblower received the regulatory bounty for information and assistance that led the staff to open the investigation into “hard-to-detect violations.” He was the initial source that alerted the SEC to a previously unknown conduct and thereafter provided assistance that helped advance investigations. Specifically, he gave useful information at the earliest stages of the investigation and later provided supplemental information. Committed to protecting the anonymity of informants, neither…

U.K. Crime Agency Asks Court to Permanently Seize Russian Oligarch’s Money

Britain’s National Crime Agency has for the first time asked a court to permanently seize funds held by a Russian oligarch, arguing that they are “proceeds of crime,” because he allegedly moved the money in violation of sanctions regulations.The agency, known as the NCA, applied on May 1 for a forfeiture order for 1.1 million British pounds (US$1.4 million) from Petr Aven, a billionaire who the U.K. says has “been involved in supporting the Government of Russia” during its war in Ukraine.The money has been frozen since the U.K. sanctioned Aven in 2022. The NCA believes it has now gathered…

Federal Reserve & California Regulators Levy $63 Million in Penalties Against Silvergate for Anti-Money Laundering Violation

The Federal Reserve Board and California’s Department of Financial Protection and Innovation (DFPI) have imposed a combined $63 million in penalties on Silvergate Capital Corporation and its subsidiary, Silvergate Bank, for inadequate transaction monitoring in violation of anti-money laundering (AML) laws. The announcement, made on Monday, July 1, 2024, comes as part of a coordinated effort between federal and state authorities. The penalties break down as follows: $43 million fine from the Federal Reserve Board$20 million payment to the California DFPI$50 million in penalties assessed by the U.S. Securities and Exchange Commission (SEC), offset by the payments to the Federal…

U.S. is seizing Los Angeles mansion from family of Armenian politician accused of bribery

The U.S. is seizing a more than 30,000-square-foot Los Angeles mansion from the family of an Armenian politician, a sprawling estate on the Westside which federal prosecutors allege was paid for with millions of dollars in bribes. The home belonging to the family of Gagik Khachatryan is situated in LA’s Holmby Hills neighborhood, wedged between Beverly Hills and Bel Air, and was estimated by U.S. prosecutors to be worth $63.5 million in May 2022. An updated estimated value of the home was not given Monday. But the American government will sell it off for the “highest obtainable market price” and…

FATF Updates High-Risk and Monitored Jurisdictions List, Reshaping Global Financial Landscape

The Financial Crimes Enforcement Network (FinCEN) has announced significant changes to the Financial Action Task Force’s (FATF) list of jurisdictions with strategic deficiencies in their anti-money laundering, counter-terrorist financing, and counter-proliferation financing (AML/CFT/CPF) regimes. These updates, stemming from the FATF’s June 2024 plenary meeting, are poised to have far-reaching implications for the global financial system and U.S. financial institutions. In a notable shift, the FATF has added Monaco and Venezuela to its “Jurisdictions Under Increased Monitoring” list, commonly referred to as the “grey list.” This designation indicates that both countries have acknowledged deficiencies in their financial crime prevention systems and…

Spanish Court Asked to Fine Duro Felguera €160M in Venezuela Alleged Bribery Case

Spanish anti-corruption prosecutors have asked a court to impose a fine of 160 million euros ($173 million) on the engineering and construction company Duro Felguera S.A., which they allege bribed Venezuelan officials in return for securing a contract to build a power plant.Prosecutors have also requested prison sentences and fines for two of Duro Felguera’s previous presidents, as well as Nervis Villalobos, Venezuela’s former energy vice-minister, according to an indictment seen by OCCRP.“All the commissions paid by ‘Duro Felguera’ were aimed at ensuring the company was privileged both in the awarding of the construction of the thermoelectric power plant and…

U.S. Financial Regulators Propose Sweeping Changes to Anti-Money Laundering Rules

On July 19, 2024, a coalition of U.S. financial regulators unveiled a comprehensive proposal to overhaul anti-money laundering (AML) and countering the financing of terrorism (CFT) regulations for banks and other financial institutions. This joint initiative, led by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC), represents the most significant update to AML/CFT rules in decades. The proposal aims to modernize the…

