Episode 171

14th July – 17th July 2025

Sanctions

US Treasury and Gulf Partners Sanction Key ISIS Facilitators Across Africa in Joint Counterterrorism Effort

On 14th July 2025, the Terrorist Financing Targeting Centre (‘TFTC’)—a US-Gulf Cooperation Council initiative—announced coordinated sanctions against three individuals facilitating ISIS operations in Africa. The designations target South African-based trainer Zayd Gangat, DRC-based financier Hamidah Nabagala, and Abdiweli Mohamed Yusuf, head of ISIS-Somalia. These operatives have supported ISIS through training, financial flows, and logistics, including extortion, kidnapping, and bombings.

Nabagala allegedly funded the 2021 Kampala bombing and attempted to send her children to ISIS camps in the DRC. Yusuf oversaw supply routes and foreign fighter transfers, generating millions through ISIS-Somalia’s illicit networks. The action underscores TFTC’s wider mission—sharing intelligence, disrupting terrorist access to global finance, and strengthening regional defences through targeted designations and capacity-building efforts.

Human Rights Groups Urge US to Revoke Sanctions Against Palestinian Legal Aid Organisation Addameer

Human Rights Watch and Amnesty International are calling on the US Treasury’s Office of Foreign Assets Control (‘OFAC’) immediately to lift sanctions imposed on Addameer, a leading Palestinian human rights group. The sanctions, enacted in June 2025, claim affiliation with the Popular Front for the Liberation of Palestine, a designated terrorist organisation—though no evidence has been presented to substantiate this link. Critics argue the US is using its sanctions regime to reinforce Israeli efforts to silence human rights advocacy, particularly concerning abuses against Palestinians.

Addameer, known for providing legal aid to Palestinian detainees held by Israel and the Palestinian Authority, has faced escalating pressure since Israeli authorities labelled it a terrorist group in 2021. The sanctions come amid growing concern over Israel’s use of administrative detention, torture, and denial of basic rights to Palestinian prisoners—conditions which Addameer has worked to expose.

Human rights organisations stress that these sanctions not only undermine Addameer’s ability to operate but also set a dangerous precedent for targeting civil society groups documenting abuse by US allies. The move has sparked fears of a broader chilling effect on advocacy efforts at a time when international scrutiny of Israel’s actions in the occupied Palestinian territories is most urgent. Advocates insist that human rights defenders should be protected—not penalised—for their work.

Money Laundering

Barclays Fined £42 Million for Major Failures in Financial Crime Controls Linked to WealthTek and Stunt & Co

The Financial Conduct Authority (‘FCA’) has issued a combined £42 million fine to Barclays Bank UK plc and Barclays Bank plc for serious lapses in managing financial crime risks. These penalties stem from two separate cases, both exposing Barclays’ shortcomings in vetting clients and monitoring suspicious transactions.

In the first case, Barclays Bank UK plc opened a client money account for WealthTek without conducting adequate due diligence. Had it consulted the Financial Services Register, it would have discovered WealthTek lacked FCA authorisation to hold client money. This oversight led to £34 million being deposited and subsequently mismanaged. A voluntary payment of £6.3 million will be made by Barclays to compensate WealthTek clients facing shortfalls, and a criminal trial against WealthTek’s principal partner is scheduled for 2027.

The second case involves Barclays Bank plc’s failure to identify and act on risks associated with banking services provided to Stunt & Co. Despite receiving £46.8 million from Fowler Oldfield—a known money laundering operation—Barclays neglected to gather essential information or respond to red flags, including police raids and alerts from law enforcement. The FCA fined the bank £39.3 million for facilitating fund flows linked to financial crime.

While Barclays received fine reductions due to early settlement and cooperation, the FCA emphasised the real-world consequences of poor financial controls. These cases underline a continuing concern in the banking sector and reinforce the FCA’s commitment to strengthening anti-money laundering frameworks. The Final Notices are here and here.

Thousands of UK Youths Exploited by Criminals in Money Laundering Schemes, Warns Children’s Society

A report by The Children’s Society reveals that thousands of young people across the UK are being exploited by criminal gangs to launder money. According to data from UK fraud prevention service Cifas, over 6,400 individuals under the age of 21 were flagged in 2024 for suspected involvement in financial crime. Many of these cases involve vulnerable children aged 15 to 17, some of whom have faced severe violence due to financial exploitation.

The exploitation often begins innocuously—with requests to share bank details or respond to misleading “quick cash” job adverts—and escalates into coercive threats, manipulation, and even financially motivated sexual extortion. Social media plays a critical role, as scam posts glamorising luxury lifestyles are used to lure potential victims. Both impoverished and affluent youth are targeted: the former due to economic desperation, and the latter for their access to credit and financial products which can conceal illegal activity.

Victims frequently suffer consequences such as frozen bank accounts, cutting off families from vital resources like food and energy. The focus on punitive measures over support prevents many from seeking help. The Children’s Society calls for comprehensive education on grooming and exploitation, specialised training for professionals in finance and education, and systemic reforms to address root causes like poverty and school exclusion. Fraud minister Lord Hanson condemned the exploitation as “absolutely disgraceful,” vowing government action to curb these practices.

