Episode 182

5th September – 7th September 2025

Sanctions

Fracht FWO Inc. Settles $1.6M OFAC Penalty for Sanctions Violations Involving Venezuela and Iran

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) announced a $1,610,775 settlement with Fracht FWO Inc., a Houston-based freight forwarder, for apparent violations of US sanctions programs targeting Venezuela and Iran. Fracht contracted with a blocked Venezuelan government airline to transport goods using an aircraft operated by Iran’s Mahan Air, which is sanctioned under terrorism and proliferation authorities. OFAC deemed the conduct egregious and noted it was not voluntarily self-disclosed.

US Sanctions Chinese Chemical Firm and Executives for Trafficking Deadly Synthetic Opioids

On September 3, 2025, the US Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Guangzhou Tengyue Chemical Co., Ltd., along with its executives Huang Xiaojun and Huang Zhanpeng, for manufacturing and trafficking synthetic opioids and dangerous cutting agents to the US. Despite prior indictments, the company continued selling potent substances like nitazenes, xylazine (“tranq”), and medetomidine—chemicals linked to rising overdose deaths and resistant to reversal treatments like Narcan. The sanctions coincide with a federal indictment involving 25 individuals and entities across China and the US, marking a coordinated crackdown on transnational drug networks fuelling America’s opioid crisis.

OFAC Sanctions NGOs Linked to ICC’s Alleged Targeting of Israel; Issues Wind-Down License

On 4th September 2025, the US Treasury’s Office of Foreign Assets Control (‘OFAC’) sanctioned three Palestinian human rights organisations—Al Haq, Al Mezan, and the Palestinian Centre for Human Rights—for their alleged involvement in the International Criminal Court’s (ICC) “illegitimate targeting” of Israel. These designations follow Executive Order 14203, which frames ICC actions against US and Israeli personnel as a national security threat. OFAC also issued General License 10, authorising the wind-down of transactions involving newly designated entities. In parallel, OFAC reclassified Ecuadorian criminal groups Los Choneros and Los Lobos as transnational terrorist organisations under expanded counter-narcotics and counter-terrorism sanctions.

Australia Imposes Sanctions on Russian Officials Over Civil Society Repression and Navalny’s Death

On September 3, 2025, Australia announced targeted financial sanctions and travel bans against 14 Russian individuals linked to the repression of civil society and the unlawful invasion of Ukraine. The move builds on previous sanctions following the poisoning and death of opposition leader Alexei Navalny, for which Australia holds the Russian government responsible. Foreign Minister Penny Wong emphasised the deteriorating human rights situation in Russia and expressed solidarity with Yulia Navalnaya, who continues her late husband’s pro-democracy advocacy despite personal risk.

HM Treasury Revokes Licence Allowing Evraz North America to Operate Under UK Sanctions Framework

The UK Treasury has revoked General Licence INT/2022/1710676, which previously permitted Evraz Plc’s North American subsidiaries to continue business operations despite sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019. Effective from 5 May 2022 and revoked on 3 September 2025, the licence had allowed payments and audit-related transactions involving Evraz North America and its subsidiaries, with UK financial institutions authorised to process these under strict conditions. The revocation signals a tightening of enforcement, and HM Treasury retains the authority to vary or suspend such licences at any time.

UK Sanctions Russian Actors Behind Forced Deportation and Indoctrination of Ukrainian Children

On 3 September 2025, the UK government-imposed sanctions on eight individuals and three organisations complicit in Russia’s systematic deportation, indoctrination, and militarisation of over 19,500 Ukrainian children. The measures target Kremlin-linked figures and youth organisations involved in re-education camps which erase Ukrainian identity and promote pro-Russian allegiance. Among those sanctioned are leaders of the Akhmat Kadyrov Foundation and state-run youth indoctrination centres. The move underscores the UK’s condemnation of Russia’s Russification policy in occupied territories and its commitment to holding perpetrators accountable. The press release is here, and the Notice is here.

