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SUMMER SCHOOL ON CRIME, LAW AND PSYCHOLOGY

To shed some light on understanding of crime, law and psychology…
The Center for Public Policy is pleased to invite students to:
Summer School on Crime, Law and Psychology 2006 (CLP2006)!
July 1-7, Prague

The organizer of European Summer/Spring Institute, Center for Public Policy, has teamed up with professors from the University of Aberdeen and Warwick University to launch a summer course for international students interested in application of psychological approaches and research methods to criminal justice system. The program aims to invite students of different backgrounds (psychology, legal studies, and criminology), who are interested in interrelatedness of crime, law and psychology and are willing to combine the challenging academic environment with the holiday fun.
Students of CLP2006 will not only have an opportunity to listen to professors from the UK’s best Universities, but will also share their ideas and interests with practitioners during the guest lectures and site visits. Last, but not least the participants of CLP2006 will have a great possibility to meet new friends and explore the magnificence of Prague during special events organized by the CLP2006 staff.

Final Application Deadline: May 30, 2006 See the website.

RIOTS REVEAL ORGANIZED CRIME POWER IN BRAZIL

Last weekend, Brazilians living in the greater Sao Paulo metropolitan area witnessed one of the country’s largest prison riots in the past five years, organized and orchestrated by Sao Paulo’s largest criminal faction, the First Capital Command (PCC in Portuguese).

When Sao Paulo state authorities transferred some 756 PCC leaders, the PCC criminal enterprise, led by Willians Herbas Camacho (a.k.a. Marcola), implemented its plan to start riots in dozens of prisons in Sao Paulo and around the country. They took advantage of the unusually lax security environment over the weekend when some 10,000 prisoners were given a day pass to visit families on the outside for Mother’s Day, and thousands more civilians entered prisons to visit inmates on the inside.

As one prison after another fell under the control of rioting inmates, the hostage count rocketed into the hundreds. Meanwhile, organized attacks on police stations around Sao Paulo kept security forces busy defending themselves. At the same time, masked gunmen commandeered city buses, ordering them evacuated before burning them to the ground.

The weekend’s total included over 250 separate attacks on police stations, stores, and other establishments. There were 115 people killed, including 32 policemen and prison guards and 71 gang members. Another 49 people were injured. Some 215 hostages were taken in 73 prison riots that occurred in prisons across Sao Paulo, Parana, Matto Grosso do Sul, Brasilia, and Bahia, according to Brazilian daily Folha de Sao Paulo. Over 80 public transport buses were burned and one metro station was attacked, leaving over five million people without public transport. On 15 May, as millions of people fled home in the early afternoon, Sao Paulo became a city of gridlock spanning 203 kilometers of roadways.

Over the weekend, as the violence raged on, Brazilian Justice Minister Marcio Thomas Bastos offered the service of 4,000 soldiers, part of a National Force trained to help contain the security problems in Brazilian states. But Sao Paulo Governor Claudio Lembo, filling in for presidential candidate Geraldo Alckmin, refused to accept federal help. Bastos made the trip from Brasilia to Sao Paulo to again offer federal assistance during a close-door meeting on Monday, 15 May. But again it was refused.

By 16 May, as quickly as the violence had started, it ended, and most prisons were back in the control of state authorities, and policemen were no longer the target of random attacks. The Sao Paulo daily newspaper, O Estado de Sao Paulo, reported on 16 May that the state government had reached an agreement with the PCC. Government officials continue to deny that claim, but it is possible such negotiations were a last-resort option for state officials clearly caught off guard by a highly organized criminal network, one many believed had been dismantled years ago.

Brazilian organized crime

The PCC began to take shape in 1993, when prisoners incarcerated in Taubate state prison in Sao Paulo organized themselves to fight against deplorable living conditions and more rights within the prison system. Over the past 13 years, this organization has grown into one of the country’s most powerful prison criminal networks, controlling activity within dozens of prisons in Sao Paulo and around the country, as well as important sales points and transport routes for drugs and guns flowing into Brazil from source countries such as Paraguay, Bolivia, Colombia, and Suriname.

