Episode 163

Sanctions

OFAC Sanctions Entities Linked to Illicit Financial Networks

The US Department of the Treasury's Office of Foreign Assets Control (‘OFAC’) has announced new sanctions targeting entities involved in financial misconduct. The sanctions aim to disrupt illicit networks which threaten global security and financial integrity. These measures underscore the US government's commitment to enforcing economic restrictions on individuals and organisations violating international laws. The latest action reflects ongoing efforts to combat money laundering, fraud, and other financial crimes.

Justice Department Declines Prosecution of Private Equity Firm Following Voluntary Disclosure of Sanctions Violations

The US Justice Department has declined to prosecute White Deer Management LLC, a private equity firm, after it voluntarily disclosed sanctions violations committed by its acquired company, Unicat Catalyst Technologies LLC. The violations, spanning 2014 to 2021, involved illegal sales of chemical catalysts to Iran, Venezuela, Syria, and Cuba, undermining US sanctions and export laws.

Unicat’s former CEO, Mani Erfan, pleaded guilty to conspiracy and money laundering, agreeing to a $1.6 million penalty. White Deer’s swift actions—including halting illicit transactions, retaining legal counsel, and reporting misconduct—were credited in the non-prosecution agreement. Unicat will pay over $3 million in fines.

This marks the first case under the Justice Department’s Mergers and Acquisitions Policy, which encourages firms to disclose violations post-acquisition to avoid prosecution. Authorities emphasise the ongoing crackdown on businesses aiding sanctioned entities.

Trump’s ICC Sanctions Threaten Future of International Justice

The US government, under President Donald Trump, has imposed economic sanctions on four judges of the International Criminal Court (‘ICC’), intensifying pressure on the tribunal. The sanctions, which follow previous actions against ICC Chief Prosecutor Karim Khan, have disrupted the court's operations and raised concerns about its ability to function effectively. The move is widely seen as retaliation for ICC arrest warrants issued against Israeli leaders.

Legal experts and European officials have condemned the sanctions, arguing they undermine global justice and international legal frameworks. The European Commission and human rights organisations urge collective resistance, with some calling for countermeasures. Meanwhile, lawsuits in the US challenge the sanctions as unconstitutional restrictions on free speech. Critics warn that Trump's actions could alienate allies and weaken multilateral legal institutions at a critical moment for global cooperation.

China Considers Lifting Sanctions on UK Lawmakers Amid Warming Relations

China is reviewing its sanctions on UK parliamentarians imposed in 2021 over accusations of spreading “lies and disinformation” about human rights abuses in Xinjiang. This shift comes as diplomatic relations between London and Beijing improve, marked by recent high-level meetings between Chinese officials and UK leaders. The sanctions affected nine UK citizens, including MPs and academics advocating for Uyghur rights. While Beijing has eased similar sanctions on EU figures, it remains unclear whether all UK sanctions will be lifted. The UK maintains its own sanctions against Chinese officials linked to Xinjiang human rights violations.

Macron Confident in US Support for Tougher Russia Sanctions Despite Trump's Hesitation

French President Emmanuel Macron remains optimistic that the US will back stronger sanctions against Russia, despite Donald Trump expressing concerns about the financial costs. During the G7 summit in Canada, Macron shared that he discussed the issue with Trump, who responded positively and indicated he wouldn't block new US sanctions proposed by Republican lawmakers.

However, Trump's earlier remarks suggested Europe should lead on tightening measures, arguing that sanctions cost the US "a lot of money." He left the Kananaskis gathering a day early, skipping a meeting between G7 leaders and Ukrainian President Volodymyr Zelenskyy. Meanwhile, the European Commission is pushing G7 nations to lower the Russian oil price cap from $60 to $45—a move Macron strongly supports.

UK Tightens Sanctions on Russia, Targeting Finance and Military Sectors

At the G7 Summit, Prime Minister Keir Starmer announced 30 new sanctions against Russian financial, military, and energy assets in response to Putin’s continued aggression and refusal to engage seriously in peace negotiations. These sanctions aim to cripple Russia’s economic and military capabilities, particularly focusing on its shadow oil fleet, war infrastructure, and UK-based facilitators aiding Russian operations.

A key measure includes cracking down on Putin’s shadow fleet, with sanctions imposed on 20 oil tankers and firms managing them, such as Orion Star Group LLC and Valegro LLC-FZ. These entities have been facilitating illicit oil trade, enabling Russia to bypass existing restrictions. The UK is also targeting Russia’s military intelligence, specifically the Main Directorate of Deep-Sea Research (‘GUGI’), which has been involved in surveillance of subsea infrastructure, posing a significant risk to UK security.

