#National Crime Agency and Revenue and Customs
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beardedmrbean · 8 months ago
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Bulgarian President Roumen Radev has signed the decree making personnel changes to the Cabinet of caretaker Prime Minister Dimitar Glavchev, less than two weeks after the caretaker government took office.
In a short statement on April 22, the president’s media office said that Radev issued the decree based on the requests made by Glavchev.
Glavchev will assume the foreign affairs portfolio in addition to his duties as caretaker Prime Minister, replacing Stefan Dimitrov, and Georgi Takhov will be the new agriculture minister in place of Kiril Vatev.
After Glavchev’s initial nominee to take over as Foreign Minister, GERB deputy leader Daniel Mitov, withdrew before the weekend, the caretaker Prime Minister nominated himself for the job.
Radev, who had described the proposal as “avant-garde” at the weekend, was due to meet with Glavchev on April 22 to discuss the proposed changes to the caretaker Cabinet’s line-up.
However, the meeting did not take place, with media reports saying that Glavchev decided against it. Instead, the caretaker PM made a formal request to be appointed caretaker Foreign Minister.
This is the latest in a number of changes executed by the caretaker government.
Its first act after taking office on April 9 was to request President Roumen Radev to decree the dismissal of Zhivko Kotsev from the post of Interior Ministry chief secretary. Radev signed the decree the following day.
On April 17, prosecutors charged Kotsev with alleged participation in an organised crime group along with former Customs Agency head Petya Bankova and business people Stefan and Martin Dimitrov.
Bankova, also earlier dismissed by the caretaker government, faces an additional charge of coercion. All the accused deny wrongdoing, and critics have claimed that the steps against them are politically-motivated.
National Revenue Agency deputy head Georgi Dimov was appointed to head the Customs Agency.
The first changes to deputy ministers came on April 10 when Glavchev appointed Metodi Metodiev, Stefan Belchev and Martin Danovski as deputy ministers of finance.
On April 10, caretaker Regional Development and Public Works Minister Violeta Koritarova fired Yassen Yordanov as head of the Road Infrastructure Agency after an internal audit found allegedly illegal actions.
April 11 saw the caretaker government dismiss Petar Petrov as deputy head of the State Agency for National Security. Petrov had been appointed to the post in July 2023 in the first month in office of the Nikolai Denkov government.
On April 12, Spaska Kincheva was appointed deputy minister of justice, while Emil Dechev and Yuliya Kovacheva were dismissed from their deputy ministerial posts at the ministry.
The same day, Stoyan Temelakiev and Tony Todorov were appointed to replace Kiril Tsenkin and Ivelina Dundakova as deputy interior ministers.
Also on April 12, Tihomir Stoychev and Elena Shekerletova were dismissed as deputy ministers of foreign affairs. Maria Angelieva and Colonel Nevyana Miteva, a former vice presidential candidate on the GERB ticket that was headed by Atanas Gerdzhikov in Bulgaria’s 2021 presidential elections, were appointed to replace them.
April 12 also saw Koritarova fire Delyana Panayotova as acting head of the National Construction Control Directorate, replacing her with Lilyana Petrova. Panayotova became acting head of the directorate in August 2022, replacing Petrova, who had held the post from December 31 2021.
On April 16, Glavchev dismissed Vladya Borissova as head of the Patent Office. Borissova had held the post since June 2021, when she was appointed by the Stefan Yanev caretaker government. Olya Dimitrova was named as her replacement.
The same day, David Sukalinski was appointed deputy minister of economy and industry and Ivan Kapitanov as deputy minister of agriculture and food. Alexander Yotsev and Georgi Toshev, respective holders of those posts, were dismissed.
On April 17, it was announced that Denitsa Zlateva had resigned as chief executive of Bulgargaz. The Bulgarian Energy Holding appointed Vesselin Sinabov in her place. In 2017, Zlateva was caretaker deputy prime minister in the Ognyan Gerdzhikov interim administration and is a former Bulgarian Socialist Party MP. She was appointed Bulgargaz chief executive in August 2022.
Dimitar Spassov and Tatyana Petrova-Boyadzhieva were dismissed from Bulgargaz’s board, and Mihail Milkov, Byanka Racheva and Marin Filipovski appointed to it.
On April 19, the caretaker government appointed Maria Neikova as district governor of Bourgas, dismissing Plamen Yanev from the post. Neikov has held the post twice before, from May 2021 to January 2022 and from August 2022 to July 2023, both times as the appointee of caretaker governments. Yanev was appointed by the Denkov government in July 2023.
Also on April 19, Martin Gikov was dismissed as deputy minister of innovation and growth, Nikolai Sidzhimov as deputy minister of environment and water, Nikolai Naydenov and Ginka Mashova as deputy ministers of labour and social policy, Viktor Stoyanov as deputy culture minister and Marieta Georgieva as deputy minister of education and science.
That day, six deputy ministers were appointed: Boiko Penkov and Dobromira Kareva as deputy ministers of health, Ilko Ganev deputy minister of culture, Pavlin Petrov deputy minister of tourism, Viktor Atanasov deputy minister of environment and water and Georgi Samandov as deputy minister of energy.
And on April 22, Finance Minister Lyudmila Petkova appointed Georgi Yordanov as the director of the Public Financial Inspection Agency. Yordanov, who was chief of staff to former GERB Finance Minister Vladislav Goranov between 2014 and 2020, replaced Ilka Dimova, who had been in office since February.
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dibyamendali · 21 days ago
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The Directorate of Revenue Intelligence (DRI) celebrated its 67th Foundation Day on December 4, 2024. Established in 1957, DRI is India's premier intelligence and enforcement agency under the Central Board of Indirect Taxes and Customs (CBIC). It plays a crucial role in combating smuggling, customs duty evasion, and related economic offenses.
To mark the occasion, the agency hosted the 9th Regional Customs Enforcement Meeting (RCEM), bringing together representatives from international organizations like the United Nations Office on Drugs and Crime (UNODC) and the International Narcotics Control Bureau (INCB). DRI also released its annual "Smuggling in India Report 2023-24," highlighting its achievements, including seizures and enforcement trends.
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How to Buy 1kg Tobacco Online in Australia
Tobacco prices in Australia are high, influenced by heavy taxation and strict regulations. These include plain packaging and health warnings. The Australian government’s Illicit Tobacco Taskforce combines the expertise of multiple departments to combat illegal 1kg tobacco Australia and online sales.
If you want to import prohibited tobacco products into Australia, you must obtain a permit and pay the relevant duty. You must also comply with Customs rules.
High prices
Tobacco products are expensive in Australia due to high tobacco taxes. This is intended to discourage smoking, especially among young people and low-income individuals. Smoking-related illnesses are costly to public health, so preventing the spread of the habit is a priority. In addition, smoking-related costs place a strain on healthcare infrastructure, including hospitals and doctors.
The price of cigarettes varies significantly depending on brand, type and location. However, working out the actual prices paid for tobacco can be difficult because information on sales is not collected by most governments. In most cases, information on the prices of tobacco is only available from wholesalers and retailers, although some smokeless tobacco products are sold to Australian consumers through online vendors. These websites must be registered with the Therapeutic Goods Administration (TGA) and be approved for sale in Australia. They must also be accompanied by an import permit. This is a requirement of the Australian Customs and Border Protection Service.
Strict regulations
Tobacco products are heavily regulated in Australia. They are not allowed to be shipped through the international mail and must arrive by air or sea cargo. Tobacco products that do not arrive by cargo are considered prohibited imports and can only be imported under strict conditions. These conditions include an import permit issued by the Australian Border Force (ABF).
This section uses tobacco price data from the National 1kg tobacco Traders
Association’s publication Australian Retail Tobacconist to examine changes in prices over time. It also relies on data from national surveys of smokers about the types of cigarettes they smoke and their reported prices paid.
