Embedded Files
14 April– 20th April 2025
Sanctions
Sanctions on the ICC
This week’s sanctions news starts in the US, where a claim has been filed against Donald Trump’s executive order imposing sanctions on the International Criminal Court (‘ICC’), with US human rights advocates arguing that it violates constitutional rights. The order penalises American citizens and organisations for assisting the ICC prosecutor, Karim Khan, who is investigating alleged war crimes committed in Gaza. The plaintiffs, backed by the American Civil Liberties Union (‘ACLU’), assert that the sanctions prevent them from providing evidence and engaging with the court, limiting their free speech and advocacy efforts. The action seeks to have the order overturned on First Amendment grounds.
Extension of Russian sanctions
In news of continued sanctions against Russia from the US, the President has extended by one year the sanctions against Russia originally introduced by President Biden in April 2021. The sanctions were imposed by Executive Order 14024, and expanded in March 2022 following Russia's invasion of Ukraine. Under US law, national emergencies declared by executive order last for one year unless renewed.
Sanctions on facilitators
The US Department of the Treasury's Office of Foreign Assets Control (‘OFAC’) has imposed sanctions on Shandong Shengxing Chemical Co., Ltd., an independent Chinese refinery, for purchasing over a billion dollars' worth of Iranian crude oil. These transactions included dealings with a front company linked to Iran’s Islamic Revolutionary Guard Corps-Qods Force (‘IRGC-QF’). Additional sanctions have been placed on multiple companies and vessels which facilitate Iranian oil shipments to China through a clandestine "shadow fleet."
The sanctions fall under Executive Order 13902, targeting Iran’s petroleum sector. The US government emphasises that entities engaging in Iranian oil trade risk severe penalties. OFAC has also updated its advisory to help the global shipping industry recognise and prevent sanctions evasion related to Iranian oil. As a result of these measures, all US-controlled assets of designated individuals and companies are blocked.
OFAC has also sanctioned the International Bank of Yemen (‘IBY’) for financially supporting the Iran-backed Houthi group, Ansarallah. The action includes sanctions on IBY officials Kamal Hussain Al Jebry, Ahmed Thabit Noman Al-Absi, and Abdulkader Ali Bazara. This move is part of broader efforts to disrupt the Houthis’ access to international financial networks and curb their attacks on commercial shipping in the Red Sea. IBY has allegedly facilitated transactions for Houthi-affiliated businesses via the SWIFT network, including oil purchases, sanctions evasion, and asset confiscation from opponents.
Under the sanctions, IBY's assets in the US are frozen, and American individuals and businesses are prohibited from engaging in financial transactions with the bank or its sanctioned officials. The Treasury Department has reinforced its commitment to supporting Yemen’s internationally recognised government in securing its banking system from Houthi exploitation.
ISIS report on Iran
In news relating to Iran, the Institute for Science and International Security has warned that Iran's nuclear program has reached a critical point, with heightened concerns that it could take on military and weapons-related dimensions imminently, despite the scale of sanctions across the globe. Since February 2024, Iran's nuclear threat has worsened significantly, with shorter timeframes to build nuclear weapons. The country’s refusal to cooperate with the International Atomic Energy Agency (‘IAEA’) has amplified uncertainty, particularly as Iran manufactures advanced centrifuges outside IAEA monitoring. Centrifuges were the subject of the most recent OFAC sanctions. In consequence of these latest developments, the Institute has raised Iran’s threat score from 151 to 157 out of 180, marking the second consecutive time the risk level has been classified as "extreme danger." Strategically, it is difficult to estimate what will happen next, but it is likely that renewed sanctions designations and enforcement, even secondary sanctions, will be on the cards.
Rewards to catch leaders of Mexican cartel
The US Department of State has announced rewards totalling up to $8m for information leading to the arrest or conviction of Johnny Hurtado Olascoaga ('Pez’) and his brother Jose Alfredo Hurtado Olascoaga ('Fresa'), leaders of the La Nueva Familia Michoacana (‘LNFM’) cartel in Mexico. The rewards are part of the Narcotics Rewards Program, with up to $5m for Johnny and $3m for Jose Alfredo.
LNFM was designated as a Foreign Terrorist Organization and Specially Designated Global Terrorist by the US Secretary of State in February 2025. The cartel operates in Mexico and is responsible for trafficking substantial quantities of methamphetamine, heroin, and cocaine into the US.
