Embedded Files
20th June – 22nd June 2025
Sanctions
UK Removes Serbian Businessman from Global Anti-Corruption Sanctions List
On 18th June 2025, the Office of Financial Sanctions Implementation (‘OFSI’), announced the removal of Slobodan Tešić from its Global Anti-Corruption Sanctions Regulations 2021 regime. Tešić—previously sanctioned for allegedly bribing senior Bosnian officials—has been delisted from the UK’s Consolidated List and is no longer subject to an asset freeze.
This update follows a routine review process under the Sanctions and Anti-Money Laundering Act 2018. It does not automatically imply exoneration but reflects a change in designation status. The announcement reaffirms that failure to comply with UK sanctions remains a criminal offence.
UK Adds Ugandan ISIL Facilitator to Terror Sanctions List
On 18th June 2025, the UK updated its ISIL (Da’esh) and Al-Qaida financial sanctions regime to include Abubakar Swalleh (also known as Tom Kiyurige or Abubaker Swaleh), a Ugandan national currently imprisoned in Luzira, Kampala. Swalleh has been designated for his role as an ISIL facilitator since 2018, allegedly providing financial, logistical, and recruitment support for ISIL in East and Southern Africa.
His designation imposes a UK asset freeze, prohibiting the handling of any funds or economic resources linked to him without a specific licence from HM Treasury’s Office of Financial Sanctions Implementation (‘OFSI’). This action aligns with UN sanctions policy and UK national security objectives under the 2019 ISIL and Al-Qaida (EU Exit) Regulations.
Failure to comply with these measures may constitute a criminal offence. The notice includes procedural guidance for financial institutions and reporting obligations to OFSI.
US Sanctions Five CJNG Leaders Under Counterterrorism Authorities
On 18th June 2025, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) sanctioned five senior leaders of the Jalisco New Generation Cartel (‘CJNG’) under Executive Orders 14059 and 13224. Designated individuals include CJNG’s leader Ruben Oseguera Cervantes (“El Mencho”) and four other operatives involved in fentanyl trafficking, extreme violence, and terrorist activities.
Among them, Ricardo Ruiz Velasco was named as the prime suspect in the murder of Mexican influencer Valeria Marquez during a livestream. OFAC cited CJNG's use of murder, torture, and drug trafficking across Mexico and the US, including operations through the Port of Manzanillo and clandestine labs.
Money Laundering
FATF Tightens Global Standards on Cross-Border Payment Transparency
The Financial Action Task Force (‘FATF’) has updated its international standards to bolster the transparency and security of cross-border payments, aiming better to detect and prevent financial crime. Announced at the June 2025 Plenary, these reforms revise Recommendation 16—also known as the “Travel Rule” in the virtual asset space—and reflect a concerted effort to keep pace with innovations in digital finance.
Key changes include standardised information requirements for peer-to-peer cross-border payments exceeding $/€1,000, requiring sender and recipient details such as name, address, and date of birth. The revisions also clarify responsibilities within the payment chain, ensuring that the financial institution initiating the payment maintains the integrity of the transmitted data. These steps are designed to reduce fraud, enable better tracking of illicit flows, and make compliance simpler for financial institutions.
In addition, the FATF now mandates the adoption of technologies which verify recipient banking details—an effort to reduce customer-facing errors and fraud. Clarifications have also been issued regarding exemptions for card-based payments made for goods and services. The revised standards support the G20 roadmap for faster, cheaper, and more transparent cross-border payments, and were shaped by two rounds of public consultation with over 300 responses from across the public and private sectors.
The updated measures are to be implemented by the end of 2030, with FATF pledging further guidance to help industry adjust.
Bulgaria, Cyprus, and Moldova Make Notable Strides in Anti-Money Laundering Compliance, Reports MONEYVAL
MONEYVAL, the Council of Europe’s anti-money laundering monitoring body, released follow-up reports assessing how well Bulgaria, Cyprus, and the Republic of Moldova have addressed FATF recommendations.
Bulgaria improved its technical compliance across several areas, including terrorism financing sanctions and beneficial ownership, now rated compliant on eight, largely compliant on 24, and partially compliant on eight recommendations.
Cyprus addressed deficiencies in correspondent banking and showed some progress with non-profit oversight. It’s now compliant on 16, largely compliant on 20, and partially compliant on two recommendations.
Moldova enhanced its due diligence measures in high-risk sectors like casinos and real estate, earning ratings of compliant on nine, largely compliant on 28, and partially compliant on three recommendations.
The reports are all linked.
Namibia Added to EU High-Risk List Following FATF Greylisting, Amid Ongoing Reform Support
On 10th June 2025, the European Commission proposed adding Namibia to the EU list of high-risk countries for money laundering and terrorism financing, aligning with FATF’s February 2024 decision to ‘grey list’ Namibia due to strategic deficiencies in its AML/CFT framework.