FinCEN Intensifies Efforts to Combat Fentanyl Trafficking & Money Laundering

The Financial Crimes Enforcement Network (FinCEN) has launched a comprehensive initiative to tackle the twin threats of fentanyl trafficking and money laundering, highlighting the critical role of financial intelligence in combating these interconnected crises. This effort, part of the broader Counter-Fentanyl Strike Force led by the Treasury Department, aims to disrupt the financial networks fueling the devastating opioid epidemic across the United States. At the heart of this initiative is the “Promoting Regional Outreach to Educate Communities on the Threat of Fentanyl” (PROTECT) series, a set of ten planned events across U.S. cities most impacted by the opioid crisis. These…

FCA takes first enforcement action against firm enabling cryptoasset trading

CB Payments Limited (CBPL) has been fined £3,503,546 by the Financial Conduct Authority (FCA) for repeatedly breaching a requirement that prevented the firm from offering services to high-risk customers. CBPL is part of the Coinbase Group, which operates a prominent cryptoasset trading platform that is accessible globally. CBPL does not undertake cryptoasset transactions for customers but it acts as a gateway for customers to trade cryptoassets via other entities within the Coinbase Group. CBPL is not currently registered to undertake cryptoasset activities in the UK. The firm entered into a voluntary requirement (the VREQ) in October 2020, which followed significant…

UK – HMRC criminal investigation into alleged exports of perfume to Russia

In a civil judgment handed down earlier this week, it was revealed (at paragraph 63) that an individual, David Crisp, was arrested by HMRC on 10 October 2023 and electronic devices were seized. The allegation is that companies managed by Mr Crisp were knowingly exporting perfume to Russia in breach of the UK’s sanctions. As of the date of the judgment, HMRC had confirmed (at paragraph 69) that the criminal investigation remains ongoing but so far no charges have been made and Mr Crisp is no longer on bail. The judgment itself is of note for the Court removing Mr…

FCA calls on firms to improve treatment of politically exposed persons (PEPs)

The FCA has told financial firms – including banks, payment firms and lenders – to do more to ensure parliamentarians, senior public servants and their families are not treated unfairly. Under legislation adopted by Parliament, financial firms are required to do extra checks on so-called politically exposed persons (PEPs). This follows global standards set by the international Financial Action Task Force and implemented by more than 200 jurisdictions. There have been concerns about how firms in the UK are meeting these requirements and so the FCA has reviewed how firms are treating PEPs. The FCA found that most firms in…

The Monetary Authority takes disciplinary action against DBS Bank (Hong Kong) Limited for contraventions of the Anti-Money Laundering and Counter-Terrorist Financing Ordinance

The Hong Kong Monetary Authority (HKMA) announced today (5 July) that it had completed an investigation and disciplinary proceedings for DBS Bank (Hong Kong) Limited (DBSHK) under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615 of the Laws of Hong Kong) (AMLO) (Note 1). The Monetary Authority (MA) has imposed a pecuniary penalty of HK$10,000,000 against DBSHK for contraventions of the AMLO.The disciplinary action (Note 2) follows an investigation by the HKMA on DBSHK’s systems and controls for compliance with the AMLO. The control deficiencies identified in the investigation relate to DBSHK’s failure to continuously monitor business relationships and…

The EBA issues ‘travel rule’ guidance to tackle money laundering and terrorist financing in transfers of funds and crypto assets

The European Banking Authority (EBA) issued today new Guidelines on the so-called ‘travel rule’, i.e. the information that should accompany transfers of funds and certain crypto assets. This rule will help tackle the abuse of such transfers for money laundering and terrorist financing purposes. The Guidelines specify which information should accompany a transfer of funds or crypto assets and also list the steps that payment service providers (PSPs), intermediary PSPs (IPSPs), crypto-asset service providers (CASPs) and intermediary CASPs (ICASPs) should take to detect missing or incomplete information, and what they should do if a transfer of funds or a transfer…

Ten years after an ICIJ exposé, Danish authorities charge Nordea bank with money laundering violations

Danish authorities last week indicted Finland-based Nordea, one of Northern Europe’s largest banks, for violating anti-money laundering laws by failing to stop $3.7 billion of suspicious transactions involving Russian clients, shortcomings previously exposed by an International Consortium of Investigative Journalists’ investigation a decade ago. The indictment, by the Danish Special Crime Unit (NSK), covers transactions that took place from 2012 to 2015 and is the result of an investigation that lasted nearly eight years. “Nordea failed to adequately investigate the bank’s Russian customers’ transactions and ignored warnings about transactions to exchange offices in Copenhagen,” the NSK said in a statement.…