The PCC became more active outside prisons in 1999, when Rio’s top criminal organization – the Red Command (CV in Portuguese) – formed an alliance with PCC members who lived in Heliopolis, a shantytown located in the southeastern zone of Sao Paulo, according to a Rio de Janeiro Federal Police officer who asked to remain anonymous. Through this alliance, the CV sought to shift some of its drug trafficking activities from Rio de Janeiro to Sao Paulo. In Rio, CV leaders had been constantly harassed by police who exacted an extortion tax for allowing favelas (shantytowns) to be used as drug sales centers and contraband transshipment points. Additionally, the PCC in 1999 was a large criminal organization with more manpower than economic activity. Its alliance with the CV increased earnings for the PCC in Sao Paulo, while opening a new pool of man power for the CV to defend its turf from rival gangs in Rio de Janeiro.

Together, the two gangs control the drug trade in Brazil’s two largest cities. They operate gun smuggling routes out of Paraguay and purchase weapons from corrupt policemen and military soldiers in Sao Paulo and Rio. High-level members of these gangs, especially the CV, continue to conduct a weapons-for-cocaine barter with members of the leftist Revolutionary Armed Forces of Colombia (FARC) based in the Colombian Amazon.

As recently as 30 April, three Colombians opened fire on a Brazilian patrol on the Rio Negro, a branch of the Amazon river that begins in an area of the Colombian Amazon reportedly controlled by the FARC. Brazilian authorities claim that the rifles were stamped with the Brazilian military coat of arms. The men were followed to the Colombian city of San Felipe, where their arms were confiscated. Brazilian Federal Police investigators told ISN Security Watch that they believe the arms were part of a cache of weapons to be traded for cocaine that traffickers would transport to Sao Paulo and Rio.

Red Command leader Fernandinho Beira-Mar is considered to have been one of the first Brazilian criminals to trade weapons for cocaine with the FARC. He was arrested by Colombian authorities in April 2001 and immediately extradited to Brazil. Yet the recent incident on the Brazilian-Colombian border in the Amazon indicates that five years later, this criminal exchange program still continues to supply the CV and the PCC with pure, Colombian cocaine.

Brazilian organized crime is just as powerful within the prison system as it is on the outside. And as the battle continues to dismantle these criminal networks, the occasional mega-rebellion reminds Brazilian authorities and civilians that the security sector here has a long way to go before it has any significant control over organized crime. These rebellions also highlight the superior communication networks operated by Brazilian organized crime.

Communication is fundamental

When Fernandinho Beira-Mar was transferred from his prison cell in Rio de Janeiro after he orchestrated a prison riot there in September 2002 to mask the assassination of rival gang leaders, authorities found a number of luxury items including silk pajamas. But what surprised them more was the number of abandoned cell phones. Reports from Rio de Janeiro daily, O Globo, claim that Beira-Mar used up to a dozen cell phones to communicate with lieutenants and other subordinates in his black market network of guns and drugs shipments and sales.

In a similar fashion, leaders of the PCC use cell phones to communicate with one another between prisons and between prisoners and gang members on the outside. Both the Civil Police and the Federal Police operate listening posts, which enable security officials to piece together actionable intelligence on plans for rebellions and other gang operations. However, the use of two-way radios has made that task much more difficult.

In both Rio and Sao Paulo, two-way radios are used by criminals to relay messages to other incarcerated gang members and members on the outside. In some cases, one prisoner calls via cell a subordinate on the outside who uses a two-way radio to transmit the message to a third individual who then uses another cell phone to pass along the message to its recipient in another prison, reports O Globo. Each node on the communications chain may use any number of cell phones or two-way radios, making tracking the signals very difficult.

Attempts to block cell phone signals in Rio and Sao Paulo have been ineffective.

In the middle of the Mother’s Day weekend riots, requests to shut down cell phone towers used by criminals to relay signals were presented to Brazil’s telecommunications regulatory body when Marco Antonio Desgualdo, the head of the Sao Paulo state Civil Police, met with this body, called Anatel, on 15 May. The Folha de Sao Paulo reported that after the meeting Desgualdo announced that authorities would not be able to shut down cell towers without the acquiescence of telecommunications companies.

These same companies – Vivo, Tim, Telefonica, Embratel, and Nextel – complain that shutting down the towers would mean an unacceptable disruption of service for their law-abiding clients. Nothing short of a court order would shut down the towers, a legal instrument that takes too long to obtain.

In some prison systems, cell phone signal blockers are used, but they are quickly rendered obsolete by the rapid pace of technological advancement in cell phone systems.