If approved by the European Parliament and Council, the listing will trigger enhanced due diligence measures for EU-based financial institutions transacting with Namibia. This is a compliance mechanism, not a sanction—it does not restrict trade or funding.
Despite the listing, the EU continues to support Namibia through technical assistance and training with national agencies, aiming to help it implement the FATF Action Plan and eventually exit both the FATF and EU high-risk lists. The EU reaffirmed its strong partnership with Namibia, emphasising shared goals for transparent and secure global finance.
UK Triples Reporting Threshold to Streamline Anti-Money Laundering Regime
On 17th June 2025, the UK Parliament approved the Proceeds of Crime (Money Laundering) (Threshold Amount) (Amendment) Order 2025, raising the financial threshold for two key anti-money laundering exemptions from £1,000 to £3,000. This change aims to ease the burden on both law enforcement and private-sector institutions by reducing the number of low-value Defence Against Money Laundering Suspicious Activity Reports (‘DAML SAR’s) which must be filed.
Under the new threshold, firms such as banks and payment providers no longer need to seek consent for transactions under £3,000 if they suspect money laundering—provided the transaction falls within operational or exit-related exemptions. Although DAML SARs will not be required below the threshold, firms must still submit standard “information-only” SARs for any suspected criminal activity.
In 2024, 23,000 DAMLs were submitted for transactions between £1,000 and £3,000, but only 182 led to asset denial, representing just 0.1% of all seizures. Officials emphasised that this adjustment allows resources to be reallocated toward higher-impact cases, aligning with the UK’s Economic Crime Plan 2 and its public-private partnership model.
Treasury Sets Vision for Modernising US Anti-Money Laundering Framework
At the 62nd meeting of the Bank Secrecy Act Advisory Group (‘BSAAG’) on 18th June 2025, US Deputy Treasury Secretary Michael Faulkender laid out the Trump Administration’s principles for modernising the Bank Secrecy Act (‘BSA’) and enhancing the US anti-money laundering and countering the financing of terrorism (‘AML/CFT’) regime. His remarks emphasised risk-based regulation, cost-efficiency, and fairness across financial institutions of all sizes.
Faulkender called for tailoring compliance obligations based on institutional risk profiles, with a particular focus on enabling smaller “Main Street” institutions to prioritise high-risk activities while de-prioritising lower-risk areas. As part of this, the BSAAG’s composition was revised to double the representation of community banks.
Treasury aims to streamline Suspicious Activity Reports (‘SAR’s) and Currency Transaction Reports (‘CTR’s) to reduce burdens while maximising their usefulness to law enforcement. Reforms will involve enhancing reporting forms, providing feedback to financial institutions, and encouraging the use of innovative technologies to improve threat detection.
Faulkender reaffirmed the importance of public-private partnerships and highlighted the creation of BSAAG subcommittees on innovation and information security. The vision aligns with the AML Act’s mandate to better align regulatory efforts with national security priorities and emerging risks.
Bribery and Anti-Corruption
EU Highlights Multidimensional Anti-Corruption Efforts at UNCAC Prevention Working Group
At the 16th session of the UNCAC Working Group on the Prevention of Corruption (17–20 June 2025), the European Union reaffirmed its deep commitment to preventing corruption across Member States and beyond. Delivering a comprehensive statement in Vienna, the EU outlined an array of legislative, institutional, and cooperative measures designed to uphold integrity in both the public and private sectors.
Central to the EU’s internal monitoring is the annual Rule of Law Report, which tracks developments across 27 Member States in key areas such as justice systems, anti-corruption frameworks, media freedom, and institutional checks and balances. Pillar 2 of the report includes concrete recommendations for national reforms. At the international level, the EU spotlighted its co-sponsorship of Resolution 10/5 on corruption linked to organised crime, reinforcing its Organised Crime Strategy (2021–2025) and the newly launched Internal Security Strategy, which strengthens anti-money laundering and confiscation measures.
Progress was also highlighted in transparency of beneficial ownership, a key focus of Resolution 10/6. EU anti-money laundering legislation mandates central registers and enhanced information sharing among authorities to prevent criminals from hiding behind opaque ownership structures. In parallel, the EU’s Whistleblower Protection Directive—aligned with Resolution 10/8—ensures safe reporting channels and shields whistleblowers from retaliation, with a dedicated UNCAC side event underscoring its importance.
Addressing public procurement integrity in line with Resolution 10/9, the EU pointed to its directives promoting competitive, transparent procurement processes and tracking Member State performance in its Rule of Law Report. In the private sector, measures aligned with Resolution 10/12 encourage large firms to adopt anti-corruption policies, whistleblowing systems, and compliance programmes. The EU is also finalising new anti-corruption legislation and preparing to unveil its first dedicated EU Anti-Corruption Strategy.
Collectively, these initiatives reflect a multidimensional approach which blends domestic reform, regional coordination, and global engagement. The EU concluded its statement by urging continued implementation of UNCAC resolutions and active civil society involvement.