Additionally, two UK residents, Vladimir Pristoupa and Olech Tkacz, were sanctioned for funnelling over $120 million worth of high-tech electronics to Russia, many of which are crucial for military operations. These individuals operated through a network of shell companies, directly assisting Putin’s war effort.

Starmer emphasised that these sanctions “strike right at the heart of Putin’s war machine,” reinforcing the UK’s commitment to tightening the screws on Russia. He stressed the need to protect national security while continuing to support Ukraine’s defence efforts.

Further action is planned in collaboration with G7 partners, including tightening the Oil Price Cap, designed to weaken Russia’s revenue streams while maintaining energy market stability. Foreign Secretary David Lammy reiterated that Putin’s intransigence makes peace unattainable, emphasising that the UK and its allies “will systematically dismantle his dangerous shadow fleet and starve his war machine.”

OFSI Publishes Art Market Threat Assessment

The Office of Financial Sanctions Implementation (‘OFSI’) has published a comprehensive threat assessment which focuses on risks related to Art Market Participants (‘AMP’s) and High Value Dealers (‘HVD’s). It outlines the definitions and reporting obligations for both AMPs and HVDs concerning high-value goods (‘HVG’s) and designated persons (‘DP’s). The document highlights the likelihood of unreported HVGs owned by DPs in the UK and the threat posed by Russian DPs and their enablers. It further provides red flags for potential sanctions breaches and case studies to illustrate compliance scenarios, emphasising the importance of robust due diligence and reporting requirements to prevent financial crime.

Money Laundering

FATF-MONEYVAL Plenary Approves Key Reforms on Financial Crime and Payment Security

The Financial Action Task Force (‘FATF’) and MONEYVAL convened a joint plenary meeting in Strasbourg, addressing global risks in money laundering, terrorism financing, and proliferation financing. Among the key outcomes was the approval of updates to FATF Standards to enhance the security of cross-border payments, aligning with the G20 initiative for faster and more transparent transactions.

Additionally, Latvia's mutual evaluation under a new assessment framework was adopted, providing insights into its compliance with anti-money laundering measures. The plenary removed Croatia, Mali, and Tanzania from increased monitoring lists, while Bolivia and the Virgin Islands were newly added. Further discussions centred on strengthening financial inclusion, refining assessment methodologies, and mitigating unintended consequences of anti-money laundering policies on non-profit organisations. The MONEYVAL press release is here.

Virgin Islands Strengthens AML Measures Following FATF Monitoring

Following the Financial Action Task Force’s (‘FATF’) placement of the Virgin Islands under its “increased monitoring” process, the government has committed to implementing targeted reforms, including improving risk-based supervision, increasing money laundering investigations, and strengthening beneficial ownership regulations.

Notable progress includes amending over 20 pieces of legislation, conducting comprehensive risk assessments, and establishing a new Sanctions Unit within the Attorney General’s office. Officials emphasise that these measures will reinforce the Virgin Islands’ status as a trusted international finance centre. The updated National Strategic Action Plan will provide stakeholders with transparent progress updates. For its part, Transparency International has labelled the greylisting of BVI as an important step for financial transparency.

Singapore Police Investigate 49 Suspects in Crypto-Linked Money Laundering Case

The Singapore Police Force conducted a coordinated operation from 13th – 30th May 2025, investigating 49 individuals suspected of involvement in money laundering through cryptocurrency accounts. Officers from the Anti-Scam Command (‘ASCom’) and seven Police Land Divisions collaborated with StraitsX, a licensed digital payment provider, to identify suspicious financial activities.

Preliminary findings reveal that the suspects allegedly opened and relinquished cryptocurrency accounts or Singpass credentials for payments ranging from $400 to $3,000. Unknown parties, often communicating via Telegram or WhatsApp, guided them in providing access to their accounts, which were then used to launder scam proceeds.

Under Singapore’s Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, offenders face penalties of up to $50,000 or three years’ imprisonment. Authorities stress the importance of public vigilance, warning individuals against permitting others to use their financial accounts for illicit transactions.

Bulgaria Enhances Anti-Money Laundering and Terrorist Financing Measures

Bulgaria has strengthened its framework to combat money laundering and terrorist financing, according to a new follow-up report by MONEYVAL, the Council of Europe’s monitoring body. The country has improved its compliance with Financial Action Task Force (‘FATF’) standards, particularly in areas like customer due diligence, beneficial ownership transparency, and regulation of designated non-financial businesses and professions. Bulgaria is now compliant or largely compliant with 32 FATF Recommendations, while eight remain partially compliant. The authorities will provide an update to MONEYVAL within a year on further progress.