Tobacco excise rates have been increasing progressively since late 1999, as shown in Figure 13.6.1. These increases have been in addition to routine indexation. They are due to major policy reforms and include an increase in the equivalisation weight on 1 December 2013, and annual increases of 5% starting from 2023.
Illicit trade
The illegal trade of cigarettes and vaping products undermines the legitimate business of honest retailers. It also deprives the community of revenue that could otherwise be used for essential services and creates an unfair advantage for rogue operators. This is why state and federal law enforcement agencies work together to combat illicit tobacco and vaping.
The Illicit Tobacco Taskforce combines Commonwealth and state law enforcement and border security agencies. This allows them to identify and disrupt serious organised crime syndicates. They use their profits to fund lavish lifestyles and link into other illegal activities, including drug supply.
Criminals are targeting the sale of illicit tobacco and vaping products because it is a lucrative market. These syndicates are using their profits to finance other illegal activities, such as drug distribution and gambling venues. They are able to exploit consumers’ desire for cheaper, untaxed goods by producing cheap, low-quality brands. This gives them an edge over legitimate tobacco and vaping retailers who pay excise duties on their product.
Age verification
A robust age verification process is a key component of online sales for tobacco and other age-restricted products. It protects vulnerable individuals from the dangers of underage tobacco use and demonstrates your commitment to responsible business practices. Additionally, it helps you maintain compliance with state and federal laws regarding tobacco sales.
The age verification process involves requesting and verifying an individual’s proof of age before making a sale. This is usually done by asking for an approved photo ID and cross-referencing it with reputable databases to ensure the authenticity of the document.
As technology evolves, so too will age verification techniques. For example, facial recognition and voice analysis are becoming increasingly common, while DNA testing is now possible. These advances can help you stay ahead of the curve and prepare for any potential changes in tobacco sales regulations. You may also want to consider implementing a detailed record-keeping system to track your sales and age verification checks.
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aalawsng · 2 months ago
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Compliance Expectations for an ICT Company in Nigeria
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With continuous technological advancement, technology development companies are evolving, especially in the Nigerian tech scene. This article explains the registration and compliance expectations for an ICT company in Nigeria.
1. Registration Steps
To start a technology development company in Nigeria, the company must register with the Corporate Affairs Commission (CAC). The CAC regulates company incorporation, operation, and dissolution under CAMA 2020.
Key Registration Requirements:
Companies must file annual returns and audited accounts annually, demonstrating continued operation and updating CAC records.
A new company must hold its first Annual General Meeting (AGM) within 18 months of incorporation and subsequently every year. Failure to comply can result in penalties and removal from the CAC database.
Available business formats include limited liability company (LTD), partnership, or sole proprietorship. The right structure depends on various factors, including size, tax consequences, and liability protection.
In addition to CAC registration, an ICT company must also register with the following:
Federal Inland Revenue Service (FIRS): Register for a Tax Identification Number (TIN) and Value Added Tax (VAT). The TIN allows the company to file tax returns via TaxProMax, the FIRS electronic tax platform.
National Information Technology Development Agency (NITDA): ICT companies must register with NITDA, which governs Nigeria’s IT ecosystem. Key requirements include adopting a .ng domain name and having a standardized service level agreement (SLA). NITDA also outlines specific fees and other compliance conditions.
Special Control Unit Against Money Laundering (SCUML): ICT companies handling financial transactions must register with SCUML to prevent financial crimes.
Bureau of Public Procurement (BPP): ICT companies intending to provide services to government entities must register with the BPP.
Computer Professional Council of Nigeria: At least one principal officer or a corporate representative must be registered with the Computer Professional Council of Nigeria.
2. Compliance Requirements
Intellectual Property Protection
The foundation of a company's technological development is its Intellectual Property (IP). Protecting IP through patents, trademarks, and copyrights is essential for maintaining a competitive advantage. The Nigerian Copyright Commission (NCC) oversees this registration process. Companies should establish guidelines for IP ownership and protection, educate staff about its value, and conduct routine audits.
Tax Registration and Compliance
Obtaining a Tax Identification Number (TIN) from the Federal Inland Revenue Service (FIRS) is essential. ICT companies must register within six months of establishment to remit Companies Income Tax (CIT) and VAT. The TIN is a unique identifier for all registered Nigerian taxpayers and must appear on all business invoices.
Key Tax Compliance Requirements:
Companies must use their TIN to file and pay corporate income tax.
Failure to register can hinder withholding tax from foreign partners and prevent filing tax returns or obtaining Tax Clearance Certificates (TCCs).
Engaging certified tax professionals can assist with navigating tax compliance.
Data Protection Regulation (NDPR)
To secure user data and privacy, ICT companies must comply with the Nigeria Data Protection Regulation (NDPR) and implement data protection policies to prevent breaches. The National Information Technology Development Agency (NITDA) governs the electronic data ecosystem and ensures NDPR compliance.
Key Data Protection Requirements:
Businesses must adopt robust cybersecurity measures.
Regular staff training on data governance is recommended.
Cybercrimes (Prohibition, Prevention, etc.) Act mandates that companies retain customer data for at least two years.
Technology Transfer (NOTAP Act 2004)
The National Office for Technology Acquisition and Promotion (NOTAP) ensures proper registration of agreements for transferring foreign technology. Failure to register or submitting false returns can result in personal liability for company officers.
Employee Relations
Tech firms must adhere to Nigerian labor laws, ensuring compliance with employment contracts, benefits, and workplace safety regulations as outlined in the Labour Act, 2004.
Anti-Money Laundering (AML) and Know Your Customer (KYC)
Companies handling financial transactions must adhere to AML and KYC regulations to prevent money laundering and ensure client identification.
Consumer Protection and FCCPC
ICT companies must comply with the Federal Competition and Consumer Protection Act (FCCPA) 2018, which established the Federal Competition and Consumer Protection Commission (FCCPC). The FCCPC enforces consumer protection and competition laws across all sectors, including ICT.
Key Points on Consumer Protection:
The FCCPA ensures fair trading practices and prohibits anti-competitive behavior, such as price-fixing and monopolies.
Companies must provide transparent and accurate information about their products and services, ensuring consumers’ rights to fair treatment and protection from exploitation.
Violations can lead to penalties, sanctions, or legal action.
References
Section 237 CAMA 2020
https://ncc.gov.ng/
https://www.oecd.org/
https://apps.firs.gov.ng/
Section 6 NOTAP Act 2004
Labour Law 2004
Written By
Aviel Avenante Law Practice
Compliance with regulations is key to sustainable growth. This guide covers all you need to know about the requirements for registration, taxation, data protection, and more for an ICT company!
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bilsmodias · 3 months ago
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Bilsmod IAS:- Top Government Positions You Can Get Through UPSC Exam
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UPSC exam is a very high-level civil service exam which is different from other competitive exams. By clearing this exam, you can make a big change in your career. In this job, you will get a chance to do respectable social work and serve your country. It opens the gateway to some of the top government posts, which not only provides a job but also a platform to serve the nation. Let's take a look at the top government posts you can get through UPSC Civil Services Exam:
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Indian Administrative Service (IAS)
It refers to The Indian Administrative Service (IAS) as the most attractive service in the UPSC. An IAS officer plays an important role in the administration of both the central and state governments. They are responsible for policy implementation, administrative functions, and establishing law and order. An IAS officer can work as a District Collector, Chief Secretary, Cabinet Secretary, and more. The position imparts great authority, respect, and the opportunity to drive socio-economic development in the country.
 Indian Police Service (IPS)
As we know The Indian Police Service (IPS) refers to another respected service that deals with the internal security and law implementation of the country. IPS officers hold explanation positions in police departments and intelligence agencies such as the Central Bureau of Investigation (CBI) and the Intelligence Bureau (IB). Their responsibilities include crime prevention, investigation, and maintaining public peace. They can also serve as Police Commissioners or Director Generals of Police, contributing to the nation’s security framework.