Fraud
US Seizes $225 Million in Cryptocurrency Linked to Sophisticated Investment Fraud Schemes
On 18th June 2025, the US Department of Justice filed a civil forfeiture complaint targeting over $225 million in cryptocurrency linked to widespread crypto investment fraud—commonly known as “pig butchering” scams. The complaint alleges the funds were funnelled through a complex money-laundering network executing hundreds of thousands of blockchain transactions to obscure their illicit origins.
The seizure—led by the FBI and US Secret Service San Francisco offices—is the largest cryptocurrency seizure in Secret Service history. Over 400 victims were identified, with collective losses in the millions. Authorities credited blockchain analytics and interagency collaboration for tracing the funds, while crypto firm Tether was noted for its proactive support.
This action underscores the DoJ’s intensified efforts to disrupt transnational crypto fraud and restore stolen funds to victims. The public is urged to report relevant losses to the FBI’s Internet Crime Complaint Centre using reference code “BT06182025.” The DoJ press release is here.
Market Abuse
Ex-Janus Henderson Analyst and Sister Convicted in £1mn Remote Insider Trading Case
Redinel Korfuzi, 38, and his sister Oerta, 36, have been found guilty of insider trading and money laundering after using confidential information from Korfuzi’s role at Janus Henderson to profit nearly £1m through rapid stock trades during the pandemic. The trades were executed within 24 hours of receiving insider tips, using their London Marylebone flat as the scheme’s hub. While two associates were acquitted, the jury found the Korfuzis guilty after a four-month trial at Southwark Crown Court. Dubbed a “secret trading club,” the offences took place between 2019 and 2021. Sentencing is scheduled for 4th July. Janus Henderson, not implicated in the wrongdoing, cooperated fully with the FCA’s investigation, Operation Naples.
Other Financial Crime News
Call for Reform: Review Urges Overhaul of UK’s International Criminal Cooperation Laws
The Criminal Law Reform Now Network (‘CLRNN’), in partnership with the Law Commission, has published an independent scoping review on the UK’s frameworks for international cooperation and extradition. Authored by Gemma Davies of the University of Durham, and others, the review highlights pressing challenges and structural inefficiencies, concluding that comprehensive reform is overdue.
Key findings include:
Extradition: The Extradition Act 2003 is straining under complex, high-volume cases. Concerns include unreliable assurances, forum bar operations, delays, and a Supreme Court decision complicating dual criminality.
Mutual Legal Assistance (‘MLA’): The UK’s MLA system is outdated and fragmented, with unclear statutory underpinnings and practical issues concerning evidence handling and police cooperation.
Criminal Jurisdiction: Current laws on territorial and extraterritorial jurisdiction are inconsistent and often unclear, hindering effective prosecution of cross-border crimes.
The review is expected to shape future legal reforms and stimulate discussions within and beyond government.
OSCE Trains Albanian Police in Sectoral Financial Crime Analysis to Bolster Anti-Money Laundering Strategy
As part of its mission in Albania, the Organisation for Security and Co-operation in Europe (‘OSCE’) recently delivered a three-day training programme (17–19 June 2025) focused on sectoral analysis of financial crimes. The initiative supported Albania’s National Strategy for the Prevention of Money Laundering and Financing of Terrorism. Led by two national experts, the training equipped 12 officers from the Albanian State Police’s Anti-Money Laundering Sector with skills to draft sector-specific analyses. These capabilities are intended to enhance strategic planning, intelligence-led investigations, and interagency coordination in tackling money laundering, corruption, and related offences.
The OSCE is the world’s largest regional security body, comprising 57 states across Europe, Central Asia, and North America. It promotes peace, democracy, and stability through conflict prevention, human rights advocacy, and support for rule of law and good governance.
Cybercrime
China’s Cyber and Space Warfare Capabilities Pose Growing Strategic Threat, Warns USIP
China’s state-backed cyber operations are evolving from espionage to sabotage, with recent malware campaigns—like those attributed to the Volt Typhoon group—targeting critical US infrastructure such as water, power, and telecom systems. According to a new analysis by the United States Institute of Peace, these intrusions represent not just isolated incidents but a broader strategy designed to paralyse economic and military functions in the event of conflict.
This threat extends to space systems as well. Chinese cyber actors are increasingly capable of compromising satellite control networks and timing signals like those provided by GPS—disruptions which could ripple through everything from aviation to financial markets. The integration of artificial intelligence with pre-implanted malware dramatically accelerates the scale and speed of potential attacks, allowing simultaneous strikes on multiple sectors “at the speed of light.”
The report argues that strategic surprise in the information age can be more devastating—and longer-lasting—than in previous eras. In response, it calls for the United States to demonstrate credible deterrence. This includes signalling to China that such attacks will not go unanswered, reviving hard-power capabilities in space, and discarding illusions that space and cyber domains can remain insulated from geopolitical conflict.
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