The battle between Sao Paulo authorities and the cell phone companies to shut down towers in the event of security needs began in February 2001, when PCC members used cell phones to orchestrate simultaneous riots in 29 prisons across Sao Paulo. Security officials failed to win the battle then, too, but no one knew that such decisions five years ago would eventually facilitate the most violent uprising of Brazilian organized crime in years.

Corruption and politics

Even as blocking cell signals and other methods to impede communication between criminals evolves into what may become a viable solution, many believe that such time is wasted on treating a problem that is not central to the real reason why the PCC was able to orchestrate such a widespread reign of disorder and rebellion. Corruption and politics, two of the usual suspects behind systemic dysfunction in democracies, are at the center of Brazil’s security problems.

Bribes paid to security officials at all levels keep leaders of the PCC and the CV well informed of official planning. When authorities planned to move over 700 of the PCC leaders to a more secure prison environment to avoid what they learned was a planned Mother’s Day rebellion, the PCC reacted by launching its rebellion two days early, disrupting the prisoner transport and a host of other activities planned to prevent the rebellion.

Low salaries exacerbate corruption because policemen and some lower-ranking members of the military are more likely to sell weapons from poorly organized stock piles to make ends meet. Over 70 per cent of the weapons used by Brazilian organized crime were made in Brazil. Many of them are sold to Paraguay where they enter the black market before returning to Brazil. Yet a significant amount are sold to criminals directly from stockpiles of seized weapons.

When budgets must be prepared, politics dictate who gets what slice of the pie. From 2004 to 2005, the Brazilian federal government reduced resources for the country’s Penitentiary Fund by 37 per cent. This fund oversees the overall improvement and maintenance of Brazil’s prison system. Meanwhile, the government of Sao Paulo state diverted from public security spending some US$81.3 million in the last five years. It was a decision in the reduction of security spending at the Sao Paulo state level that was likely made after the 2001 prison riots in that state.

Commenting on the event, Brazilian President Luiz Inacio “Lula” da Silva said it was a demonstration of the power of organized crime in Brazil. His comments underline the fact that Brazilian organized crime is a force that has grown to threaten Brazilian cities as well as the nation. With links to organized crime in Paraguay and Suriname, and a thriving barter system with Colombia’s FARC soldiers, the PCC and CV may soon become internationally known as a criminal network that has grown too big for Brazil’s security system to handle.

(ISN Security Watch (18/5/06))

CALL FOR PAPERS: INTERNATIONAL JOURNAL OF CYBER CRIMES AND CRIMINAL JUSTICE

International Journal of Cyber Crimes and Criminal Justice (IJCCCJ) is a peer reviewed interdisciplinary journal published biannually and devoted to the study of cyber crime, cyber criminal behavior, cyber victims, cyber laws and cyber investigations.

IJCCCJ will be both print (published by Serials Publication) and online (open access) Journal. IJCCCJ will focus on all aspects of cyber/computer crime: Forms of Cyber Crime, Impact of Cyber crimes in the real world, Policing Cyber space, Cyber-terrorism, International Perspectives of Cyber Crime, developing cyber safety policy, intrusion investigations, information security, Cyber Victims, Cyber offender behavior, Cyber Geography,cyber crime law, Cyber Pornography, Physical Computer Security, Privacy & Anonymity on the Net, Internet Fraud & Identity Theft, Mobile Phone Safety, Online Gambling, Copyright and Intellectual property Law, Detection of Distributed Denial of Service Attacks, Firewall Testing and Digital Forensics. As the discipline of Cyber Criminology approaches the future, facing the dire need to document the literature in this rapidly changing area has become more important than ever before. The IJCCCJ will be a nodal centre to develop and disseminate the knowledge of cyber crimes to the academic and lay world. The journal publishes theoretical, methodological, and applied papers, as well as book reviews.

For information on the submission on manuscripts please visit the website.

Please send completed manuscripts by email to
Dr. K.Jaishankar
Editor-in-Chief, IJCCCJ,
Department of Criminology and Criminal Justice
Manonmaniam Sundaranar University
Abishekapatti, Tirunelveli 627 012
Tamil Nadu India
E-mail cybercrimejournal@gmail.com
Website: http://www.cybercrimejournal.co.nr

RCMP CAN’T DENT ORGANIZED CRIME

OTTAWA – The RCMP cannot afford to fight the majority of organized crime activity in Canada, Commissioner Giuliano Zaccardelli said yesterday.