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 Indian Foreign Service (IFS)
The Indian Foreign Service (IFS) is perfect for those who desire to represent India at the international level. IFS officers are responsible for being in charge of foreign relations, representing India abroad, and dealing with international issues. They serve as diplomats in Indian embassies and consulates and can rise to positions like Ambassador or High Commissioner. The role involves frequent postings abroad and interaction with foreign dignitaries.
Indian Revenue Service (IRS)
The Indian Revenue Service (IRS) is divided into two branches: Income Tax and Customs & Central Excise. IRS officers play a significant role in the management and collection of direct and indirect taxes. They help in the formulation of tax policies and can serve as Chief Commissioner of Income Tax or member of the Central Board of Direct Taxes (CBDT). Their work is crucial for the country's financial management and economic stability.
If you are preparing for CUET then, you can check us as the Top CUET Coaching in Patna.
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References:-
Bangladeshi crisis and foreign policy
7 Tips to Improve Your UPSC Interview Preparation For Sure Success
The Evolution and Influence of Renewable Energy
Unique Sports from Every Corner of the Globe
Mastering The Art Of Essay Writing in UPSC Mains Exam
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wholesaletobaccoaustralia · 11 months ago
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Why Buy Tobacco Online?
Tobacco store online offer a number of benefits including competitive pricing and secure payment options. They also allow customers to explore a wider selection of products.
Travellers (including relevant overseas travellers and aircraft or ship crew) can import tobacco duty free if they comply with customs requirements. Duty must be paid on any quantity brought in above the duty free allowance.
Convenience
Purchasing tobacco products online can offer convenience by eliminating the need to travel to a brick-and-mortar store. Moreover, you can browse a wider selection of products on an internet retailer’s website. This includes rare or hard-to-find items. This way, you can find the perfect product that fits your needs and tastes.
Buying tobacco online can save you money, too. Some websites provide a buy two, get one free offer or other discounts that can greatly lower the cost of your favorite buy cigarettes online. In addition, some sites offer free shipping on all orders, further reducing your overall costs.
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Illegal tobacco smuggling is a serious crime that can undermine the health of Australians and deprive governments of revenue needed for essential community services. The Government has formed a Black Economy Taskforce to combat illicit tobacco. This taskforce brings together Commonwealth and state law enforcement agencies to proactively detect, disrupt and dismantle major organised crime syndicates in the illicit tobacco industry.
Variety
A tobacco store online often offers a much wider selection of cigarettes than physical stores, which is a huge benefit for those who like to try out different types and brands. Moreover, many online stores provide special deals and discounts for customers who purchase large quantities of their favourite products. This makes them a convenient and cost-effective choice for smokers. Besides, online stores are also discreet and secure, which is ideal for people who do not want to go out in public purchasing their tobacco products. They also allow for easy and fast delivery.
THIS SITE IS FOR ADULT SMOKERS OVER THE AGE OF 18 ONLY!
Value
One of the best reasons to buy tobacco online Australia is that it can save you money. This is because cigarettes are often more expensive in brick and mortar stores. Also, many websites offer special discounts on certain brands. In addition, it is possible to find rare or hard-to-find tobacco products that may not be available in your local area.
Illicit tobacco sales are a serious criminal issue that diverts billions in much needed tax revenue from the Government to support organised crime syndicates and undercuts legitimate retailers. A national approach, including the introduction of a form of retail licensing and a supply chain oversight regime would help to address these issues.
Retailers who sell illicit tobacco are most likely to be located in low socio-economic status areas. An audit of 122 retail stores in NSW found that retailers from these areas were significantly more likely to be unlisted and breach in-store retailing laws. This could be addressed through a fully-fledged licensing system that charges fees to cover the costs of regular compliance audits of mailing lists, or a more robust air and sea cargo shipping protocol that requires full identification of all points of entry into Australia.
Security
The Tobacco Market Australia buy tobacco online offers customers a secure and discreet purchasing experience. They also offer competitive pricing and shipping options, and their payment system is encrypted to ensure the security of your personal information.
Illegal tobacco smuggling is fueling organised crime, senior border security officials say. It is a serious tax avoidance issue that is causing huge losses in funding for essential services, and diverting billions of dollars in tax revenue to criminal syndicates.
Tobacco products must be sold in plain packaging under the Tobacco Plain Packaging Act 2011. They may not be imported by post and if they arrive as prohibited imports the Australian Border Force will seize them and destroy them. This includes 'heat-not-burn' tobacco products (IQOS and heat sticks).
BATA supports any measures that can help law enforcement personnel easily identify illegitimate retailers, including a national licensing or supply chain oversight approach. We would welcome the opportunity to discuss with the Government any ways in which this might be implemented.
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danieldavidreitberg · 1 year ago
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Can AI Help End the Illicit Tobacco Trade?
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The illicit tobacco trade is a global scourge, costing governments billions of dollars in lost revenue and fueling organized crime. It's estimated that one in ten cigarettes smoked worldwide is illegal, and the problem shows no signs of slowing down. But in the fight against this shadowy industry, a new weapon has emerged: artificial intelligence (AI).
The Scope of the Problem
The illicit tobacco trade is a complex web involving criminal organizations, corrupt officials, and counterfeiters. They operate across borders, exploiting loopholes in regulations and using sophisticated methods to evade detection. The consequences are far-reaching, impacting public health, national security, and economic development.
Health Risks: Illicit cigarettes often contain higher levels of harmful chemicals than legal ones, posing a significant health risk to smokers.
Lost Revenue: Governments lose billions of dollars in tax revenue from the sale of illegal tobacco, hindering their ability to fund essential services.
Organized Crime: The illicit tobacco trade is a major source of income for criminal organizations, fueling other illegal activities like human trafficking and drug smuggling.
Enter AI: A Powerful Tool for Tackling the Illicit Trade
AI offers a range of capabilities that can be harnessed to combat the illicit tobacco trade:
Data Analysis: AI can analyze vast amounts of data from sources like customs records, financial transactions, and social media to identify patterns and anomalies indicative of illegal activity. This can help authorities pinpoint smuggling routes, track criminal networks, and predict future trafficking attempts.
Image Recognition: AI-powered image recognition software can be used to scan shipping containers, warehouses, and retail outlets for counterfeit cigarettes. This can automate the detection process and significantly improve efficiency.
Risk Assessment: AI can analyze risk factors associated with different individuals, businesses, and shipments to identify those most likely to be involved in the illicit trade. This allows authorities to focus their resources on high-risk targets.
Predictive Analytics: By analyzing historical data and current trends, AI can predict where and when the next smuggling attempt might occur. This allows authorities to be proactive and deploy resources to prevent it.
Examples of AI in Action
Several countries are already using AI to combat the illicit tobacco trade. For instance:
The United States: The US Customs and Border Protection Agency uses AI to analyze shipping manifests and identify suspicious shipments. This has led to the seizure of millions of illegal cigarettes.
The United Kingdom: The UK's HMRC (Her Majesty's Revenue & Customs) uses AI to track the movement of tobacco products and identify tax evasion. This has resulted in millions of pounds in recovered revenue.
China: China is developing an AI-powered system to track the production and distribution of cigarettes. This system is expected to significantly reduce the sale of counterfeits.
Challenges and Considerations
While AI holds immense promise, it's important to acknowledge the challenges:
Data Quality and Bias: The effectiveness of AI depends on the quality and accuracy of the data it's trained on. Biased data can lead to inaccurate results and reinforce existing inequalities.
Privacy Concerns: The use of AI raises concerns about data privacy and the potential for misuse. It's crucial to ensure that data is collected and used ethically and responsibly.