StanChart loses bid to cut US sanctions breach claims from UK lawsuit

Standard Chartered on Monday lost a bid to cut from a London lawsuit allegations that it broke U.S. sanctions against Iran in a more widespread way than it has previously admitted. More than 200 investors are suing Standard Chartered at London’s High Court for allegedly untrue statements about its sanctions non-compliance between 2007 and 2019. The lawsuit comes after the London-based bank agreed to pay $1.1 billion in 2019 to U.S. and British authorities over transactions which breached sanctions against Iran and other countries. The 2019 deal extended by two years a 2012 deferred prosecution agreement with Standard Chartered, under…

CFTC Orders Trafigura to Pay $55 Million for Fraud, Manipulation and Impeding Communications with the CFTC

The Commodity Futures Trading Commission today issued an order simultaneously filing and settling charges against Trafigura Trading LLC, a global commodities merchant with its principal place of business in Houston, Texas, for multiple violations of the Commodity Exchange Act (CEA) and associated CFTC regulations. The order requires Trafigura to pay a $55 million civil monetary penalty and implement certain remedial measures to ensure future compliance with the CEA. The order includes three violations:   “As reflected in today’s Order, Trafigura misappropriated material non-public information and engaged in manipulative conduct that affected published benchmark rates,” said Director of Enforcement Ian McGinley.  “This…

FINMA proceedings: HSBC Private Bank (Suisse) SA violated money laundering regulations

HSBC Private Bank (Suisse) SA breached its obligations in the prevention of money laundering in connection with two politically exposed persons and thereby seriously violated financial market law. This was established in the context of enforcement proceedings by the Swiss Financial Market Supervisory Authority FINMA, which has imposed measures to ensure that compliance with the law is restored. The decision orders that, until these measures have been implemented in full, the bank may not enter into any new business relationships with politically exposed persons. In December 2021, FINMA opened enforcement proceedings against HSBC Private Bank (Suisse) SA in connection with…

Drug Traffickers Producing More Cocaine in Europe: EU Report

Some cocaine production has shifted from Latin America to Europe, as criminal groups explore new trafficking methods and authorities boost transatlantic cooperation, according to the latest EU drug report. Both drug seizures and drug use keep increasing in Europe, according to findings published by the European Monitoring Centre for Drugs and Drug Addiction (EMCDDA) on June 11.  “While seizures are up, purity remains high, and prices are stable, showing that huge amounts of cocaine are available,” Ylva Johansson, European Commissioner for Home Affairs, said during the launch of the drug report. Cocaine Production Expands in Europe Traditionally, traffickers turned coca…

Combatting corruption: Council adopts position on EU law

In order to step up efforts in the fight against corruption, the Council today agreed its position on an EU law that sets minimum standards for the definition and sanctioning of corruption offences, preventive measures and rules for more effective investigation and prosecution. The law’s main novelty is that, for the first time at EU level, it brings together in one legal act rules on corruption in the public and private sectors. Paul Van Tigchelt, Belgian Deputy Prime Minister and Minister of Justice and the North Sea Corruption corrodes trust in the public sector, harms the economy and damages the…

‘Sanctions hole’: how secretive routes supply Russia with western tech and consumer goods

Since Vladimir Putin’s invasion of Ukraine, the west has imposed thousands of sanctions on Russia, and handed it the dubious distinction of being the most heavily sanctioned country on Earth. Targeting everything from the finances of individuals to the major industries of its economy, international sanctions have aimed to isolate Russian consumers, with major brands such as Apple and McDonald’s ceasing their operations in the country. But two years on, Russia’s economy is showing surprising resilience and is forecast to grow faster than most of the world’s advanced economies, although experts say that it is unsustainable in the long term.…

Money laundering gang jailed over £1.2m IT fraud

Five people who helped launder the proceeds of a £1.2m computer scam have been jailed. The fraud targeted elderly and vulnerable people, tricking them into paying out thousands of pounds each to fix non-existent IT problems. Between May 2015 and November 2019 the gang transferred £1,289,837 to two brothers based in India, who had been posing as representatives of HP, Microsoft Norton and Epson to defraud their victims. Amanda Grigg, 66, of Truro, Gena Harrington, 39, of Birmingham, Bindu Devasia, 49, of Kent, Nicholas Alcide, 40, of Birmingham, and Jose Kuriakose, 50, of Kent, were sentenced at Leeds Crown Court…