UK Art Market Faces Increased Scrutiny Following Ojiri Terrorism Conviction

The conviction of art dealer Oghenochuko Ojiri under the Terrorism Act 2000 has highlighted compliance risks in the UK art market, according to law firm Mishcon de Reya. Ojiri, founder of Ojiri Gallery, pleaded guilty to failing to disclose transactions linked to a sanctioned Hezbollah financier, resulting in a 2.5-year prison sentence.

This case underscores the legal obligations of art market participants (‘AMP’s), who must comply with the UK's anti-money laundering regulations, including the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002. Despite the 5th Anti-Money Laundering Directive being in place since 2020, some AMPs remain unaware of mandatory registration and reporting requirements.

Authorities emphasise that non-compliance can lead to severe penalties, including criminal charges, fines, and reputational damage. Art dealers, galleries, and auction houses are urged to implement rigorous due diligence, proactive reporting, and annual registration to avoid regulatory breaches.

Bribery and Anti-Corruption

Bangladesh Hires UK Lawyers to Recover Allegedly Stolen Funds

Professor Muhammad Yunus, chief adviser to Bangladesh’s interim government, announced that UK lawyers have been retained to assist in recovering funds allegedly siphoned off during Sheikh Hasina’s tenure. Estimates suggest approximately $234 billion was illicitly transferred from Bangladesh, with significant portions suspected to be held in the UK.

The International Anti-Corruption Coordination Centre, hosted by the UK’s National Crime Agency, is considering support for Bangladesh’s efforts, though the NCA has declined to confirm any formal investigation. Yunus praised the British government for its responsiveness in addressing the issue.

During his UK visit, Yunus met business secretary Jonathan Reynolds to discuss economic collaboration but was unable to secure a meeting with Prime Minister Keir Starmer. Upon returning to Dhaka, Yunus emphasised the growing depth of relations between Bangladesh and the UK.

ICPC Urges National Obstetric Fistula Centre to Lead Anti-Corruption Efforts

The Independent Corrupt Practices and Other Related Offences Commission (‘ICPC’) in Nigeria has called on the National Obstetric Fistula Centre (‘NOFIC’) in Katsina to champion integrity and fight corruption. During a one-day sensitisation event, ICPC officials emphasised behavioural change as key to fostering a corrupt-free work environment. NOFIC leadership reaffirmed their commitment to transparency and accountability in healthcare service delivery. The programme featured presentations on workplace ethics and anti-corruption laws, with over 80 attendees engaging in discussions on institutional integrity.

ICPC’s Two-Year Drive: Major Gains in Nigeria’s Anti-Corruption Battle

Over the past two years, Nigeria’s Independent Corrupt Practices and Other Related Offences Commission (‘ICPC’) has made significant strides in curbing corruption across public and private sectors. Key achievements include:

-          Legal Actions: 2,524 corruption petitions received, leading to 914 investigations, 159 court cases, and 36 convictions.

-          Financial Recoveries: Over ₦94.3 billion reclaimed, alongside ₦19.8 billion in prevented financial mismanagement.

-          Project Monitoring: Oversight of 3,221 government-funded projects, ensuring proper execution and accountability.

-          Institutional Reforms: Implementation of 676 Ethics and Integrity Compliance Scorecards, improving governance across ministries and agencies.

-          Public Engagement: 1,734 anti-corruption events held, reaching 449,122 people, alongside a rebranded TV programme, Transparency File, and Nigeria’s first anti-corruption podcast, EthicsPod.

The ICPC’s proactive efforts—spanning investigations, financial oversight, institutional integrity, and public education—underscore its role in safeguarding Nigeria’s governance framework.

Fraud

FBI Warns of Rising Elder Fraud Cases Ahead of Awareness Day

Ahead of World Elder Abuse Awareness Day on 15th June, the FBI was highlighting the growing threat of financial scams targeting seniors. Fraudsters exploit older individuals through investment schemes, technical support scams, and romance fraud, leading to devastating financial losses.

According to the FBI’s Internet Crime Complaint Center (‘IC3’), elder fraud complaints surged by 46% in 2024, totalling $4.885 billion in losses. The Boston Division alone recorded losses exceeding $134 million across Massachusetts, Maine, New Hampshire, and Rhode Island. Officials warn that many cases go unreported due to victims’ embarrassment or lack of awareness.

The FBI urges seniors to remain cautious of unsolicited calls and high-pressure tactics, recommending verification of unknown contacts and immediate reporting of suspected fraud via IC3.gov. Collaboration with state and federal partners continues to strengthen efforts to combat elder exploitation.

FEMA Warns of Disaster-Related Fraud in Oklahoma

Following recent fires and straight-line winds in Oklahoma, FEMA has issued a warning about fraud and identity theft targeting disaster survivors. Scammers have attempted to apply for FEMA assistance using stolen personal information.