Cost and Implementation: Implementing AI solutions requires significant investment in infrastructure and expertise. This can be a barrier for developing countries with limited resources.
The Road Ahead
Despite the challenges, AI has the potential to be a game-changer in the fight against the illicit tobacco trade. By harnessing its capabilities responsibly and ethically, we can create a safer and healthier world for everyone.
Let's work together to make the illicit tobacco trade a thing of the past. By using AI responsibly and ethically, we can build a healthier and more just world.
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sterlingcooper111 · 1 year ago
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ALL SMALL BUSINESSES ARE CRIMINALS ACCORDING TO THE GOVERNMENT!
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Get this, starting on January 1, 2024, our nasty Senators and Congressmen have now activated a LAW that considers all businesses with less than $5 million in revenue and 20 employees or less to be FIRST considered as financial criminals.
The law now mandates reporting of the BENEFICIAL OWNERS of ALL companies and businesses operating in the USA FINANCIAL CRIMES ENFORCEMENT NETWORK (FInCEN) or face fines and JAIL!
AS SMALL BUSINESS YOU ARE ALL SUSPECTED CRIMINALS1
Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing the bipartisan Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting provisions. The rule will enhance the ability of FinCEN and other agencies to protect U.S. national security and the U.S. financial system from illicit use and provide essential information to national security, intelligence, and law enforcement agencies; state, local, and Tribal officials; and financial institutions to help prevent drug traffickers, fraudsters, corrupt actors such as oligarchs, and proliferators from laundering or hiding money and other assets in the United States.
Illicit actors frequently use corporate structures such as shell and front companies to obfuscate their identities and launder their ill-gotten gains through the United States. Not only do such acts undermine U.S. national security, but they also threaten U.S. economic prosperity: shell and front companies can shield beneficial owners’ identities and allow criminals to illegally access and transact in the U.S. economy, while disadvantaging small U.S. businesses who are playing by the rules. This rule will strengthen the integrity of the U.S. financial system by making it harder for illicit actors to use shell companies to launder their money or hide assets.
Recent geopolitical events have reinforced the point that abuse of corporate entities, including shell or front companies, by illicit actors and corrupt officials presents a direct threat to the U.S. national security and the U.S. and international financial systems. For example, Russia’s illegal invasion of Ukraine in February 2022 further underscored those Russian elites, state-owned enterprises, and organized crime, as well as Russian government proxies have attempted to use U.S. and non-U.S. shell companies to evade sanctions imposed on Russia. This rule will enhance U.S national security by making it more difficult for criminals to exploit opaque legal structures to launder money, traffic humans and drugs, and commit serious tax fraud and other crimes that harm the American taxpayer.
At the same time, the rule aims to minimize burdens on small businesses and other reporting companies. Millions of businesses are formed in the United States each year. These businesses play an essential and important economic role. Small businesses are a backbone of the U.S. economy, accounting for a large share of U.S. economic activity and driving U.S. innovation and competitiveness. U.S. small businesses also generate millions of jobs, and in 2021, created jobs at the highest rate on record. It is anticipated that it will cost reporting companies with simple management and ownership structures—which FinCEN expects to be the majority of reporting companies—approximately $85 apiece to prepare and submit an initial BOI report. In comparison, the state formation fee for creating a limited liability company (LLC) can cost between $40 and $500, Beyond the direct benefits to law enforcement and other authorized users, the collection of BOI will help to shed light on criminals who evade taxes, hide their illicit wealth, and defraud employees and customers and hurt honest U.S. businesses through their misuse of shell companies.
The rule describes who must file a BOI report, what information must be reported, and when a report is due. Specifically, the rule requires reporting companies to file reports with FinCEN that identify two categories of individuals: (1) the beneficial owners of the entity; and (2) the company applicants of the entity.
The final rule reflects FinCEN’s careful consideration of detailed public comments received in response to its December 8, 2021, Notice of Proposed Rulemaking on the same topic, and extensive interagency consultations. FinCEN received comments from a broad array of individuals and organizations, including Members of Congress, government officials, groups representing small business interests, corporate transparency advocacy groups, the financial industry and trade associations representing its members, law enforcement representatives, and other interested groups and individuals.
Balancing both benefits and burden, the following are the key elements of the BOI reporting rule:
Reporting Companies
The rule identifies two types of reporting companies: domestic and foreign. A domestic reporting company is a corporation, limited liability company (LLC), or any entity created by the filing of a document with a secretary of state or any similar office under the law of a state or Indian tribe. A foreign reporting company is a corporation, LLC, or other entity formed under the law of a foreign country that is registered to do business in any state or tribal jurisdiction by the filing of a document with a secretary of state or any similar office. Under the rule, and in keeping with the CTA, twenty-three types of entities are exempt from the definition of “reporting company.”
FinCEN expects that these definitions mean that reporting companies will include (subject to the applicability of specific exemptions) limited liability partnerships, limited liability limited partnerships, business trusts, and most limited partnerships, in addition to corporations and LLCs, because such entities are generally created by a filing with a secretary of state or similar office.
Other types of legal entities, including certain trusts, are excluded from the definitions to the extent that they are not created by the filing of a document with a secretary of state or similar office. FinCEN recognizes that in many states the creation of most trusts typically does not involve the filing of such a formation document.
Beneficial Owners
Under the rule, a beneficial owner includes any individual who, directly or indirectly, either (1) exercises substantial control over a reporting company, or (2) owns or controls at least 25 percent of the ownership interests of a reporting company. The rule defines the terms “substantial control” and “ownership interest.” In keeping with the CTA, the rule exempts five types of individuals from the definition of “beneficial owner.”
In defining the contours of who has substantial control, the rule sets forth a range of activities that could constitute substantial control of a reporting company. This list captures anyone who can make important decisions on behalf of the entity. FinCEN’s approach is designed to close loopholes that allow corporate structuring that obscures owners or decision-makers. This is crucial to unmasking anonymous shell companies.
The rule provides standards and mechanisms for determining whether an individual owns or controls 25 percent of the ownership interests of a reporting company. Among other things, these standards and mechanisms address how a reporting company should manage a situation in which ownership interests are held in trust.
These definitions have been drafted to account for the various ownership or control structures reporting companies may adopt. However, for reporting companies that have simple organizational structures it should be a straightforward process to identify and report their beneficial owners. FinCEN expects the majority of reporting companies will have simple ownership structures.
Company Applicants
The rule defines a company applicant to be only two persons:
the individual who directly files the document that creates the entity, or in the case of a foreign reporting company, the document that first registers the entity to do business in the United States.
the individual who is primarily responsible for directing or controlling the filing of the relevant document by another.
The rule, however, does not require reporting companies existing or registered at the time of the effective date of the rule to identify and report on their company applicants. In addition, reporting companies formed or registered after the effective date of the rule also do not need to update company applicant information.
Beneficial Ownership Information Reports
When filing BOI reports with FinCEN, the rule requires a reporting company to identify itself and report four pieces of information about each of its beneficial owners: name, birthdate, address, and a unique identifying number and issuing jurisdiction from an acceptable identification document (and the image of such document). Additionally, the rule requires that reporting companies created after January 1, 2024, provide the four pieces of information and document image for company applicants.
If an individual provides their four pieces of information to FinCEN directly, the individual may obtain a “FinCEN identifier,” which can then be provided to FinCEN on a BOI report in lieu of the required information about the individual.
Timing
The effective date for the rule is January 1, 2024.
Reporting companies created or registered before January 1, 2024, will have one year (until January 1, 2025) to file their initial reports, while reporting companies created or registered after January 1, 2024, will have 30 days after receiving notice of their creation or registration to file their initial reports.
Reporting companies have 30 days to report changes to the information in their previously filed reports and must correct inaccurate information in previously filed reports within 30 days of when the reporting company becomes aware or has reason to know of the inaccuracy of information in earlier reports.
