Episode 165

23rd June – 26th June 2025

Sanctions

US Treasury Sanctions Network Supplying Sensitive Machinery to Iran’s Defence Sector

On 20th June 2025, the US Treasury's Office of Foreign Assets Control (‘OFAC’) sanctioned one individual, eight entities, and identified one vessel—SHUN KAI XING—for facilitating Iran’s weapons programmes. These parties engaged in procuring and trans-shipping dual-use technologies for Iran's ballistic missiles, UAVs, and other military projects, primarily on behalf of entities affiliated with the Islamic Revolutionary Guard Corps (‘IRGC’).

Key actors include Hong Kong’s Unico Shipping Co. and China-based suppliers Futech and Dongguan Zanyin Machinery, who attempted to disguise the Iranian end-users through falsified shipping documents and intermediaries in Turkey and Singapore. These moves violated Executive Order 13382, targeting WMD proliferators. The State Department press release is here.

US Treasury Targets Largest Houthi Oil Smuggling Network to Date

On 20th June 2025, the US Treasury’s OFAC sanctioned four individuals, 12 entities, and two vessels tied to illicit oil trading and smuggling operations benefiting the Iran-backed Houthi group, Ansarallah. The action—OFAC’s most extensive yet against the group—exposes a sprawling network of front companies in Yemen which generated revenue for militant activities by trafficking in Iranian oil and dual-use goods.

Entities like Black Diamond Petroleum, Star Plus Yemen, and Royal Plus Shipping funnelled profits through Houthi-controlled ports, often involving actors linked to the Islamic Revolutionary Guard Corps and Russian intermediaries. Sanctioned vessels continued delivering refined petroleum products even after US authorisations had expired, violating prior licensing rules.

OFAC Authorises Transactions for Venezuela’s PDVSA 2020 Bond Beginning December 2025

On 20th June 2025, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) issued General Licence No. 5S, authorising all transactions related to the Petróleos de Venezuela, S.A. (‘PDVSA’) 2020 8.5% bond starting 20th December 2025. This licence lifts prior restrictions imposed under Executive Order 13835 (as amended), allowing financing and dealings with the bond which were previously prohibited.

However, the licence does not permit other activities still barred under the Venezuela Sanctions Regulations or other sections of 31 CFR chapter V. It also replaces General Licence No. 5R, which was issued in March 2025.

US Sanctions Top Tren de Aragua Leader Amid Expanded Anti-Crime Push

On 24th June 2025, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) sanctioned Giovanni Vicente Mosquera Serrano, a fugitive leader of Tren de Aragua—a Venezuelan-origin organisation designated as a Foreign Terrorist Organisation and Specially Designated Global Terrorist. Mosquera Serrano is linked to narcotics trafficking, extortion, and money laundering across Latin America, including overseeing murders in Colombia. The sanctions, issued under Executive Orders 13581 and 13224, freeze his US-linked assets and prohibit US persons from engaging with him financially. This action follows his addition to the FBI’s Ten Most Wanted list and an unsealed DOJ indictment. The State Department has offered a reward of up to $3 million for information leading to his arrest or conviction. US authorities emphasised their continued coordination to disrupt the gang’s transnational criminal operations.

EU Targets Syrian Elites Over Atrocities and Sectarian Violence

On 23rd June 2025, the EU imposed sanctions under its Global Human Rights Sanctions Regime on five Syrian individuals linked to the former Assad regime. These include three ex-military leaders—Miqdad Fatiha, Ghaith Dalla, and Suhayl al-Hasan—accused of torture, extrajudicial killings, and escalating sectarian violence in March 2025. Two businessmen, Mudalal and Imad Khoury, were also sanctioned for financing the regime’s crimes, including chemical weapon use. The measures include asset freezes and travel bans. This brings the total under the regime to 123 persons and 36 entities. The EU reaffirmed its commitment to monitor Syria and act against further human rights violations.