“At this point in time, our best guess is that we’re able to tackle maybe a third of what we know is out there, in terms of serious organized crime,” he said, adding that is probably a generous estimate. “And remember, when I say one-third, that’s of what we know.”

Although the Mounties’ budget has doubled over the past seven years, Commissioner Zaccardelli told the Standing Senate Committee on National Security and Defence he still has “serious issues to deal with, in terms of resources.”

Foes of the force include outlaw motorcycle groups and Italian, Russian and Asian organized-crime organizations, many with a well-established presence at Canada’s vulnerable land, sea and airports.

Committee chairman Colin Kenny pressed the commissioner to explain why Canada has only about 100 Mounties to cover 89 airports across the country and just 30 officers patrolling its 19 marine points.

Commissioner Zaccardelli responded the force has adopted intelligence-led policing tactics to identify and target the most dangerous organizations, but “given the resources we have and our limitations, we know there are groups that we can’t go after.”

That terrorist groups appear to be increasingly involved in organized crime activities makes the issue all the more troubling, he suggested.

“There clearly is more and more indication that some terrorist groups are clearly getting some of their finances by either directly supporting some criminal activity, or indirectly being fed resources that are the product of illegal activities,” he explained. “That is a trend that we’re watching and monitoring and has the potential to cause serious problems.”

Yet despite his complaints about lack of resources, Commissioner Zaccardelli told the committee he was “very pleased” with the federal budget last week.

The Tories pledged $37-million to expand the RCMP’s training facilities in Regina, and $161-million for more police officers and federal prosecutors. According to budget documents, the funding “will enable the RCMP to to fill 1,000 vacancies by 2010.”

But testimony yesterday revealed that is an optimistic target.

Department of Justice officials are expected to take about $25-million for new lawyers, leaving $136-million for police.

“We’re looking at about $192,000 for a fully operational police officer at the federal level, so when you start doing the math … it tells you,” Commissioner Zaccardelli said.

The math says 1,000 new officers would cost $192-million, $56-million more than has been committed. The commissioner said he was under the impression the initial pledge was “to start getting us up there,” however.

While the commissioner’s testimony raised many questions, he brushed by reporters following the hearing without answering them.

Mr. Kenny said in an interview the fact the RCMP can only touch on one-third of known organized crime in the country is a “big-time” concern.

“What about the other two-thirds?” he asked. “We’ve come out with reports on ports and airports and on the border, and time and time again we come back to the question of: We don’t have enough cops. Bottom line.”

He also expressed concern regarding terrorist involvement in organized crime.

“[Narco-terrorists] come and they distribute drugs through Canada and get a hell of a lot of dough for it,” he said. “We have an incredible distribution network that would put UPS to shame in terms of how drugs are distributed across the country.”

Commissioner Zaccardelli was spared questions regarding the recent decision to arm Canada’s border guards, a move he strongly opposed in the past.

He told a Senate committee last spring that while the border is a dangerous place, “having a customs officer run out of his hut and shoot after” criminals was the wrong move.

The comment enraged border union officials, who have long been lobbying for more protection.

Mr. Kenny said the plan will be very costly to implement, however, noting his first choice would have been to boost RCMP presence at Canada’s frontier.

“To do it is going to be very complicated,” he said. “At the end of the day, you’re going to have a more expensive border guard as well.”

(National Post Tuesday, May 09, 2006)

ORGANIZED CRIME, MEXICO’S TOP THREAT

Nuevo Laredo has become a stage where Mexican organized crime demonstrates its immense power to corrupt, kill, and make money. Despite every attempt by both Mexican and US authorities to control smuggling and violent death, Mexican organized crime continues to take advantage of the largest inland trade zone to smuggle hundreds of tonnes of cocaine north into the US and thousands of automatic rifles south into Mexico. Two factions of Mexican organized crime continue to wage a war for control of access to Laredo, Texas. It is a direct route to a demand market in the US worth billions of dollars year after year.