FEMA urges residents to be vigilant, advising them to verify inspectors' credentials and report suspected fraud to the FEMA Fraud Branch. Officials emphasise that FEMA representatives never charge fees for assistance, inspections, or application support.

Survivors who receive unexpected FEMA communications or suspect identity theft can report concerns to local authorities or the Oklahoma Attorney General’s Consumer Protection Unit. Additional guidance is available through the Federal Trade Commission’s identity theft resources.

University of Portsmouth and Isle of Wight College Foster Fraud Prevention Innovation

The University of Portsmouth hosted a fraud prevention competition, engaging Isle of Wight College students in tackling financial crime through creative solutions. Four student teams presented video projects addressing issues such as victim grooming and impersonation scams. The winning team, from the Level 3 Year 2 Uniformed Public Services programme, impressed judges with a presentation on holiday accommodation fraud.

The event strengthened academic partnerships and allowed students to develop research, teamwork, and problem-solving skills. Experts from the university and the Hampshire and Isle of Wight Constabulary praised the participants' innovative approaches. Students highlighted their appreciation for the opportunity, emphasising how the experience will shape their future careers.

City of London Police Launch Street Campaign to Combat Romance Fraud

New data from City of London Police reveals romance fraud losses in the UK exceeded £106 million in the past year, with victims losing an average of £11,222 each. Reports of such scams have surged by 9%, highlighting the growing threat of emotional and financial manipulation. To raise awareness, the police transformed four London streets—Love Lane, Rose Street, Honey Lane, and Bank—into hubs for fraud prevention messaging, using digital billboards to warn the public.

Detective Superintendent Oliver Little stressed the psychological harm and betrayal that romance fraud inflicts, debunking myths that only elderly women are affected. While male victims now slightly outnumber female victims, women often experience greater financial losses due to prolonged engagement with scammers. The 50-59 age group saw the highest financial impact, losing over £22 million collectively.

Authorities urge vigilance: never send money to someone you haven’t met in person, verify identities, and seek advice from trusted sources before making financial commitments.

Market Abuse

French Regulator Fines SMCP and Shareholders €1.72 Million for Market Violations

The AMF Enforcement Committee – France’s financial markets regulator – has fined the shareholders of SMCP €1.7 million for breaching reporting obligations and disseminating false information. The issuer, SMCP, was also fined €20,000 for failing to maintain confidentiality of inside information. European TopSoho, SMCP’s former majority shareholder, was found guilty of market manipulation, with its leader, Ms. Chenran Qiu, personally fined €1 million. Dynamic Treasure Group, involved in the share transfer, was fined €300,000. Appeals may be filed against the decision.

Other Financial Crime News

UNODC and IPU Expand Cooperation to Strengthen Global Crime Prevention

The United Nations Office on Drugs and Crime (‘UNODC’) and the Inter-Parliamentary Union (‘IPU’) have reinforced their partnership to combat corruption, transnational organised crime, terrorism, and cybercrime. Building on prior collaboration in legislative assistance—primarily focused on counter-terrorism—the new agreement broadens their scope to include human trafficking, firearms trafficking, cybercrime, violence against women in politics, and governance research.

Under the two-year implementation plan, UNODC and IPU will conduct awareness campaigns, develop model laws, support inter-parliamentary networks, and organise regular summits to strengthen global legislative frameworks. The agreement, signed virtually by UNODC Executive Director Ghada Waly and IPU Secretary-General Martin Chungong, aims to enhance parliamentarians' capability in implementing UN standards and norms in crime prevention and criminal justice.

The IPU is a global organisation of national parliaments, founded in 1889 to promote peace, democracy, and sustainable development worldwide. It facilitates parliamentary diplomacy, strengthens legislative institutions, and supports initiatives on human rights, gender equality, youth participation, and climate action.

The IPU has 181 member parliaments and works closely with the United Nations, contributing to governance discussions and policy frameworks. Its headquarters are in Geneva, Switzerland, with offices in New York and Vienna.

Cybercrime

UK Banks Under Siege: Cybersecurity Becomes Biggest Expense

UK banks are facing relentless cyber-attacks, with executives warning that cybersecurity has become their largest financial burden, according to The Guardian. The article highlights how devastating breaches—like those at M&S, the Co-op, and Harrods—reinforce the high stakes for financial institutions. A major bank hack could cripple the financial system, blocking payments, triggering bank runs, and disrupting daily transactions.

To counter this, banks are investing billions in security, with HSBC alone allocating hundreds of millions. Cyber resilience measures, including ethical hacking programmes and cyber war games coordinated by the Bank of England, aim to strengthen defences. However, experts warn that evolving threats mean no system is ever fully secure.