Next Steps
The BOI reporting rule is one of three rulemakings planned to implement the CTA. FinCEN will engage in additional rulemakings to (1) establish rules for who may access BOI, for what purposes, and what safeguards will be required to ensure that the information is secured and protected; and (2) revise FinCEN’s customer due diligence rule following the promulgation of the BOI reporting final rule.
In addition, FinCEN continues to develop the infrastructure to administer these requirements in accordance with the strict security and confidentiality requirements of the CTA, including the information technology system that will be used to store beneficial ownership information: the Beneficial Ownership Secure System (BOSS).
Consistent with its obligations under the Paperwork Reduction Act, FinCEN will publish in the Federal Register for public comment the reporting forms that persons will use to comply with their obligations under the BOI reporting rule. FinCEN will publish these forms well in advance of the effective date of the BOI reporting rule.
FinCEN will develop compliance and guidance documents to assist reporting companies in complying with this rule. Some of these materials will be aimed directly at, and made available to, reporting companies themselves. FinCEN will issue a Small Entity Compliance Guide, pursuant to section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, in order to inform small entities about their responsibilities under the rule. Other materials will be aimed at a wide range of stakeholders that are likely to receive questions about the rule, such as secretaries of state and similar offices. FinCEN also intends to conduct extensive outreach to all stakeholders, including industry associations as well as secretaries of state and similar offices to ensure the effective implementation of the rule.
For more information visit https://www.sterlingcooper.info
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history-matters · 1 year ago
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Paul Helliwell was an American original, a master of the arcane craft of concealing secret business operations. A legendary hard-drinking OSS colonel in World War II, businessman, lawyer, and banker after the war, he became so successful that he should have made the cover of Fortune. The only problem: Helliwell was not a businessman at all. He was a CIA officer on assignment.
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Helliwell pioneered the art of illegally financing intelligence activity to avoid bureaucratic accountability. He formulated techniques for creating banks and businesses to cover CIA operations. In the late 1940s, organizations like Brown Brothers Harriman and the Chase Manhattan Bank were happy to accommodate the young spy agency. But with the advent of covert operations where laws were broken, the CIA needed smaller banks and business fronts not subject to U.S. laws or SEC rules or the veto of nervous corporate executives. Helliwell was well qualified for this task. He had, from the beginning, been in on one of the CIA's most closely guarded secret operations. Of the long, secret list of CIA wrongdoing that constituted the Agency's so-called "family jewels," Helliwell had the details of the most outrageous and long-running Agency crime. Ever since 1949, the CIA had allowed the rebel armies and dictators it supported in Asia to deal in illegal drugs in order to finance their operations. After retiring from the CIA, Paul Helliwell, founder of such agency "proprietaries" as SEA Supply Inc. of Bangkok and Air America, opened a law office in Miami and formed Castle Bank offshore in nearby Nassau to cover the agency's covert money movements. In 1973 agents of the Internal Revenue Service were able to photograph the Castle Bank's customer list while a bank executive dined in a posh Key Biscayne restaurant with a woman described as an IRS "informant." Reviewing the purloined documents, IRS investigators found that the 308 Castle Bank customers on the list had moved $250 million to foreign numbered accounts. Depositors' included Playboy publisher Hugh Hefner, Penthouse magazine publisher Robert Guccione, and some major organized crime figures Morris Morris Dalitz, Morris Kleinman, and Samuel A. Tucker. Elated by the, find, investigators formed Project Haven to make "the single biggest tax-evasion strike in IRS history." Suddenly, the IRS announced that it was dropping the investigation because of "legal problems." According to a later investigation by the Wall Street Journal, "pressure from the 'Central Intelligence Agency … caused the Justice Department to drop - what could have been the biggest tax evasion case of all time." The CIA invoked "national security" since it was using the Castle Bank "for the funding of clandestine operations against Cuba and for other covert intelligence operations directed at countries in Latin America and the Far East."
Helliwell was reported to have played a key role in the purchase of the site for Disney World.
Walt Disney had selected the location during a flight over central Florida, and a thorough investigation of the land was needed before it could be officially chosen. Before sending an analyst to Florida, their New York counsel, law firm Donovan, Leisure, Newton & Irvene, got involved. The head of DLN&I provided Disney's analyst with a phone number, stationary, and business card with a fake name, all tying him to another firm, Burke & Burke, located one floor below their offices at One Wall Street. In secrecy, the analysis was completed and the site was chosen. DLN&I then created a company in Delaware, the Compass East Corp. Another law firm, this time from Miami—Helliwell, Melrose & DeWolf—created five more: Bay Lake Properties, Ayefour Corp., Ready Creek Ranch, Tomahawk Properties, and Latin American Development and Management Corp. All six were shell corporations. Through the five Florida companies, HM&D began to purchase all the desired land for an average of $200 per acre, all without alerting anyone to Disney's plans. In 1966, all five companies and their holdings were merged under Compass East. Through these firms, Disney had acquired more land than they had ever anticipated. Florida surveyors were contacted and hired to survey the property, and told to bill Helliwell, Melrose & DeWolf.
HM&D was founded and run by Paul Helliwell.
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ailtrahq · 1 year ago
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In a significant step towards tackling cybercrime and bolstering global security efforts, the IRS Criminal Investigation (CI) recently collaborated with international counterparts to provide advanced training to Ukrainian law enforcement officers. The focus was on the intricacies of cryptocurrency and blockchain tracing. Strengthening Global Efforts Against Crypto-Enabled Crime Expanding on the previous successful cyber training given to Ukrainian law enforcement in May, the IRS Criminal Investigation (CI) teamed up with the Dutch Fiscal Information and Investigation Service (FIOD) and His Majesty’s Revenue and Customs (HMRC) from the UK. Together, they conducted a second training session from September 18th to 21st, aimed at helping nearly 40 Ukrainian law enforcement officers better understand cryptocurrency and blockchain tracing. This training took place online and equipped Ukrainian law enforcement with tools to fight money laundering, analyze fake cryptocurrency transactions, and enhance their skills in blockchain forensic investigations. According to the official press release, the CI, FIOD, and HMRC collaborated with blockchain analytics firms CipherTrace and BlockTrace to provide the training. The training involved individuals from various Ukrainian law enforcement agencies, including the Cyber-Police Department of the National Police of Ukraine, the Economic Security Bureau of Ukraine, the Security Service of Ukraine, the National Anti-Corruption Bureau of Ukraine, and Ukraine’s State Bureau of Investigation. Upon completing the training and passing an exam, participants earned accreditation as Cryptocurrency Tracing Certified Examiners (CTCE). CI Chief Jim Lee said in a statement, “I regularly tout the importance of public-private partnerships, and the trainings we’ve delivered to our Ukrainian law enforcement partners are real life examples of how government agencies and the private sector have come together on a global level to curtail sanction evaders.” In May 2023, in collaboration with its partner and blockchain intelligence platform Chainalysis, CI provided an initial round of cyber training to Ukrainian law enforcement. The primary objective was to focus on identifying and disrupting the financial networks employed by individuals attempting to hide their assets in violation of sanctions. Evading Sanctions A year after invading Ukraine, Russian military fundraising groups have managed to raise millions of dollars in cryptocurrencies, despite US and international sanctions. It was previously believed that Russian military procurement and disinformation groups have raked in nearly $4.2 million, relatively smaller than Ukraine which accumulated $212 million during the same period. However, recent research by blockchain analytics firm Elliptic suggests that Russia had amassed up to $20 million in cryptocurrencies. Notably, over half of these funds have come through US-sanctioned entities, with more than 80% of the money flowing through centralized crypto exchanges. These entities have also utilized decentralized finance (DeFi) protocols, NFT services, and decentralized exchanges. Some individuals and groups have also embraced crypto for fundraising or incentives, even promoting NFT projects for the war effort. Source
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mightyflamethrower · 1 year ago
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Boosters, fencers, and cleaners: Inside cartels' newest criminal enterprise of organized retail theft
by Anna Giaritelli, Homeland Security Reporter
 August 29, 2023 06:00 AM
A nationwide retail theft epidemic cost the United States close to $100 billion in 2021. Stores are being forced to raise prices or shut up shop, insurers are refusing to help, and smaller mom and pop stores are being left behind. In this series, Mayhem on Main Street, the Washington Examiner will investigate the causes behind the scourge of shoplifting, the role of the cartels, the cost to stores big and small, and the complicity of lax prosecutors. Part 2 investigates the role of the cartels. To read Part 1, click here.