This announcement follows the indictment of the Hurtado Olascoaga brothers in the Northern District of Georgia for conspiracy to manufacture and distribute narcotics, including heroin, methamphetamine, cocaine, and fentanyl. The US Treasury’s Office of Foreign Assets Control (‘OFAC’) also imposed sanctions on them and two other LNFM members.
Orban ally delisted
The US government has decided to remove sanctions from Antal Rogán, a close aide to Hungarian Prime Minister Viktor Orbán. This move comes amid efforts to strengthen diplomatic ties between the two countries. US Secretary of State Marco Rubio also engaged in discussions with Hungary's foreign minister regarding cooperation. The decision signals a shift in the approach toward Hungary's leadership, potentially impacting broader geopolitical relations. Human Rights First and Transparency International US have condemned the decision.
Sanctions on criminal network
In the UK this week, sanctions have been imposed on the Iranian-backed Foxtrot criminal network and its leader, Rawa Majid, due to their involvement in attacks against Jewish and Israeli targets in Europe. The sanctions include an asset freeze, travel ban, and director disqualification. This move is part of the UK's broader response to Iranian-hosted threats and follows previous actions against Iran, including placing it on the enhanced tier of the Foreign Influence Registration Scheme. Since 2022, the UK has responded to over 20 Iran-linked plots posing potential risks to British citizens. The US also sanctioned Majid and the Foxtrot Network in March 2025. The Foreign Influence Registration Scheme is a UK government initiative designed to increase transparency around foreign state-directed activities. The Notice is here.
Sanctions variations
In the UK on the Russia financial sanctions regime, the Office of Financial Sanctions Implementation has made two variations respecting Paramount Energy and Commodities DMCC and Niels Oscar Troost. These entries remain subject to Asset freeze, Director Disqualification Sanction, Transport sanctions, Trust Services Sanctions, with Troost also remaining subject to a Travel Ban. Troost is a Dutch national who is understood to be linked to Paramount Energy & Commodities SA, involved in activities supporting Russia’s government. Paramount Energy & Commodities DMCC is a Dubai-based company operating in Russia’s energy sector and deemed strategically significant to Moscow. Troost is currently challenging his EU designation. The Notice is here.
OFSI has also amended an entry on the Global Anti-Corruption Sanctions regime relating to Marina Tauber. Tauber is a Moldovan politician and a member of the Moldovan Parliament. She has been associated with the Șor Party, a political movement led by Ilan Shor. Tauber has faced multiple sanctions and legal actions due to allegations of corruption and ties to pro-Russian activities. Tauber has also been sanctioned by Canada, the European Union, and the United States for her role in financial misconduct and political activities linked to Russian interests. The Notice is here. The Consolidated List has been updated.
EU sanctions designations
In the European Union, sanctions have been imposed on seven individuals and two entities in Iran for serious human rights violations, including the judiciary's role in arbitrary detentions. These sanctions target Shiraz Central Prison and the First Branch of the Revolutionary Court of Shiraz, as well as officials linked to Iran’s penal system. The measures include the typical range of asset freezes, travel bans, and restrictions on financial transactions. The EU has increasingly tightened sanctions against Iran since 2022, citing concerns over executions, repression of freedoms, and human rights abuses. The legal acts implementing these sanctions are published in the Official Journal of the EU. Staying with the EU, it may be that the bloc is preparing its 17th package of sanctions against Russia, which are expected to be discussed at an upcoming EU foreign ministers meeting in May. EU foreign policy chief, Kaja Kallas, confirmed the ongoing work on these measures but did not provide details. This latest round of sanctions continues the bloc’s efforts to pressure Russia over its actions, especially in light of the recent Russian attack on Sumy.
Money Laundering
Arrests as part of money laundering investigation
This week’s money laundering news starts in Europe, specifically the Netherlands, where Dutch authorities have arrested four men in a large-scale investigation into money laundering and tax fraud, targeting two companies linked to criminal financial activities. The Financial Intelligence and Investigation Service found that the suspects failed to file payroll and sales tax returns while allegedly laundering illicit funds through corporate and personal expenses. The investigation was triggered by suspicious transaction reports flagged by the Financial Intelligence Unit, leading to coordinated raids across Amsterdam, Rotterdam, and Hoofddorp, where authorities seized records and assets. The scheme reportedly involved "katvangers," or figureheads, to obscure illicit transactions through multiple company bank accounts. The 56-year-old main suspect has been detained for at least 14 days as the Dutch Public Prosecution Service continues its probe into complex financial crime.
