Episode 180

15th August– 17th August 2025

Sanctions

Haitian Gang Leader ‘Barbecue’ Indicted for Violating US Sanctions

Jimmy Cherizier, known as “Barbecue,” a fugitive gang leader from Haiti, has been indicted by a US District Court for conspiring with US citizen Bazile Richardson to violate US sanctions by funnelling funds from the United States to support violent gang activities in Haiti. Richardson was arrested in Texas, while Cherizier remains at large. The US government, citing Cherizier’s role in human rights abuses including the 2018 La Saline massacre, has offered a $5m reward for information leading to his arrest. The indictment highlights a broad conspiracy involving financial transfers and firearm procurement, with multiple federal agencies contributing to the investigation.

US Treasury Sanctions Mexican Cartel for Timeshare Fraud Targeting Elderly Americans

The US Department of the Treasury has sanctioned four individuals and 13 companies in Mexico linked to timeshare fraud orchestrated by the Cartel de Jalisco Nueva Generacion (‘CJNG’), a designated Foreign Terrorist Organisation. Operating from Puerto Vallarta, CJNG has expanded its revenue streams beyond drug trafficking to include scams targeting US timeshare owners—particularly older Americans—through deceptive call centres and fraudulent resale schemes. Victims have lost hundreds of millions of dollars, often through repeated re-victimisation. The sanctions aim to disrupt CJNG’s financial networks and protect vulnerable consumers, with coordinated efforts from the FBI, DEA, and Mexican authorities. The State Department press release is here.

US Treasury Sanctions Mexican Cartels for Violence, Drug Trafficking, and Agricultural Extortion

On 14th August 2025, the US Treasury’s Office of Foreign Assets Control sanctioned two violent Mexican cartels—Carteles Unidos and Los Viagras—along with seven affiliated individuals for their roles in drug trafficking, terrorism, and widespread extortion in Michoacan’s agricultural sector. The action, coordinated with multiple US and Mexican agencies, targets cartel leaders responsible for synthetic opioid production, recruitment of foreign mercenaries, and attacks on civilians and law enforcement. Los Viagras, linked to extortion of avocado and citrus growers, has also allied with CJNG, a major fentanyl supplier. These sanctions aim to disrupt cartel revenue streams and reinforce US efforts to combat transnational organised crime.

US Treasury Sanctions Garantex and Grinex for Enabling Cybercrime and Sanctions Evasion

On 14th August 2025, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) re-designated the cryptocurrency exchange Garantex and sanctioned its successor, Grinex, for facilitating over $100 million in illicit transactions linked to ransomware and cybercrime. The action targets three Garantex executives and six affiliated entities across Russia and Kyrgyzstan. Following law enforcement disruptions in March 2025—including domain seizures and arrests—Garantex shifted operations to Grinex to evade sanctions. The Treasury also sanctioned associated firms and individuals, including those behind the ruble-backed A7A5 token used to compensate affected users. These measures aim to uphold the integrity of the digital asset industry and disrupt networks exploiting crypto for criminal and geopolitical threats.

US Treasury Greenlights Alaska Summit Amid Trump–Putin Ceasefire Talks

On 13th August 2025, the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) issued General License No. 125, authorising specific transactions which would otherwise be prohibited under Russian-related sanctions. This license clears the way for logistical and diplomatic arrangements necessary for a high-level meeting between the US and Russian governments in Alaska. The summit took place on 15th August at Joint Base Elmendorf–Richardson. The licence remains valid until 20th August 2025, but does not permit the release of frozen assets or any unrelated transactions.

OFSI Makes Administrative Amendment to Designation

In the UK, the Office of Financial Sanctions Implementation (‘OFSI’) has made an amendment to the Global Irregular Migration Regime. Marko Petrović is designated under the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 for his association with the Kavač Gang, which facilitates unlawful entry into Balkan and Turkish countries by issuing passports based on false identities.

OFSI Webinar to Explore Proposed Reforms to Financial Sanctions Enforcement

On 17th September, the Office of Financial Sanctions Implementation (‘OFSI’) will host an online webinar from 14:00 to 15:00 to discuss its consultation on enhancing civil enforcement processes for financial sanctions. The session will provide background on the proposals and delve into the suggested changes. Attendees can submit questions in advance by emailing ofsienforcementconsultation@hmtreasury.gov.uk before 19:00 on 2nd September. A detailed agenda will be released soon. The Eventbrite sign-up is here.

Money Laundering

Leveraging Blockchain Transparency for Enhanced Crypto Anti-Money Laundering Compliance

The most recent BIS Bulletin No 111 proposes an innovative approach to anti-money laundering (‘AML’) compliance for cryptoassets, particularly addressing the limitations of traditional intermediary-based methods when dealing with decentralised public blockchains. Instead of relying on regulated intermediaries, this new approach leverages the inherent transparency of public blockchain transaction histories. It suggests implementing an "AML compliance score" for individual cryptoasset units (like Bitcoin's UTXOs) or wallet balances (for stablecoins), which indicates the likelihood of their association with illicit activities.

This scoring mechanism would be particularly crucial at "off-ramps" – points where cryptoassets are converted into fiat currency and interact with the traditional banking system. A higher score (e.g., 100) would signify "clean" funds from "allow-listed" wallets, while a lower score (e.g., zero) would indicate "tainted" funds linked to "deny-listed" addresses. Crypto exchanges, stablecoin issuers, and banks could use these scores to set minimum requirements for cashing out crypto, thereby preventing illicit funds from entering the conventional financial system. The stringency of this AML check can vary, from requiring all transactions to pass through Know-Your-Customer (‘KYC’) compliant addresses to merely checking for direct or indirect links to known illicit addresses. This system can also incorporate other regulatory criteria such as foreign exchange regulations, taxation, and consumer protection. The goal is to instil a "duty of care" among crypto market participants and users, encouraging them to avoid transacting with potentially compromised tokens. International cooperation is highlighted as essential for the effectiveness of such cross-border regulations. It's worth noting that stablecoins have become the preferred asset for criminals since 2022, accounting for approximately 63% of all illicit crypto transactions in 2024.

Bribery and Corruption

Global Arms Trade Corruption Exposed: Systemic Patterns and Calls for Accountability

A new report from the World Peace Foundation and Corruption Tracker reveals that corruption in the global arms trade is not incidental but deeply embedded in its structure. Analysing 59 cases across 63 countries and 81 companies over 45 years, the report identifies recurring patterns which enable wasteful spending, corporate impunity, and strategic irrelevance. It critiques conventional definitions of corruption and advocates for abolitionist approaches to accountability, arguing that meaningful reform requires rethinking the military-industrial system itself.

Other Financial Crime News

City of London Police Secure INTERPOL Silver Notice against Fugitive Fraudster

The City of London Police has obtained an INTERPOL Silver Notice to help trace and recover assets linked to convicted fraudster Anthony Constantinou, former head of Capital World Markets. Constantinou was sentenced in absentia to 14 years in prison in 2023 for fraud, money laundering, and fraudulent trading. He remains at large, and a £64 million confiscation order has been issued against him. The Silver Notice enhances international cooperation to locate and seize his overseas assets, aiming to compensate victims of his scheme. This effort complements an existing INTERPOL Red Notice for his arrest. The INTERPOL Silver Notice is an international tool designed to aid law enforcement agencies trace and recover criminal assets across borders.