Mexican cartels are behind the spike in organized retail crime and are deeply entrenched in every level of the process, according to the federal government's chief investigative agency.
Retailers nationwide sustained nearly $100 billion worth of losses in 2021, the highest year on record, according to the National Retail Federation report published in September 2022. The growing number of cartel-run theft rings around the country drove that figure up from $70 billion in 2019.
SMALL BUSINESSES HELPLESS OVER SPIKE IN RETAIL THEFTS, SAY THEY FEEL ABANDONED BY LAWMAKERS
"Organized retail crime is leading to more brazen and more violent attacks in retail stores throughout the country. Many of the criminal rings orchestrating these thefts are also involved in other serious criminal activity such as human trafficking, narcotics trafficking, weapon trafficking, and more," said Steve Francis, acting executive associate director for Homeland Security Investigations, in a statement. HSI is part of the Department of Homeland Security's Immigration and Customs Enforcement.
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The Retail Industry Leaders Association described the acceleration of organized retail crime in recent years as having "exploded."
In fact, 80% of retailers polled nationwide reported an increase in merchandise stolen in 2022, according to the National Retail Federation.
No subindustry of retail is exempt. A spokeswoman for the home improvement corporation said Home Depot's most targeted items have been wire and wiring devices, power tools, and home automation products. When stores lock up those items, it only prompts thieves to focus on stealing other high-ticket items.
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(San Francisco Police Department via AP)
Organized retail crime has taken a huge toll on federal and state governments, costing them $15 billion in lost tax revenue, not including lost sales taxes, according to HSI.
Additionally, the average family will fork up an extra $500 annually to cover rising costs of goods as companies increase their prices to make up for stolen goods.
The type of mass-theft seen around the nation, particularly since the coronavirus pandemic began, is different than shoplifting, according to HSI. As the pandemic set in, people increasingly pivoted to purchasing items online, making it easier to sell stolen goods.
"Organized retail crime exploded over the last few years as criminals exploited the anonymity of third-party online marketplaces to fence billions in stolen products," RILA Senior Executive Vice President of Public Affairs Michael Hanson said in a statement.
These retail crimes are perpetrated by people who work as part of a crime ring run by cartels. In recent years, cartels have gone from illicit drug manufacturing and smuggling, human smuggling and trafficking, and illegal firearm smuggling to commandeering crime in the retail environment.
Cartels are involved in every level of retail crime, from in-store theft and listing items in online marketplaces to shipping stolen merchandise worldwide and using U.S. financial institutions to hold their profits.
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(AP Photo/Jae C. Hong)
Stolen items are then handed over to the second person in the theft ring: the "fencer" or "fence." The fencer buys the merchandise from the booster at a discounted price and will list the item on a number of platforms, including e-commerce websites such as eBay and Amazon, social media, and wholesale or trading companies.
Fencers will go to great lengths to conceal that the items were stolen. One example is using lighter fluid and heat guns to remove anti-theft stickers from goods. Once purchased, goods may be shipped via cargo containers overseas to be sold.
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Joana Suleiman/Washington Examiner
"The reason is almost certainly the I-70 corridor, which has become a pipeline not only for drugs but also for organized retail crime. There is a link between drug trafficking and organized retail crime," Kobach said in prepared remarks for testimony before a House subcommittee in June. "The drug-addicted often become boosters in order to feed their habits, and some fences recruit them specifically."
Boosters "almost always" steal a dollar amount that is below the felony theft level, Kobach said. In Kansas, that looks like $900 worth of merchandise being stolen to stay below the $1,000 felony threshold.
Boosters typically use "pushouts" or "rollouts," throwing items in a cart or large bag and walking or running out of the store, "knowing that the policy of the corporation prohibits staff from stopping them," according to Kobach.
"With this brazenness comes increased violence, with boosters sometimes assaulting or even using pepper spray against store personnel who dare to intervene," he said. "Boosters will hit the same specific store with impunity, sometimes as frequently as two to three times per week."
One such incident in April turned tragic when the booster was approached by Blake Mohs, a 26-year-old Home Depot security guard in New Jersey. Mohs took back the stolen merchandise and was shot. The woman arrested after the shooting was identified as 32-year-old private security guard Benicia Knapps. Knapps picked up the stolen item next to Mohs and ran out after shooting him.
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Home Depot has since introduced several initiatives to mitigate theft, though Fornes did not share details.
The final two steps in the theft cycle are left to the "cleaners," whose job is to disguise the origins of stolen merchandise, and professional money launderers who funnel the profits, according to HSI.
This summer, Congress cracked down on items sold on retail sites, including Amazon and eBay. The INFORM Consumers Act, passed in June, has been the biggest step forward for retailers and law enforcement. The Federal Trade Commission issued a warning to online sellers that it would be cracking down as the law called for.
"The industry is hopeful that requiring online marketplaces to collect, verify and disclose information about high-volume third-party sellers, marketplaces will finally evict bad actors from their platforms," RILA Senior Executive Vice President of Retail Operations Lisa LaBruno said in a statement when the bill was passed. "In turn, consumers can shop with more confidence that the products they purchase online are legitimate."
CLICK HERE TO READ MORE FROM THE WASHINGTON EXAMINER
Fornes called it a positive first step for how it takes away the "cloak of anonymity" that professional shoplifters hide behind when selling stolen merchandise online.
"Now, Congress and states must focus on three paths forward: First, enforcing the new law of the land. Second, creating capacity for law enforcement to investigate and prosecute cases through funding federal, state, and local task forces. And third, educating and training law enforcement and prosecutors on how to partner with retailers to combat dangerous criminals and organized crime," Fornes said.
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trackeye · 2 years ago
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Vital Factors for Selecting the Best Private Detective Agency in Delhi
Have you ever needed a detective after getting into trouble? In the end, you come to the conclusion that you made the wrong choice for your case's solution. It doesn't matter if the query is personal or professional. We'll discuss important factors to take into account when choosing the best Private Detective in Delhi in this blog post. Hence, check back towards the end of this post.
Who are private investigators?
Those who conduct private investigations look for facts and other pertinent information. The detective evaluates the evidence for matters that are legal, financial, or private. These individuals might work for both their own company and a private detective service. For their research, private investigators employ a variety of strategies and instruments. This aids in the investigation of both criminal and civil mysteries. Most assessments are completed via computers and in-person interviews.
Expert Advice for Picking the Best Private Investigations Firm:
We go over every suggestion for choosing the top Private Detective in Delhi. You want someone who can handle your issue with expertise. In addition, he is capable of gathering proof to support your claims..
Privateness and Secrecy:
Remember that maintaining your privacy is crucial. before selecting the top private investigation firm in Delhi or any other location. when you ask an organization to look at your case. Check their privacy and discretion rules to be sure. While investigators are looking into your case, business acumen is crucial. Thus, you must verify how such organizations ensure the privacy of your data. Also, ensure that all research, proof, and pertinent data are kept fully private.
