The Golden City debacle serves as a warning to investment schemes to consult international criminal lawyers before doing business with those connected to human rights abuses and atrocity crimes. There is a compliance mesh that creates a connection between criminal law and financial risk. Our memorandum for Justice for Myanmar when we were instructed by the Australian Centre for International Justice is a career defining example.
Golden City officially opened Golden City Business Centre in 2017. The development with a net leasable area of around 150, 000 sq ft involved land use payments over a 70-year term with amounts of up to US$191.1 million to the Myanmar army. States have imposed sanctions against Myanmar in response to its government’s violent suppression of pro-democracy movements, corruption, and human rights violations. Sanctions include arms and trade embargoes, asset freezing and prohibitions on travel and investment and yet the investment opportunity was offered through the Singapore Stock Exchange (SGX).
My legal expertise, together with excellent junior barrister Daye Gang, was requested in 2021 when SGX initiated regulatory actions against the developer of the Golden City complex, ETC, after Justice For Myanmar published an investigation into payments to the Myanmar army, implicating funds raised on the SGX.
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