MONEYVAL meeting in Latvia
The Council of Europe’s Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (‘MONEYVAL’) recently held a face-to-face meeting with Latvian authorities from 14 to 16 April 2025 in Strasbourg, France. This meeting was part of its sixth round of mutual evaluations, assessing Latvia’s anti-money laundering and counter-terrorism financing measures. Latvia is the first country to undergo assessment under this new evaluation round. The meeting allowed Latvian officials and evaluators to exchange views on the draft Mutual Evaluation Report ahead of MONEYVAL’s plenary session in June 2025, which will be held jointly with the Financial Action Task Force (‘FATF’).
Virgin Islands government publishes first national risk assessment
The Government of the Virgin Islands has released its first National Risk Assessment on Money Laundering, Terrorist Financing, and Proliferation Financing risks associated with legal persons and arrangements in the Territory. This assessment aligns with the updated Financial Action Task Force (‘FATF’) Recommendations 24 and 25 and highlights potential vulnerabilities in corporate structures such as BVI Business Companies, trusts, and limited partnerships.
The report finds that, while regulatory oversight is strong, complex international financial structures introduce inherent risks. The residual risk for money laundering was rated as “Medium High,” emphasising the need for ongoing vigilance, regulatory improvements, and enforcement.
Premier Natalio Wheatley described the publication as a major milestone in strengthening the Virgin Islands' anti-money laundering and counter-terrorism financing measures. The assessment, led by the National Anti-Money Laundering Coordinating Council (‘NAMLCC’), involved collaboration between multiple government agencies and consultations with private-sector professionals. It will guide future policy reforms, enforcement strategies, and international cooperation efforts.
GBIC responds to FATF consultation
And finally on money laundering news this week, the German Banking Industry Committee (‘GBIC’) has commented on the Financial Action Task Force (‘FATF’) public consultation on revisions to Recommendation 16, which focuses on payment transparency. The GBIC comment emphasises the need to balance anti-money laundering and counter-terrorist financing efforts with efficient payments and data protection. GBIC suggests revising several proposed provisions to achieve this balance.
Fraud
University develops machine-learning fraud detection
On fraud news this week, engineers at Florida Atlantic University (‘FAU’) have developed a machine learning-based fraud detection method to tackle financial fraud in industries such as health care and finance. Traditional fraud detection struggles due to imbalanced datasets. The FAU researchers created a novel labelling method which works without relying on manually labelled data, making fraud detection more efficient and scalable. Their approach outperformed existing methods, reducing false positives and improving accuracy. The study highlights the potential of AI in combating fraud, offering a cost-effective and reliable solution for large-scale applications.
Bribery and Corruption
Joint report on anti-corruption progress in Lebanon
On bribery and corruption news this week, we start in Lebanon, where a joint report has been published by the Anti-Corruption Resource Centre and Transparency International – Mitigating corruption in the reconstruction of Lebanon. Lebanon's reconstruction efforts following recent crises, including the Beirut port explosion and the conflict between Israel and Hezbollah, are a source of significant corruption risk, particularly through patronage networks, clientelism, and state capture. These issues undermine planning, public contracting, and service delivery in sectors such as construction and waste management. While anti-corruption laws have been passed and institutions like the National Anti-Corruption Commission and Public Procurement Authority have been established, implementation remains weak due to limited capacity, low compliance, and resistance from political elites. International donors are wary of these challenges and often bypass state institutions and channel aid through trusted local and international networks while simultaneously working to strengthen Lebanese oversight bodies. In order to mitigate corruption, best practice outlined in the report includes: Conducting thorough emergency needs assessments; performing due diligence on implementing partners; and, enhancing transparency by publishing project-related documents; and ensuring independent audits.
GRECO reports on Spain’s anti-corruption progress
Now to the Council of Europe Group of States against Corruption (‘GRECO’) which has announced the publication of two reports assessing Spain's progress in implementing anti-corruption recommendations.