Respecting Legal Limits and Ethics:
Legal ethics and borders may blend together and be difficult to distinguish. Recognize the philosophy and way of thinking of the top Private Detective in Gurgaon or the place where you reside. Verify that the business adheres to legal requirements. And never infringes upon your client's privacy. We have a group of knowledgeable specialists on staff who adhere to all ethical standards.
Customer Testimonials and Care:
Keep your respect and honor intact. Avoid such persons if the agency, the investigator, or both do not regard you. Look for organizations with a history of success in India. We work with reputable businesses and individuals. Think carefully and look up reviews from previous customers who have used that agency. In Delhi-National Capital Region, we serve as a private, corporate, and matrimonial detective agency. and provide all detective services throughout the nation.
Cost-effective Pricing Structure:
People are turning to private cases as the number of instances and crimes rises. For certain organizations in India, it has turned into a source of clients and revenue. Many of the private investigative firms withhold information about their prices. They impose high costs even on trivial instances. Inquire about the detective agency's cost in Chennai, Delhi, Mumbai, or any other part of the nation.
Conclusion:
This article has come to a close. While selecting a detective agency in India, keep in mind the advice we've provided. Allow me to introduce the top detective agency in the nation with offices throughout India. The best private detective in Delhi works for Trackeye Detectives. When conducting research, these agents are always conscious of the law and governmental standards. The legality of some investigative techniques, however, may occasionally be ambiguous. Nonetheless, it is crucial for our detectives to uncover the facts and reach the proper conclusion. For extensive investigations, our investigators work in a variety of settings. And finally, think about the best result. Dial 99993-13389 to reach us.
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seachranaidhe · 6 years ago
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House of senior SEA UDA member seized in Carrickfergus
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SEA UDA/UFF muriel
The National Crime Agency has taken possession of a house belonging to a senior member of the South East Antrim UDA.
The house is in the Castlemara area of Carrickfergus.
The NCA alleged he acquired the property through mortgage fraud, tax evasion and money laundering, before signing it over to his wife.
A court case was started, but the couple decided not to contest it and…
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thefivedemands · 6 years ago
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UDA IN AZIONE NEL SOUTH EAST ANTRIM: ATTACCHI E RECLUTAMENTI SEA UDA responsabile del clima di terrore in cui è costretta a vivere la comunità dell'area di Newtownards…
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timac-extraversal · 4 years ago
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Graph of Redundant Inexpensive Departments
(TIMAC #001, ~2,900 words, ~11.5 minutes)
Summary: To create mild competition without privatization, large government departments can be split geographically with adjacent territories allowed to choose their service provider.
Epistemic Status: Speculative government design.
-☆☆☆-
Could it be desirable to ax an entire government department or agency?
From a conservative perspective, if a bureaucrat's job is to write rules, then he will write rules. Faced with the alternatives of either writing more rules or finding a new job, the bureaucrat will either keep writing rules or be replaced by someone who will. His boss, whose power and prestige depend on the number of personnel needed to enforce the rules, is unlikely to object. In the absence of someone whose job it is to destroy rules, rules will gradually accumulate, and with them the burden of compliance - a problem for everyone except the organization making and enforcing the rules.
From a more liberal or left-wing perspective, abusive organizations with power often protect their own. An organization found to have engaged in wrongdoing will take a hit to its prestige, its power, and its budget, and thus the leaders who get to wield that power have an incentive to cover it up. From the other side, lower-level employees may feel a sort of comraderie (or mutual fear of prosecution) and refuse to provide the necessary information to properly investigate the wrongdoing. If these views are pervasive in the organization to the point of influencing its hiring, then the organization may prove very resistant to reform.
The Problem of Police
Police departments must always work with incomplete information. This applies both to who they arrest - at least some suspects will later be found innocent and released - and to how they arrest - a man being arrested might have a weapon on him or might start behaving erratically at any moment. Physically capturing people without harming them is difficult due to the forces involved, which is part of why weapons like tasers, pepper spray, and plastic bullets are now described by some as "less than lethal" rather than "non-lethal."
Given a large enough number of encounters, even a department composed of entirely-dispassionate military robots armed with tranquilizer darts are going to seriously harm someone, and most police departments are much worse than this. Police violence is a notorious problem, and reports of police corruption or covering for bad behavior aren't far behind. Communities must choose between the risk of getting harassed and murdered by the police, and the risk of getting harassed and murdered by criminals, with better departments doing better at both metrics, but perhaps at a cost to some other factor we care about.1
Mapping Out the Problem
I'm not a criminologist. I don't know exactly what makes a good police department - but I bet there are a lot of experts who do, who for reasons of incentives aren't being listened to right now. (Though with recent events, perhaps people are paying more attention.) What I am about to propose is a more general technique which would require further testing.
We could try gathering metrics, but metrics can be gamed. How do we even quantify traits like 'friendly' and their associated trade-offs?2 We could try electing the police chief and top-tier officers, but people already seem to be paying more attention to national politics than to local politics; adding even more local elected officials to memorize won't help that, even before we account for whatever bizarre distortions political party affiliation would have on the cops. (In fact, it's long been said that 'tough on crime' stats for elected officials are driving wastefully unmerciful prosecutions and other bad policing.)
If the department culture itself is corrupt or has networks of corruption, we're even worse off. Technically, we could ax the entire department and replace it with a new one - Camden, New Jersey, replaced their city department with a county one - but this is likely to result in some disruption and to require a lot of political energy.
Dividing the Array of Cops
...but what if it were easier to just get rid of an underperforming department? What would that require?
First, to prevent service disruption, we would need a backup department that is ready to work within weeks or months. Second, whatever structural factors corrupted the first department might corrupt the second department, so we'll need a stream of replacements.
For raw numbers, let's use New York City. (I don't have anything personally against New York or the NYPD. New York is just really big.) The city of New York has over 38,000 police officers for its population of about 8.3 million residents (a ratio of about 216:1). It would be difficult to replace an entire force the size of a town in one year and ensure quality, and it would take several years to rebuild institutional competence.
However, the challenge of replacing the NYPD doesn't come from the 38,000 personnel overall; a force that large might need to replace 1,000 personnel a year from retirements alone. What makes us unable to replace the NYPD is that all 38,000 cops are in one department. If we had a larger number of smalller departments, then the number of personnel we'd need to recruit in one year to replace one department would be much more manageable.
Charter Justice
At this point, a more libertarian writer might suggest that if we're replacing the NYPD with smaller departments, then we should replace it with competing private security services companies ('PSCs') and issue security services vouchers. I'm skeptical of this approach for a variety of reasons.
In the voucher scenario, only living friends and relatives of a homicide victim are still customers, as the homicide victim himself cannot be a future source of revenue for the PSC.
Regular police departments are already under political pressure to ignore crimes by the wealthy and politically well-connected. If people can pay more than the voucher amount, the department has further incentive to do so.
Regular people are already tasked to capacity on obtaining, verifying, and processing information, to the point that our society is under epistemic stress. Searching through and verifying the records and reputations of a dozen PSC firms is unpaid work that we can expect will be done poorly.
The ideal coverage zone for PSC firm competition is the individual or the building. Neighborhood-level coverage organizations would create principle-agent problems and start coming up with their own de facto ordinances to save money - but without neighborhood-level coverage organizations, it would be difficult to gain fast responses and economies of scale.
Under a non-profit department model, it is more difficult to siphon off resources that would have gone to policing as cash for personal use and the return on investment for doing so is lower (due to costs of evasion/laundering). A for-profit department is incentivized to drop the least-profitable cases and to minimize expenses while externalizing the costs even more than a conventional department.
It is not that the impulse for private firms is wrong in the general case, but rather it's a matter of the incentives in the specific case. Private firms do fairly well at producing ordinary goods and services with repeat buyers where customers are easily able to assess the quality of the good or service. Policework doesn't fit the characteristics as well, in part because it's about enforcing (and thus influencing) the rules themselves.