FinCEN’s 2023 Report Highlights Robust Compliance Enforcement and the Power of Financial Data in Fighting Crime

The Financial Crimes Enforcement Network (FinCEN) has released its Year in Review for Fiscal Year 2023, underscoring the critical role of regulatory compliance and enforcement in safeguarding the U.S. financial system. The report showcases how the bureau leverages the Bank Secrecy Act (BSA) data to combat money laundering, terrorism financing, and other financial crimes, while holding non-compliant entities accountable. In FY 2023, FinCEN’s enforcement actions resulted in four civil money penalties totaling $60,780,829. These penalties serve as a stark reminder to financial institutions of the cost of non-compliance with BSA regulations. The message is clear: failure to adhere to reporting…

Moldova Arrests Officials For Helping Criminals Bypass Interpol Red Notices

Moldova detained Tuesday four allegedly corrupt officials tied to an international conspiracy that has allowed criminals to escape Red Notice arrest warrants issued by Interpol. The officials are believed to have accepted bribes totalling several million U.S. dollars in exchange for offering criminals safe harbor in Moldova from Red Notices issued in their names, or for deleting the arrest warrants altogether. Moldova’s Anti-corruption Prosecution Office ordered raids on 33 locations to seek out and detain the suspects, as part of a multilateral investigation that includes federal authorities across the U.K., the U.S., France, and Spain. The conspiracy was revealed by the U.S.…

Singapore Unveils Updated Risk Assessment on Money Laundering

Singapore recently published its updated Money Laundering (ML) National Risk Assessment (NRA). This comprehensive assessment, a collaborative effort involving supervisory and law enforcement agencies, the Suspicious Transaction Reporting Office (STRO), private sector entities, and international counterparts, synthesizes the current ML risks facing the nation. Since the last assessment in 2014, Singapore has been diligently monitoring money laundering risks, conducting thematic assessments on the misuse of legal persons, virtual assets, and environmental crime. These efforts ensure timely identification and mitigation of risks by relevant stakeholders. Exposure Due to Economic Openness Singapore’s status as a global financial center and trading hub exposes it to…

Banana giant held liable for funding paramilitaries

A court in the United States has found multinational fruit company Chiquita Brands International liable for financing a Colombian paramilitary group. The group, the United Self-Defence Forces of Colombia (AUC), was designated by the US as a terrorist organisation at the time. Following a civil case brought by eight Colombian families whose relatives were killed by the AUC, Chiquita has been ordered to pay $38.3m (£30m) in damages to the families. Chiquita said in a statement that it intended to appeal against the jury’s verdict, arguing that there was “no legal basis for the claims”. The jury in the case,…

EU ushers in new anti-money laundering era

The EU is revolutionising its approach to money laundering and the financing of terrorism with the creation of a new bloc-wide body and a raft of new regulations. In a decisive move designed to beef up its defences against the ever-present scourge of , on Thursday (19 June) the European Union unveiled its comprehensive Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) legislative package. The package, which was formally adopted by the European Parliament in May, establishes a new EU Anti-Money Laundering Authority (AMLA) and introduces stricter regulations aimed at enhancing transparency and accountability across the financial system. The new…

Epoch Times CFO charged in $67m money-laundering plot

The chief financial officer of the Epoch Times news outlet has been arrested over his alleged involvement in a massive money-laundering scheme.  Federal prosecutors allege that Bill Guan, 61, participated in a global plot to launder at least $67m (£52m) of illegal cash to benefit himself and the Epoch Times. According to the indictment, Mr Guan led the outlet’s “Make Money Online” team, which used cryptocurrency to purchase tens of millions worth of crime proceeds.  Mr Guan has not yet entered a plea. If convicted, he could spend more than 30 years in prison.  In a statement on Monday evening,…

New UK sanctions to crack down on Putin’s war machine

UK announces 50 new sanctions designations and specifications to degrade Putin’s war machine, in co-ordinated action with G7 partners to support Ukraine.  New targets include ships in Putin’s shadow fleet, institutions at the heart of Russia’s financial system and suppliers supporting Russia’s military production.   These new sanctions, announced while the Prime Minister attends the G7 Leaders Summit in Italy, will bear down on Russia’s ability to fund and equip its war machine and show the UK’s steadfast support for Ukraine. Today’s action includes the UK’s first sanctions targeting vessels in Putin’s shadow fleet, used by Russia to circumvent UK and…