Read the full article at ISN Security Watch

GAS TRADERS TO WESTERN EUROPE FACE ORGANISED CRIME INQUIRY BY THE US

VITAL gas supplies to Western Europe are at the mercy of shady middlemen who have taken control of the gas trade between Russia, Ukraine and Turkmenistan, it was alleged yesterday.
Their unregulated business dealings have contributed to a sharp rise in the price of gas in leading markets, including Britain and Germany. Their secretive company, RosUkrEnergo, which has a monopoly of billions of dollars of gas sales to Ukraine, is being investigated by the organised crime division of the US Justice Department.

At the same time Angela Merkel, the German Chancellor, is expected to press President Putin to guarantee the security of gas supplies when she meets the Russian leader this week.

Yesterday the British non-governmental organisation Global Witness called for an investigationinto RosUkrEnergo and urged the European Union not to enter into any agreements with the leadership of Turkmenistan until there was greater transparency in the gas trade.

The organisation also called on the Kremlin to show leadership on energy security — the theme of Russia’s debut year in its presidency of the G8 — by investigating allegations of wrongdoing in the gas sector.

“Lack of transparency makes it impossible for the people of Turkmenistan and Ukraine, or gas customers in Western Europe, to know who really controls this trade and where the profits go,” Tom Mayne, a Global Witness campaigner, said.

“The EU is forging a long-term strategy on how to source and use energy. But this strategy won’t be credible unless it promotes transparency and good governance in countries which supply Europe’s energy, because instability in these countries could ultimately threaten energy supplies.”

RosUkrEnergo emerged as a key player in the gas trade between East and West following a protracted gas dispute between Russia and Ukraine in January.

Gazprom, the Russian monopoly, cut off supplies to Ukraine on New Year’s Day to force Kiev to pay more for gas, severely disrupting deliveries to the rest of Europe. Russia said that it was phasing out subsidies for Ukraine and other former Soviet republics and accused Ukraine of stealing supplies destined for Western Europe.

Kiev denied this and accused the Kremlin of punishing it for the 2004 Orange Revolution.

Gazprom’s move raised doubts in the West about Russia’s reliability as an energy partner and prompted calls for the EU to reduce its dependency on Russian oil and gas. Gazprom and Naftogaz, the Ukrainian state gas company, reached a new deal on January 4 under which Russia and Turkmenistan supply their gas to Ukraine through RosUkrEnergo.

The Switzerland-based company is owned half by Gazprom and half by Raiffeisen Bank, of Austria. But Raiffeisen is acting on behalf of beneficiaries who have never been identified. The Global Witness report was published three days after the US Justice Department confirmed that it was investigating RosUkrEnergo.

Company executives travelled to America two months ago to discuss its structure with department officials and US authorities have reportedly requested information about RosUkrEnergo from the Austrian Government.

Global Witness said that it also had a letter showing that doubts over RosUkrEnergo’s ownership structure and affiliates prompted its auditors from KPMG International to resign in November. Global Witness named two top Ukrainian officials who had held key positions in RosUkrEnergo. And it identified a group of British businessmen who, it said, had worked with RosUkrEnergo and also played key roles at its equally opaque predecessor, Eural Trans Gas.

It also alleged that President Niyazov of Turkmenistan kept most of his Central Asian nation’s estimated annual gas revenues of $2 billion (£1.12 billion) off the books. “Niyazov keeps most of the gas revenues under his effective control in overseas and off-budget funds,” it said. “Most worrying of all, it seems that no money from the sale of Turkmen gas even makes it into the national budget.”

Global Witness alleged that Mr Niyazov kept $2 billion in the Foreign Exchange Reserve Fund at Deutsche Bank, of Germany, in an account that he alone had access to.

“It is hard to reconcile Deutsche Bank’s role in managing Turkmenistan’s money, which is under Niyazov’s effective control, with the long-term interest of Germany in promoting stability in Central Asia,” it said.

A spokesman for the European Commission said: “It is important to improve transparency in energy markets.” EU leaders agreed last month to push ahead with a common European energy policy to ensure security of supplies, particularly from Russia and Central Asia. The EU leaders decided to combine forces after Gazprom cut off gas supplies to the Ukraine. One senior Commission official said at the time: “Russia has got its jackboot on Europe’s gas pipe.”

(Times Online 25-04-2006)

MONEY LAUNDERING IN THE NETHERLANDS

The International Monetary Fund (IMF) estimated money laundering at 2-5% of world GDP but few others have made an attempt to quantify global money laundering. John Walker (1999) was the first analyst to make a serious attempt at quantifying money laundering and the initial output from his model suggests that $2,85 trillion is laundered globally.