For these reasons, I think competing public departments would be a better choice than a private security model.
Departments
How many departments should the city have? When a department is larger, it can gain economies of scale on paperwork, storage, and so on. When a department is smaller, it's easier to replace and there's more variation, but the more departments there are, the more departments there are to keep track of. We must manage the flow of information.
For many cities adopting this multi-department framework, five (5) might be the optimal number of police departments. In New York, each would have around 7,600 officers. (A meta-department could be placed in charge of procuring city-wide police software and standard equipment.) Three departments would be too few - each department would only have to be better than two others, and a department closure would raise the other departments' workloads by 50%. Seven or even nine departments might work for New York (with around a million residents per department), but every jurisdictional boundary that needs to be cooperated over for an investigation of a cross-jurisdiction crime adds more friction and makes the investigation less likely to succeed. Smaller and more temporary task forces could be created between departments for city-wide crimes.
Once we have five departments, it becomes easier for the City to remove one should an entire department be implicated in a Nepalese tiger smuggling ring, or some much more ordinary kind of malfeasance.3
But how often do we actually want or need to remove the entire department at once? We might want to decrease a department's power and reach without totally removing it, for less disruption.
Territories
Instead of dividing the City of New York into 5 territories, let us divide the city into 100. To start, each department gets 20 territories, all contiguous. Funding is on a per-territory basis, based on demographic factors such as population and level of poverty.
Who knows whether a police department is doing a good job? How do we solve the question of what metrics are appropriate and what the right balance of risk is? We don't. We punt that question to voters. Every two years or so, all police territories that are either on the border of a department's controlled territories, or are adjacent to a border territory, vote on whether to switch to neighboring police departments.
The voters don't need to keep track of much. Most years, the main question they need to answer is: "is my neighborhood's police department doing a better job than the police department across the street?" They don't need to know who the police chief is, or what the department's exact policies are, although of course informed voters can do research on the departments to find out.
City elected officials manage the map requirements. Only 5 territories may be transferred away from a department in one round. The area controlled by a police department must be contiguous. A transfer may be refused by city officials if it violates one of these two conditions. The actual process of switching will occur over a period of 6-12 months.
Departments that are well-regarded will gradually grow, while departments that are hated by the citizens will shrink. If they are unwilling or unable to reform, a department will be dissolved when it falls below 5 controlled territories.
For more immediate results, the Mayor can put a referendum to dissolve a department to the voters for the following election.
New Departments
To stay at a total of 5 departments, a new department must be added whenever an old department is dissolved. Where do new departments come from? To create a new department, the largest (and thus presumably most well-regarded) department is split into two departments over a four-year period. Alternatively, a vote may be held to find a critical mass of territories that want a new department, and a new department can be formed there. The decision on which of these two processes to use will be left to city elected officials.
Departments can also be allowed to move beyond municipal boundaries, allowing the movement of departments from the suburbs into the city, or between suburbs.
It's quite possible that the new department procedure will never be used. The threat of losing control of territory, and thus losing jobs for officers, and losing prestige for the department, may be sufficient to get about as much performance out of the police departments as they are realistically able to provide with the budgets they have.
With both a source of new departments and a loss of old and underperforming departments, and the movement of departments along a graph of connected territories, we can call this overall approach GRID - Graph of Redundant Inexpensive Departments4 - until a more suitable name is devised. "Departments" are of course a bureaucratic construct. Officers may end up working for different departments throughout their careers.
The marginal employee typically needs a company more than the company, which is much larger, needs the marginal employee. Unions allow a balance where 'employee' bargaining organization size is in the same class as firm size. Under GRID, there should be one union for each department, to prevent the police unions from overriding city policy, while ensuring they have firm-size negotiating leverage.
Risks
How much discretion in setting internal policy will the departments have? This will be set by the city elected officials, who may allow more or less discretion as they deem appropriate. The degenerate state is similar to having one city police department, but with higher overhead.
How much will the departments campaign, and how much will the policing become politicized? It's likely that the neighboring territories will be relatively similar to each other, so police policies probably won't wildly diverge. As for campaigning, it isn't just important to do a good job, but also to ensure that others know that you did a good job. The best campaign for a department is probably to have good relations with the community.
Will departments still attempt to cover up failures? The organization is smaller and thus less able to endure the consequences of a major failure. However, I expect that most major failures start out as a minor failure that is then compounded. With the tighter feedback between actions and consequences, and with fewer people to monitor, the intent is that minor problems will be found and addressed earlier, before they have a chance to become major problems.
Risks: Will the Gain Be Sufficient?
The GRID approach only makes sense if police departments aren't performing near their maximum potential given their available resources (such as equipment, talent pool, conditions of the areas they're patrolling, etc), and the reasons for this are within the potential control of the department. (For instance, if a city's tax base evaporates and the police department is used to gain revenue for the city government through fines, it will be very difficult for the department to have any kind of good relationship with the community.)
Creating multiple departments means having more department chiefs, more buildings, and periodic moves between buildings. The total number of cops is unlikely to change, but the total cost of the program might rise by 3-10% (to blindly guess). GRID should only be enacted if we expect that there is a double-digit gain that we cannot achieve through smaller, simpler policy interventions, or other alternative classes of policy interventions.
General Applications
The use of police departments is only a specific example of what is intended as a general technique. If institutions are essential to the maintenance of advanced civilization, but there are risks of long-term institutional decline, then it may be worth breaking them up into smaller units so that one institutional failure doesn't wipe out society's full institutional capabilities in that institution's class. (Further, the rate of institutional decline is likely to vary, allowing us to maintain a higher average institutional performance for longer through replacing the worst-performing institutions.) While the failure of small institutions may be more pro-cyclical on the small scale, an early small institution failure may be more recoverable than a late large institution failure, as it may occur while more resources are still available, and re-capitalization cost to create a replacement will be lower.
On the other hand, large institutions can better survive shorter and smaller disruptions. GRID should be conceived as part of a general discourse on institution size as part of society's ecosystem of institutions.
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[1] - For instance, many colleges use 'Affirmative Action' policies to alter the demographic distribution of their incoming student body, generally justified as either increasing the diversity students are exposed to, or making up for disparities earlier in the educational pipeline. Increasing the training standards for police to match that of a 4-year degree might improve officer performance, but will likely require an affirmative action program due to whatever disparities are present in the pipeline for a conventional 4-year college degree, and will likely also increase individual debt and expectations of officer pay. Cities may find they can't lower the pay even if they want to, as they compete for the same pool of otherwise college-bound prospects as many industries do. This may further hinder the ability of impoverished cities to hire an adequate number of officers relative to the number of calls, or drain municipal budgets that could have been directed towards prevention or other programs.
[2] - "We must measure some proxy for officer friendliness. Officer smiles per pedestrian-minute is such a proxy, therefore we must measure it," and absurdities of similar magnitude might follow.
[3] - A tiger smuggling ring is less realistic and used as an example because it's less depressing than a more realistic one like ties to organized crime. On the other hand, in this absurd year of 2020, a department might be found guilty of something equally outlandish.
[4] - A little joke on my part. GRID does not directly share its design with RAID (Redundant Array of Inexpensive Disks), but is designed to make replacement of a department easier.
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complete · 4 years ago
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As it stands this includes all crimes, including kidnapping, torture, csa, even murder.
From the article:
"Which agencies will be able to authorise secret crimes?
MI5 and other intelligence bodies
Police forces and the National Crime agency
Immigration and Border Officers
HM Revenue and Customs
Serious Fraud Office
UK military forces
Ministry of Justice (investigations in prisons)
Competition and Markets Authority
Environment Agency
Financial Conduct Authority
Food Standards Agency
Gambling Commission
Medicines and Healthcare Regulation Authority" ...
Seems like a very bad idea.
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