8th August– 10th August 2025
Sanctions
Treasury Targets Narco-Terrorist Network and Updates Licensing Report
The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has sanctioned four individuals linked to the Cartel del Noreste, a narco-terrorist organisation operating in Mexico. These designations fall under counter-narcotics and counter-terrorism measures. Among those targeted are CDN’s second-in-command, a former police officer turned fugitive, and a tactical leader involved in attacks on Mexican military forces. OFAC also designated a narco-rapper whose concerts and streaming royalties are used to launder cartel funds. These actions, taken under Executive Orders 14059 and 13224, aim to disrupt CDN’s leadership and financial networks. Concurrently, OFAC released its quarterly report detailing licensing activities under the Trade Sanctions Reform and Export Enhancement Act (‘TSRA’), covering authorised exports of agricultural and medical goods to Iran from April to June 2025. The update also includes administrative changes to the Specially Designated Nationals (‘SDN’) list, reflecting revised identifiers for sanctioned entities and individuals across multiple jurisdictions.
OFSI Extends Licence Expiration
The Office of Financial Sanctions Implementation (‘OFSI’) has extended the operational period of a licence (INT/2022/2085212) which permits payments to designated Sanctioned Banks and their subsidiaries for the purpose of supplying energy to Mongolia. The licence also clarifies that Relevant Institutions can facilitate these transactions. Furthermore, it mandates record-keeping requirements for all activities conducted under its permissions and specifies that it took effect on 15th August 2022, now with an expiration date of 14th August 2027, subject to potential variations, revocations, or suspensions by HM Treasury.
Money Laundering
Paxos Fined $48.5M Over AML Failures Linked to Binance
Paxos Trust Company will pay a $26.5 million penalty and invest an additional $22 million to strengthen its compliance programme following a settlement with the New York State Department of Financial Services (‘DFS’). The DFS investigation found Paxos failed to conduct adequate due diligence on its former partner Binance and operated a deficient anti-money laundering system. Between 2017 and 2022, $1.6 billion in illicit transactions flowed through Binance, including dealings with sanctioned entities. Paxos also lacked effective controls to detect suspicious behaviour, failed to escalate red flags, and allowed coordinated illicit activity to go undetected. DFS previously ordered Paxos to cease minting Binance USD, prompting global regulatory action. The settlement underscores DFS’s commitment to enforcing accountability in the virtual currency sector.
Bribery and Corruption
Poland’s Anti-Corruption Efforts Under Scrutiny
Poland has made limited progress in implementing anti-corruption reforms recommended by the Council of Europe’s GRECO body. Of 21 recommendations issued in 2019, only three have been fully implemented, eight partially, and ten remain untouched. Improvements include new conduct guidelines and gift policies for top executive officials, enhanced access-to-information oversight, and draft legislation on asset disclosure. However, key areas like post-employment restrictions, training, and confidential counselling remain unaddressed. In law enforcement, the Border Guard has introduced ethics rules and a gift policy, but transparency in recruitment and whistleblower protections are still lacking. GRECO has requested a follow-up report by March 2026.
Whistleblower vs Whitehall – The Bribes Britain Buried
This week, The Guardian has taken an in-depth look at the case of Ian Foxley, a former British Army officer, who risked everything to reveal decades of government-sanctioned bribery in UK arms deals with Saudi Arabia. From secret payments disguised as “bought in services” to a dramatic escape from Riyadh, this long-read reveals how corruption was not just tolerated—but orchestrated—by the Ministry of Defence. If you care about accountability, ethics in government, or the hidden costs of foreign policy, this is must-read.
Fraud
FCA Recovers Over £300,000 from Investment Fraudsters
The Financial Conduct Authority (‘FCA’) in the UK has secured confiscation orders totalling £305,284 against Raheel Mirza, Cameron Vickers, and Opeyemi Solaja, following their convictions for a fraudulent investment scheme. The trio cold-called victims between 2016 and 2020, promoting a shell company and falsely claiming to trade in binary options. In reality, they used the funds to support their personal lifestyles. They were sentenced in 2023 to a combined 24.5 years in prison. A further order against Reuben Akpojaro is pending. The FCA aims to return the recovered funds to victims as soon as possible.
Guilty Plea in $4 Million Ponzi Scheme Case, SFO NZ Confirms
Thomas Alexander Kokouri Tuira, also known as Alex Tuira, has pleaded guilty to two representative charges of obtaining by deception in connection with a Ponzi scheme involving nearly $4 million. The plea was entered ahead of his scheduled trial, marking a significant development in the New Zealand Serious Fraud Office’s investigation. His wife, Aroha Awhinanui Tuira, has pleaded not guilty and is set to face trial in the Christchurch High Court starting Monday.
A Ponzi scheme is a type of financial fraud where returns to earlier investors are paid using the capital from newer investors, rather than from legitimate profit earned by the operation. The scheme relies on a constant influx of new money to continue and typically collapses when it becomes impossible to recruit enough new investors to pay returns. Named after Charles Ponzi, who orchestrated such a fraud in the early 20th century, these schemes often promise high returns with minimal risk, luring victims into a cycle of deception and financial loss.
FinCEN Hosts Public-Private Summit to Tackle Fraud in Digital Assets Ecosystem
Last month, the US Treasury’s Financial Crimes Enforcement Network (‘FinCEN’) convened a major FinCEN Exchange event focused on promoting innovation while addressing fraud and scam risks in the digital assets space. The gathering brought together law enforcement, financial institutions, regulatory tech firms, and trade groups to discuss trends, compliance strategies, and consumer protection. The event underscored the importance of balancing technological progress with robust safeguards, aligning with Executive Order 14178 to strengthen US leadership in digital finance. FinCEN reaffirmed its commitment to collaboration and vigilance in combating financial crimes linked to digital assets.