Research by the Utrecht School of Economics and the Australian National University shows that Walker tends to overestimate money generated for laundering in the Netherlands, by about 30-40%. The results indicate that there is Є 8 to 14 billion from crime generated in the Netherlands of which 44% will stay in the Netherlands for laundering. This means that money laundering from crime in the Netherlands amounts to Є 3.2 to 4.2 billion per year, with the most likely estimate to be Є 3.8 billion. The remaining Dutch criminal money will be placed somewhere else. In addition, criminal money from abroad will also flow into the Netherlands. There is also an additional Є 14 to 21 billion that flows into the Netherlands from the top 20 origin countries of generated money for laundering. This means that the amount of money laundering with which the Dutch have to deal accounts for about Є 18 to 25 billion, hence about 4% of the Dutch money demand, or about 5% of the Dutch GDP.

Read the full report ‘The Amounts and Effects of Money Laundering’ (PDF)

SERIOUS ORGANISED CRIME AGENCY

The Serious Organised Crime Agency (SOCA) is a new law enforcement agency in the UK created ‘to reduce the harm caused to people and communities in the UK by serious organised crime.’

It takes over the functions of the National Crime Squad (NCS), the National Criminal Intelligence Service (NCIS), the role of HMRC in investigating drug trafficking and related criminal finance and some of the functions of the UK Immigration Service (UKIS) in dealing with organised immigration crime. SOCA assumed its functions on Saturday 1 April 2006.

The website of SOCA is still a little empty although the annual plan 2006/2007 (PDF) has been put online and gives some more insight in this organisation.

CALL FOR PAPERS: MONSTERS AND THE MONSTROUS

4th Global Conference, Monsters and the Monstrous: Myths and Metaphors of Enduring Evil. Monday 18th September – Thursday 21st September 2006 Mansfield College, Oxford, United Kingdom.

This inter-disciplinary and multi-disciplinary conference seeks to investigate and explore the enduring influence and imagery of monsters and the monstrous on human culture throughout history. In particular, the project will have a dual focus with the intention of examining specific ‘monsters’ as well as assessing the role, function and consequences of persons, actions or events identified as ‘monstrous’. The history and contemporary cultural influences of monsters and monstrous metaphors will also be examined.

Perspectives are sought from those engaged in the fields of literature, media studies, cultural studies, history, anthropology, philosophy, psychology, sociology, health and theology. Ideas are welcomed from those involved in academic study, fictional explorations, and applied areas (e.g. youth work, criminology and medicine).

Papers will be considered on any related theme. 300 word abstracts should be submitted by Friday 2nd June 2006. If your paper is accepted for presentation at the conference, an 8 page draft paper should be submitted by Friday 1st September 2000 Full announcement

CONFERENCE: CRIME, JUSTICE AND SURVEILLANCE

A TWO-DAY International Conference hosted by the Centre For Criminological Research, University of Sheffield in association with www.surveillance-and-society.org on Wednesday 5th and Thursday 6th April 2006.

In the UK the last decade has seen an unprecedented deployment of surveillance technologies and practices in the name of crime control. Drug testing, electronic monitoring, DNA testing and video monitoring have all expanded rapidly. Actuarial practices based on risk assessment and offender profiling have become central to proactive based policing strategies that ‘target the criminal and not the crime’, and intelligence gathering has been put at the heart of policing. In addition multi-agency partnerships, which integrate police, probation, education, social services and health departments in a ‘joined up’ approach to crime reduction have led to new practices of information exchange. This is aimed at both identifying potential deviants for pre-emptive intervention and subjecting known criminals to ‘intensive supervision and surveillance’ in the community. The criminal record has now been enhanced and expanded with the development of searchable data-base technologies, specialist registers, and facilities to allow access to externally held databases.

These developments are not unique to the UK, and this conference seeks to explore the British experience in the context of developments in Europe and beyond and to consider the social, political and legal issues that arise from the expansion of surveillance. The conference aims to be truly inter-disciplinary and intends to include contributions from sociologists, anthropologists, geographers, criminologists, socio-legal scholars, historians, economists and social scientists researching surveillance practices and technologies.
Full announcement.

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