The first report, adopted in December 2023, found that Spain had not fully implemented any of the recommendations issued in 2019 to prevent corruption in the central government and law enforcement agencies. Thirteen recommendations were partly implemented, while six remained unaddressed. As a result, Spain was placed under GRECO’s non-compliance procedure, with a deadline to report improvements by the end of 2024. The report acknowledged the adoption of the SIAGE integrity framework but urged more tailored measures for top executive functions.
The second report, evaluating recommendations issued in 2013 concerning parliamentarians, judges, and prosecutors, showed no progress since 2022. Seven recommendations were fully implemented, three were partly implemented, and one regarding the selection system for the General Council of the Judiciary remained unresolved. This report concluded Spain’s compliance review for these groups.
Both reports were published at the request of Spanish authorities, following GRECO's procedural rules.
SFO charges UK insurance broker with foreign bribery
And finally on bribery and corruption news this week, the Serious Fraud Office (‘SFO’) in the UK has charged United Insurance Brokers Limited (‘UIBL’), a UK insurance company, with failing to prevent bribery in Ecuador. The case involves allegations that UIBL's US-based intermediaries paid bribes to Ecuadorian officials in exchange for re-insurance contracts worth $38m between October 2013 and March 2016. UIBL allegedly received a $6.2m commission, with $3m reportedly funnelled to intermediaries who then paid bribes to secure contracts with Ecuadorian state insurers, covering sectors such as water and electricity.
If this case proceeds to trial, it will mark the first time an SFO 'failure to prevent bribery' charge is heard by a jury. Nick Ephgrave QPM, Director of the SFO, emphasised the UK’s commitment to stamping out international bribery, underscoring corporate accountability. UIBL representatives are set to appear in Westminster Magistrates’ Court on 7 May 2025 to face charges.
Market Abuse
Lawmakers propose insider dealing restrictions for US politicians
Now, in a follow-up to last week’s story about tariffs, the impact on financial markets, and allegations of market manipulation, it is understood that Democratic lawmakers in the US Congress are looking to limit stock trading by federal policymakers. As indicated, the decision to impose and then reverse tariffs led to accusations that markets were being manipulated, raising concerns about possible insider trading among administration officials and congressional members. Prominent Democrats, including Representative Alexandria Ocasio-Cortez and Senator Adam Schiff, have called for investigations into whether lawmakers or officials profited from these market shifts. Ocasio-Cortez has been leading efforts to ban members of Congress from owning or trading stocks while in office, arguing that access to sensitive information should not be used for personal financial gain. House Minority Leader Hakeem Jeffries expressed support for restrictions on congressional stock trading, though he did not explicitly back a full ban on stock ownership.
Other Financial Crime News
DoJ updates on compensation for victims of crime
In other financial crime news this week, the US Justice Department has announced that it has surpassed $12 billion in compensation to victims of crime since 2000, using assets forfeited from criminal activities. This milestone highlights the department's support for victims of a range of crimes, including fraud, human trafficking, and cybercrimes. Recent cases include compensations for victims of Bernie Madoff's Ponzi scheme, email scams, and forced labour. These efforts aim to help victims recover from financial and emotional losses caused by criminal acts.
UK government investment in quantum technology
In the UK, government has announced a £121m investment in quantum technology to combat fraud, money laundering, and crime, while also reinforcing its leadership in quantum research. This funding, unveiled on World Quantum Day, aims to accelerate the deployment of quantum computing, networking, and sensing solutions, with institutions like HSBC and the National Quantum Computing Centre exploring quantum applications for anti-money laundering detection. The initiative is part of the UK's National Quantum Technologies Programme, supporting early-stage research, commercial adoption, and talent development. Quantum technology has a wide range of applications including in cybersecurity, drug discovery, financial modelling, climate science, and artificial intelligence, among others.
NCA announces outcome of Operation Machinize
Staying in the UK, the National Crime Agency has announced the outcome of Operation Machinize, a three-week crackdown which targeted barbershops and other cash-intensive businesses suspected of facilitating money laundering and other organised crimes across England. Law enforcement visited 265 premises, froze over £1m in bank accounts, executed 84 warrants, and arrested 35 individuals. Authorities questioned 55 people on immigration status, safeguarded 97 individuals from potential modern slavery, and seized cash, illicit tobacco, vapes, and cannabis plants. Crime gangs reportedly use businesses like barbershops and vape shops to integrate criminal cash into the financial system, hindering investigations. The operation, coordinated by the National Economic Crime Centre, involved 19 police forces and multiple agencies, demonstrating the UK’s determination to combat financial crime and protect the integrity of its high streets.