EU Urged to Get Creative as Russia Sanctions Face New Obstacles

As EU leaders gather for the June 2025 summit, sanctions on Russia are losing momentum. With US President Trump opposing tougher measures and some EU states blocking bold action, Brussels is being encouraged to chart its own course. Experts at the Carnegie Endowment for International Peace suggest three strategies: tightening enforcement on oil exports transiting EU waters, cutting off Russia’s access to the EU gas market (where it lacks alternatives), and reforming the EU’s sanctions decision-making by sidestepping vetoes through trade law and qualified majority voting. These steps aim to close loopholes and assert EU autonomy as geopolitical fragmentation deepens.

Money Laundering

FATF Updates Guidance to Align Financial Inclusion with AML/CFT Measures

In June 2025, the Financial Action Task Force (‘FATF’) released updated guidance emphasising that financial inclusion and anti-money laundering/counter-terrorism financing (‘AML/CFT’) efforts are mutually reinforcing. The revision follows strengthened expectations under Recommendation 1, urging countries to adopt risk-based, proportionate controls which expand access to formal financial services, particularly for underserved and low-risk populations. The guidance includes real-world case studies—such as Sweden's streamlined ID process for asylum seekers and Singapore’s limited-purpose accounts for higher-risk individuals—and highlights the benefits of increased transparency in reducing financial crime. It also introduces a revised assessment methodology reflecting this enhanced focus.

Fraud

Scammers Exploit Funeral Livestreams to Target Grieving Families

Fraudsters in the UK are exploiting online funeral livestreams by posting fake links on social media, tricking mourners into paying fees or donating through bogus pages. These scams often impersonate family members and target high-profile or youth-related deaths. The Chartered Trading Standards Institute (‘CTSI’) warns that many victims stay silent to avoid causing more distress, which enables the fraud to persist. The National Association of Funeral Directors stresses that livestreams should never cost money and urges the public to verify links with official funeral providers. Victims are advised to report incidents and contact their bank if they have shared card details.

Other Financial Crime News

£64 Million Confiscation Order Against Fugitive FX Boss Anthony Constantinou

Anthony Constantinou, the former head of City of London-based Capital World Markets (‘CWM’), has been ordered to repay £64 million or face an additional 14 years in prison. Convicted in absentia in 2023 of fraud, fraudulent trading, and money laundering, Constantinou ran a bogus investment scheme promising 5% monthly returns through foreign exchange trades.

In reality, CWM paid early investors with later funds and spent the remainder, funnelling millions into Constantinou's lavish lifestyle—including cars and sponsorships to boost credibility. The total criminal benefit was assessed at nearly £98 million.

The CPS and City of London Police emphasise the ruling as part of broader efforts to dismantle large-scale financial fraud and return money to victims. Over £478 million in criminal assets have been recovered over the past five years, with £95 million returned in compensation.

From Law to Impact: Transparency International’s Push for Effective Whistleblower Protection

Transparency International highlights the persistent gap between whistleblower protection laws and their practical implementation. While legal frameworks have improved—especially following the EU Whistleblower Protection Directive—many countries still offer weak enforcement, unclear reporting channels, and inadequate safeguards against retaliation.

The organisation stresses that true whistleblower protection requires more than laws—it demands political will, resources, and collaboration between governments, civil society, and the private sector. Transparency International supports organisations through best-practice guides, self-assessment frameworks, and monitoring tools that go beyond compliance checklists to ensure systems work in practice.

They also provide direct assistance to individuals via Advocacy and Legal Advice Centres in over 60 countries, helping whistleblowers navigate the risks of reporting misconduct.

Gen Z Least Likely to Blow the Whistle at Work, Says UK Charity Protect

According to a June 2025 survey by Protect, the UK’s whistleblowing charity, Gen Z (ages 18–24) are significantly less likely than older generations to report workplace wrongdoing through formal employer channels. While health and safety issues were the top concern overall, only 56% of Gen Z said they would raise such matters—compared to 86% of those aged 55+. Instead, younger workers showed a higher willingness to speak out on sexual and racial harassment and were more inclined to use social media or the press. Protect urges employers to improve whistleblowing support for younger staff, particularly during onboarding, to build confidence and clarity on how to report issues.