Fiji’s former Prime Minister Frank Bainimarama jailed for a year

Frank Bainimarama, who was Fiji’s prime minister for some 15 years until losing power in 2022, has been jailed for a year after he was found guilty of using his position to shut down a corruption investigation into a prominent university. Once armed forces chief, Bainimarama seized power in a 2006 coup and later won democratic elections in 2014 and 2018. The 70-year-old narrowly lost the December 2022 election to a coalition of parties led by the current prime minister, Sitiveni Rabuka, but remains a popular figure. Outside the court in Suva on Thursday, a crowd of supporters gathered ahead…

Bribery Rocks Russian Defense Ministry, Senior Officials Detained

Russian authorities detained a senior Defense Ministry official, alleging his involvement in a large-scale bribery scheme exceeding 100 million Russian rubles (just over US$1 million), the Russian Investigative Committee stated Tuesday on its Telegram channel.The Main Investigation Department of the Committee (Следственный комитет Российской Федерации – SLEDKOM) said it has opened “a criminal case against the head of the personnel department of the Defense Ministry, Yury Kuznetsov.”“The investigation reveals that between 2021 and 2023, while serving as the head of the 8th Directorate of the General Staff of the Russian Armed Forces, Kuznetsov allegedly accepted bribes from representatives of commercial…

Treasury Unveils 2024 Strategy to Combat Illicit Finance Amid Evolving Threats

The U.S. Department of the Treasury today issued its 2024 National Strategy for Combating Terrorist and Other Illicit Financing, outlining the government’s priorities to disrupt money laundering, terrorist financing, and other financial crimes. The 2024 Strategy provides a comprehensive blueprint to address key illicit finance risks identified in recent national risk assessments, including large-scale fraud, ransomware attacks, the opioid crisis, terrorism, corruption, and exploitation of new financial technologies. “In this critical moment for our national and economic security, we need to continue to close the pathways that illicit actors seek to exploit for their schemes,” Under Secretary of the Treasury…

Singapore Money Laundering Suspects Invested Huge Sums in Dubai Property

Three people arrested in a raid on an alleged money laundering ring in Singapore invested over $30 million in Dubai real estate, leaked data reveals. One of the suspects, who was wanted in China at the time, was behind a property broker that became a major sales agent for the city’s largest real estate developer, part-owned by Dubai’s ruler. Key FindingsSu Jianfeng, in detention in Singapore awaiting trial for charges of money laundering and fraud, is an owner of Dubai-based broker Fidu Properties DMCC. That firm was part of the Fidu Property Real Estate Brokerage, a top partner for Emaar…

Canada’s anti-money laundering agency imposes $6.7 mln fine on TD Bank

May 2 (Reuters) – Canada’s anti-money laundering agency said on Thursday it had imposed its biggest-ever penalty of nearly C$9.2 million ($6.71 million) on TD Bank (TD.TO) The bank has been grappling with regulatory probes over its AML compliance program both at home and in the United States, which have been a drag on the stock’s performance.The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) said the administrative monetary penalty on TD Bank was imposed on April 9 following a compliance examination in 2023. FINTRAC said it found that TD Bank had failed to submit suspicious transaction reports as…

Audit Firm BF Borgers and Owner Charged with Massive Fraud

The Securities and Exchange Commission (SEC) has leveled charges against audit firm BF Borgers and its owner, Benjamin F. Borgers. The SEC alleges “deliberate and systemic failures” by the firm to maintain compliance with the Public Company Accounting Oversight Board (PCAOB) in over 1,500 SEC filings. The SEC’s investigation revealed a pattern of misconduct, including false representations to clients about compliance with PCAOB standards, fabrication of audit documentation, and misleading statements in audit reports included in more than 500 public company SEC filings. As part of the settlement, BF Borgers agreed to pay a substantial $12 million civil penalty, with…

AUSTRAC and SkyCity agree to proposed $67 million penalty

SkyCity Adelaide Pty Ltd (SkyCity) and AUSTRAC have filed joint submissions with the Federal Court of Australia, proposing a $67 million penalty over the casino’s contravention of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). A court hearing has been set down for 7 June 2024, at which Justice Lee will consider the parties’ proposed settlement. While AUSTRAC and SkyCity agree that a $67 million penalty is appropriate in all the circumstances, it is a matter for the court to determine the appropriate penalty. In reaching this agreement, SkyCity has admitted that it operated in contravention of the…