UK issues first INTERPOL Silver Notice
The UK has issued its first-ever INTERPOL Silver Notice to trace and recover criminal assets linked to Anopkumar Maudhoo, a convicted fraudster who allegedly made £8.5m through large-scale conveyancing fraud. Maudhoo, who used multiple aliases, admitted to 76 offences, including fraud and money laundering. The Silver Notice, part of an INTERPOL pilot involving 52 countries, helps identify laundered assets such as properties, vehicles, and financial accounts.
The National Crime Agency (‘NCA’), alongside the Eastern Region Special Operations Unit (‘ERSOU’), is investigating Maudhoo’s assets, with some already seized, including 19 high-value cars and a speedboat. The initiative is part of broader UK efforts to enhance international cooperation in tackling fraud and financial crime. Security Minister Dan Jarvis emphasised the government’s commitment to preventing fraud and prosecuting offenders.
UK Gambling Commission charges alleged election gamblers
The UK Gambling Commission has charged 15 individuals with offences under the Gambling Act 2005 for allegedly using confidential information about the timing of the 2024 General Election to gain an unfair advantage in betting markets. The investigation, launched in June 2024, determined that the accused had prior knowledge of the proposed election date, which constitutes cheating under section 42, Gambling Act 2005. The charged individuals are scheduled to appear at Westminster Magistrates Court on 13th June 2025.
FCA brings charges for running an unauthorised business and misleading investors
The Financial Conduct Authority has brought charges against John Burford for running an unauthorised business and misleading investors. Burford allegedly accepted money from over 100 investors between 2020 and 2023, managing investments without proper authorisation. He promoted subscription services and investment funds through his company, Financial Trading Strategies Limited, but is accused of misrepresenting fund values and losses. The FCA claims he generated over £1m through fraudulent activities. Burford is set to appear in court on May 23, 2025, facing charges under the Financial Services and Markets Act 2000 and the Companies Act 2006. Penalties could include fines and imprisonment.
FCA speech on enforcement approach
Therese Chambers, joint executive director of enforcement and market oversight at the UK's Financial Conduct Authority (‘FCA’), has delivered a speech at NYU’s Programme on Corporate Compliance and Enforcement Spring Conference. She emphasised the importance of international cooperation in tackling financial misconduct and detailed the FCA’s enforcement priorities for the next five years.
The FCA aims to deter financial crime by keeping illicit funds out of the financial ecosystem, taking swift action against fraud within regulated firms, maintaining market integrity, and developing a safe crypto regulatory framework. Chambers highlighted recent enforcement actions, including penalties for major UK banks and the prosecution of individuals involved in financial misconduct.
She also underscored the FCA's commitment to faster investigations, improved transparency, and collaborative efforts with US agencies. The speech reinforced the FCA’s role in ensuring London remains a trusted international financial centre.
Interview with Nick Ephgrave
And finally on other financial crime news this week, the Law Society Gazette in the UK has interviewed Nick Ephgrave, head of the UK's Serious Fraud Office (‘SFO’). In the article, he discussed the agency’s agenda for 2025-26, focusing on making investigations faster, bolder, and more aggressive. His strategy includes leveraging policing techniques, using covert methods, and improving intelligence operations. The SFO has launched an asset confiscation enforcement team to recover financial assets and has developed a crypto expertise team to track illicit cryptocurrency transactions. Ephgrave also aims to streamline casework, reduce complexity, and accelerate disclosure processes using machine learning.
Cybercrime
Cyberattack on IKEA
The cybercrime news this week starts in Europe and the cyber-attack on the Fourlis Group, which operates IKEA stores in Greece, Cyprus, Romania, and Bulgaria. It suffered a ransomware attack in November 2024, leading to financial losses of €20m. The attack primarily affected online IKEA shops, disrupting operations just before Black Friday on 27th November 2024. By December 2024, the company had lost €15m in sales, with an additional €5m in damages accumulating in 2025. A forensic investigation found no evidence of data theft. No ransomware group has claimed responsibility for the attack.