JMLSG Finalises Revisions to UK AML Guidance; HM Treasury Approval Pending

The Joint Money Laundering Steering Group (‘JMLSG’) has published final amendments to Part I of its anti-money laundering guidance, covering updates to key paragraphs including 5.3.138A–B, 5.3.97A, 5.3.99, 5.6.36–5.6.38, and 2.16–2.24. These revisions have been submitted to HM Treasury for ministerial approval and are accessible under the “Revisions” tab on the JMLSG website. The changes reflect ongoing efforts to align industry practices with evolving regulatory expectations around client due diligence, risk assessment, and suspicious activity monitoring.

Singapore Authorities Penalise Law Firms Over Anti-Money Laundering Failures Linked to 2023 Property Case

Singapore’s Director of Legal Services, supported by the Ministry of Law, is investigating 24 law firms involved in property conveyancing tied to a 2023 anti-money laundering operation. Under the Legal Profession Act, firms and lawyers must assess client risk, conduct customer due diligence, and report suspicious transactions. So far, two firms received fines of SGD 30,000 and 100,000, a third faces a potential SGD 70,000 penalty, one was reprimanded, and a lawyer referred for disciplinary action. No further action is deemed necessary for seven firms, while inquiries into 13 others are ongoing. Ministry of Law reiterated the sector’s AML responsibilities in a June 2025 guidance note, urging vigilance as new laundering risks emerge across Singapore’s financial and legal ecosystems.

Bribery and Corruption

Democrats Launch “Anti-Crypto Corruption Week” to Challenge Republican Crypto Legislation and Trump’s Alleged Financial Exploitation

House Financial Services Committee Democrats, led by Congresswoman Maxine Waters and Congressman Stephen Lynch, have declared this week “Anti-Crypto Corruption Week.” The initiative responds to three Republican-backed bills—the CLARITY Act, the GENIUS Act, and legislation banning central bank digital currencies—which Democrats say would enable widespread crypto fraud and legitimise financial exploitation linked to former President Donald Trump.

Waters argues that these bills lack essential consumer protections and national security measures while empowering Trump's alleged crypto empire, which she claims has already generated $1.2 billion in personal gains. Lynch criticises the proposed legislation as a threat to US financial stability and national security, citing Trump’s alleged conflicts of interest and foreign investment in his crypto ventures.

Democrats have undertaken multiple actions to spotlight these concerns: blocking Republican hearings, staging walkouts, hosting Democratic-led hearings, and proposing the STOP Trump in Crypto Act. These efforts are part of a broader push to prevent political figures and their families from profiting off digital assets. Committee Democrats emphasise that they are committed to safeguarding the financial system from corruption and defending democratic accountability amidst evolving financial technologies.

Senator Warren Alleges Corruption in Trump’s Presidential Library Funding

A report from US Senator Elizabeth Warren’s office raises significant ethical concerns regarding donations pledged to former President Donald Trump’s future presidential library. While presidential libraries traditionally serve as archival and educational centres, Trump’s version appears to be attracting unprecedented sums — reportedly over $500 million — from corporations, foreign governments, and special interest groups, many of whom have ongoing business before federal agencies or pending decisions which could be influenced by Trump.

The report documents corporate settlements channelled directly into the library fund, including multimillion-dollar donations from Meta, Paramount, X (formerly Twitter), and ABC News. In addition, merchandise partnerships with companies like Instant Pot, Lenox Corporation, and Soho Apparel Group are funnelling proceeds to the library. The government of Qatar has allegedly gifted a $400 million luxury jet, with plans for it to be part of the library collection, and leftover funds from Trump’s inauguration may contribute up to $30 million more, sourced from major tech and finance firms.

Unlike campaign or inaugural donations, contributions to presidential libraries are largely unrestricted and can be solicited even while the president is in office. This loophole, according to Warren’s team, allows for potential influence-peddling — enabling donations from entities seeking favourable policy outcomes, pardons, or access to federal contracts. The magnitude and timing of Trump’s donations, especially while still serving as president, set a new precedent in the intersection between public office and private gain, prompting calls for tighter regulations around presidential library funding.

ICPC Chairman Urges Balanced Anti-Corruption Strategies which Safeguard Human Dignity

At a high-level seminar marking the 2025 African Union Anti-Corruption Day, Dr. Musa Adamu Aliyu, Chairman of Nigeria’s Independent Corrupt Practices and Other Related Offences Commission (‘ICPC’), stressed that anti-corruption efforts must uphold human dignity and respect fundamental rights. Speaking through the Commission’s Secretary, Clifford Oparaodu, he described the “dignity paradox” whereby corruption deprives citizens of essential services, yet poorly executed enforcement measures risk violating civil liberties.

Dr. Aliyu called on stakeholders—including the judiciary, law enforcement, civil society, media, and the private sector—to adopt ethical practices which prevent abuses. He urged fair trials, humane investigation procedures, and responsible journalism which avoids media trials and premature reputational damage. The Chairman also highlighted legislative responsibilities to protect whistleblowers and promote safe reporting mechanisms.