Europol Report Warns of Rising Youth Involvement and Online Extremism in 2024 Terrorism Trends

Europol’s 2025 Terrorism Situation and Trend Report (TE-SAT) highlights a volatile terrorism landscape across the EU in 2024, with 58 attacks reported and 449 terrorism-related arrests. Notably, nearly one-third of suspects were minors or young adults—some as young as 12—prompting serious concern over online radicalisation via extremist digital communities. These platforms promote ideological violence linked to jihadism, right-wing extremism, occultism, and satanism.

Geopolitical conflicts, such as those in Gaza, Ukraine, and Syria, further intensified extremist narratives, fuelling anti-Semitic propaganda and attracting foreign terrorist fighters. The collapse of the Assad regime in Syria and the rise of Hay’at Tahrir al-Sham leadership is seen as a future risk multiplier.

The report also warns of emerging technologies being exploited: generative AI is increasingly used to produce hate content, while encrypted platforms facilitate terrorist coordination and recruitment.

Council of Europe Launches Anti-SLAPP Training in Serbia to Safeguard Freedom of Expression

In June 2025, the Council of Europe held Serbia’s first training session on countering Strategic Lawsuits Against Public Participation (‘SLAPP’s)—legal actions aimed at silencing journalists, activists, and civil society. Judges from Serbia’s top courts joined civil society groups to explore how to identify and prevent SLAPP misuse, guided by the Council’s 2024 Recommendation (CM/Rec(2024)2) and European Court of Human Rights case law.

Organised under the EU-Council of Europe joint programme “Horizontal Facility,” the training featured interactive sessions on early SLAPP detection, national judicial implications, and future curriculum design. The event also highlighted good practices from a regional baseline assessment, aiming to strengthen public participation safeguards and reinforce Article 10 protections of the European Convention on Human Rights.

Armenian Officials Trained by OSCE to Combat Criminal Use of Virtual Assets

From 18-20 June 2025, the Organisation for Security and Cooperation in Europe (‘OSCE’) and Armenia’s Financial Monitoring Centre hosted a workshop in Yerevan to train financial intelligence and law enforcement personnel on tackling the illicit use of virtual assets. The expert-level course covered advanced topics such as tracing cryptocurrency transactions, darknet platform simulations, behavioural clustering, and the use of blockchain analytics tools. Real-world scenarios—including sanctions evasion and state-linked ghost wallets—were simulated to strengthen practical skills. Supported by several OSCE participating states, the training forms part of a broader effort to counter money laundering risks and promote international cooperation in the virtual asset space.

Companies House Marks 10 Years of Open Data, Bolstering UK Transparency and Economic Growth

Companies House is celebrating a decade since launching its free “Find and update company information” service, which has grown from 1.3 billion data accesses in 2015–16 to over 16.5 billion by 2023–24. This open data initiative has fuelled innovation, improved accountability, and strengthened the fight against financial crime. Valued at up to £3 billion annually, the data supports business verification, AML compliance, and journalistic investigations. As new reforms under the Economic Crime and Corporate Transparency Act take effect—including director ID verification—the register’s integrity and usefulness are expected to grow even further.

BVI’s Company Register Plan Risks Shielding Corruption, Warns Transparency International

Transparency International UK has strongly criticised the British Virgin Islands' (‘BVI’) new access policy for its company register, stating it undermines global transparency standards. While the policy simplifies how “legitimate interest” is defined, it allows company owners to be notified—and potentially object—when journalists or civil society request information. Anti-corruption advocates argue this could endanger investigators and obstruct scrutiny. The BVI, already grey listed by the FATF, is facing growing pressure to align with international norms on beneficial ownership transparency. UK MPs and civil society groups urge tougher action if the BVI fails to meaningfully reform.