US report on cyber risk to aviation
In news of a significant report from the US Cyberspace Solarium Commission (‘CSC’), which has published a new report – Turbulence Ahead: Navigating the Challenges of Aviation Cybersecurity – which highlights the growing cybersecurity threats facing the US aviation industry, emphasising the need for stronger defence against increasingly sophisticated cyberattacks. The report identified the increase in cyber threats across the aviation sector, including airlines, airports, and air traffic control. The sector is a prime target for cyberattacks because of the scale of disruption which can be caused. It is also noted that there are regulatory challenges from fragmented oversight, with the FAA and TSA struggling to coordinate cybersecurity regulations effectively. In light of this, the report makes a number of policy recommendations. First, it recommends that a modernised technology framework should be cybersecurity focused. The FAA should implement a comprehensive cybersecurity enhancement program to protect Air Traffic Control (‘ATC’) systems, complementing the ongoing NextGen initiative. This will ensure cybersecurity measures are embedded in modernisation efforts. Secondly, that there should be a cybersecurity infrastructure grant programme. Here, the FAA and Department of Defence should launch a cybersecurity grant programme for strategic airports vital to national defence. The program would provide targeted financial support to 69 designated airports, prioritising those based on defence importance, passenger and cargo volume, and location. Grant recipients would need to assess vulnerabilities and address the most critical risks.
Thirdly, there should be comprehensive risk assessments for high-impact airports. The TSA, FAA, and CISA should collaborate to conduct in-depth cybersecurity risk assessments on hub-and-spoke and point-to-point networks. These assessments would identify vulnerabilities, inform infrastructure modernisation, and ensure resilience for military mobility. Fourthly, cybersecurity regulations ought to be harmonised to reduce compliance inefficiencies and improve risk management. Fifthly, and finally, Aviation Cyber Initiative (‘ACI’) ought to be strengthened. The FAA should amplify the ACI’s tracking and coordination mechanisms in order to improve cybersecurity in the sector. Increased funding for ACI’s joint research and development programmes would drive innovation and preparedness. Taken together, these recommendations aim to modernise aviation cybersecurity, improve regulatory oversight, and enhance resilience against cyber threats.
NATO holds cyberattack exercise
At a global level, NATO has announced that last week it held an exercise in Czechia, where representatives from 20 Allied governments and national agencies tested NATO’s ability to coordinate responses to major cyber threats affecting critical national infrastructure. The exercise focused on NATO’s Virtual Cyber Incident Support Capability (‘VCISC’), which was launched at the 2023 Vilnius Summit. The VCISC acts as a clearing house for cyber assistance, linking Allies requesting support with designated counterparts and facilitating offers such as malware analysis, cyber threat intelligence, and digital forensics. With the increasing frequency of malicious cyber activities targeting critical systems, government services, and military operations, the importance of ensuring that NATO members have a coordinated and intelligent response. Indeed, the issue is amplified by shifting global geo-politics following the Russian invasion of Ukraine – where cyber warfare has operated alongside conventional warfare – and the change in administration in the US.
French cybersecurity agency publishes guide on remediation strategy
In France, a guide has been published by ANSSI, the French cybersecurity agency, on remediation strategies for Active Directory Tier 0 following a major cybersecurity incident. It provides a conceptual framework for restoring control over a compromised IT system, specifically focusing on rebuilding the trusted core of Active Directory. The guide outlines key measures for technical teams responsible for reconstruction operations, offering a structured approach to recovery and security reinforcement.
Reports China admits involvement in cyberattack
And finally on cyberattack news this week, it is being reported by the Wall Street Journal, that in a December 2024 meeting, China privately admitted its involvement in the Volt Typhoon cyberattacks, which targeted US critical infrastructure, including energy, communications, transportation, and water industries. The Wall Street Journal interprets this as a warning to the US regarding Taiwan, as tensions escalate. US officials are considering cyber strikes against China, while experts warn of potential Chinese retaliation through hacking groups like Salt Typhoon. The Trump administration’s mass federal layoffs have raised concerns about cybersecurity vulnerabilities in the US. Taiwan’s semiconductor industry plays a crucial role in the conflict, as computer chips are essential for modern technology, AI, and military systems.
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