Supporting the event’s theme, Jane Onwumere of TUGAR emphasised that corruption is not merely a financial or legal matter, but an infringement of human rights. She advocated for integrating integrity and dignity into all anti-corruption efforts. Commemorative activities also took place across other Nigerian states, with awareness campaigns and public engagement events led by ICPC state offices.

Fraud

FEMA Warns Texas Residents to Stay Vigilant Against Fraud Following July Storms

In the aftermath of severe storms and flooding which struck Texas beginning 2nd July, FEMA has issued warnings about scams targeting disaster survivors. Criminals have reportedly used stolen personal data to fraudulently apply for FEMA aid. Residents receiving unexpected correspondence from FEMA are urged to report suspected fraud immediately via the FEMA Fraud Branch or by visiting a Disaster Recovery Centre for help. FEMA emphasised that its officials never request payment or banking details and always carry official photo ID. Authorities also urged the public to report scams to law enforcement or the Texas Attorney General’s Consumer Protection Hotline.

Other Financial Crime News

UK Marks One Year of Renewed Anti-Financial Crime Push with Cross-Sector Progress Report

A year into the Labour Government's tenure, leading figures from government, civil society, law enforcement, and the private sector gathered for a panel hosted by RUSI to assess the UK’s progress in combating illicit finance. The discussion explored achievements since July 2024, including advancements in implementing the government’s second economic crime plan and preparations for the UK’s upcoming Financial Action Task Force (‘FATF’) mutual evaluation in 2027.

Notable participants included Giles Thomson (OFSI and HM Treasury), Ben Trim (HSBC), Josie Stewart (Joffe Charitable Trust), and Rachael Herbert (National Economic Crime Centre), reflecting a multi-sector commitment to cleaning up the financial system. The panel emphasised the UK’s role as a global leader in countering dirty money and underlined growing collaboration between public and private institutions.

Looking ahead, the Foreign Secretary’s announcement of an international summit on countering illicit finance signals a strategic pivot to long-term leadership in global financial crime policy. The panellists called for sustained efforts, enhanced data sharing, and ethical coordination to tackle emerging threats—including AI-enabled sanctions evasion and opaque asset flows.

Cyber Crime

UK Moves to Recognise Digital Assets as New Category of Personal Property Under Proposed Law

The Property (Digital Assets etc) Bill [HL] seeks to modernise UK property law by formally recognising digital assets—such as cryptocurrencies and non-fungible tokens (‘NFT’s)—as a distinct third category of personal property. Traditionally, UK law has acknowledged only two types: “things in possession” (physical objects) and “things in action” (enforceable legal rights). The proposed legislation, due for second reading in the House of Commons on 16 July 2025, introduces the concept of digital assets existing as personal property even if they do not fit into these legacy classifications.

The bill is concise, with a single main clause, and it does not define specific types of digital assets. Instead, it provides a flexible legal framework, empowering courts and legal practitioners to apply the recognition to digital assets as cases arise. This approach responds to growing uncertainty over the legal status of cryptoassets, particularly in commercial and personal contexts where ownership and transfer rights are often contested.

The proposal follows recommendations from the Law Commission and builds on existing UK regulatory developments, such as Financial Conduct Authority (‘FCA’) rules on crypto promotions and anti-money laundering compliance. Broader efforts are underway, including consultations on rules for stablecoins and the possibility of introducing a central bank digital currency—the ‘digital pound.’

By formally recognising digital assets as property, the bill is expected to bring legal clarity for individuals, investors, and businesses, while promoting innovation and regulatory alignment in the digital economy.

Cybersecurity Crises Deepen as Human Vulnerabilities and AI Threats Escalate

The latest cybersecurity roundup from the World Economic Forum highlights the growing threat posed by sophisticated cybercriminals exploiting human behaviour and emerging technologies. A recent breach of Qantas Airlines, potentially linked to the Scattered Spider group, exposed six million customers' data and underscored the limitations of multi-factor authentication when hackers convincingly impersonate employees. This group has also targeted UK retailers like Marks & Spencer and Harrods, leading to months-long operational disruptions. Across the UK, cyberattacks surged, affecting 27% of businesses — an 11-point increase year-on-year.

Governments are responding by aligning with tech giants to bolster defences. OpenAI has signed a $200 million deal to enhance AI-driven cyber capabilities for the US Department of Defence. Simultaneously, Microsoft is offering free cybersecurity services to European governments, while Orange is launching a homeland security division.

Other stories include South Korea penalising SK Telecom after leaking 27 million user records, Singapore granting police broader powers to block fraudulent bank transfers, and malware campaigns by North Korean and Russian actors targeting crypto and government sectors. In the US, the House of Representatives banned WhatsApp from its devices, citing data transparency concerns.

The report also emphasises rising risks to industrial infrastructure from generative AI. Over 75% of energy and manufacturing firms faced attacks last year, with half admitting poor preparedness. This has driven demand for “red teaming” — rigorous pre-attack testing — and spiked cybersecurity job openings in the US, revealing the urgency of public-private cooperation to fill persistent skill gaps.