UK Government Launches 2025 Sanctions Survey to Shape Future Policy and Business Support

The UK Government, in collaboration with Deloitte, has launched the 2025 UK sanctions perceptions survey to gather insights from businesses and professionals across sectors. Aimed at identifying knowledge gaps, improving government support, and removing barriers to legitimate trade, the survey invites responses from legal, compliance, risk, and finance teams. Participants are encouraged to complete and share the survey by 6th October, with collaborative features allowing teams to save and jointly contribute. Feedback will inform future sanctions policy and reflect on progress made over the past 18 months. The link to the survey is here.

Money Laundering

FATF Warns Countries to Crack Down on Shell Companies Amid Transparency Rollbacks

The Financial Action Task Force (‘FATF’) is intensifying scrutiny of shell companies, calling them the “getaway car” for global financial crime. FATF President Elisa de Anda Madrazo emphasised that upcoming national assessments will focus on the effectiveness of beneficial ownership systems, urging countries to maintain accurate, accessible registries. The warning follows recent rollbacks in transparency rules by the US and Switzerland, raising concerns about enforcement gaps. FATF’s grey and black lists continue to pressure jurisdictions with weak anti-money laundering measures, as the watchdog pushes for stronger global standards.

OSCE Boosts Turkmenistan’s Capacity to Combat Money Laundering and Terrorism Financing

From 1st to 4th September 2025, the Organisation for Security and Co-operation in Europe (‘OSCE’) Centre in Ashgabat hosted a strategic analysis training course aimed at strengthening Turkmenistan’s national efforts against money laundering and terrorism financing. Delivered in partnership with ECOFEL and the Egmont Group, the course targeted staff from the Financial Monitoring Service at the Ministry of Finance and Economy. It focused on enhancing analytical skills, critical thinking, and understanding of the intelligence cycle—key components for implementing recommendations from the Eurasian Group’s mutual evaluations. The initiative is part of broader OSCE support for legislative reform, transparency, and good governance in Turkmenistan’s AML/CFT framework. The OSCE is the largest regional security group, uniting 57 member states from North America, Europe, and Asia. Its goal is to advance peace, stability, and democracy.

Bribery and Corruption

GRECO Urges Slovakia to Accelerate Anti-Corruption Reforms in Government and Police

In its latest follow-up report, the Council of Europe’s anti-corruption body GRECO calls on Slovakia to intensify efforts to implement key reforms targeting corruption among high-level government officials and the police. Of 21 recommendations issued in 2019, only five have been fully implemented. While Slovakia’s 2023–2027 Government Manifesto outlines promising steps—such as a draft code of conduct and partial transparency measures—GRECO highlights major gaps, including lobbying rules, asset declarations, and whistleblower protections. The police force has made progress in ethics training and gender inclusion, but lacks an independent complaints mechanism and robust post-employment restrictions. Slovakia must report back by June 2026.

Other Financial Crime

IMF Warns: Tech-Savvy Criminals Outpace Regulators in Global Financial Crime Surge

As digital tools supercharge financial crime, the IMF highlights how criminals are exploiting AI, crypto, and decentralised platforms to launder money, deceive victims, and evade detection—often faster than regulators can respond. From deepfake scams and encrypted messaging to synthetic identities and cross-border laundering, enforcement agencies face mounting challenges amid fragmented oversight and outdated systems. The article urges governments to modernise AML/CFT frameworks, invest in AI-powered monitoring, and collaborate with fintechs to build secure, interoperable payment corridors which preserve inclusion while safeguarding financial integrity.

Stablecoins at a Crossroads: IMF Proposes Privacy-Preserving Compliance Framework

As stablecoins reshape global payments, an IMF article outlines a “compliance-by-design” model which embeds anti-money laundering and counter-terrorism safeguards directly into blockchain architecture—without compromising user privacy. Using zero-knowledge proofs and smart contracts, the system enables real-time identity verification and suspicious activity detection while shielding personal data unless legally required. This approach could transform enforcement from reactive to proactive, balancing financial integrity with confidentiality. Yet challenges remain, including computational burdens, cross-border governance, and the need for trusted credential issuers to anchor the system.

Cybercrime

Cyberattack Halts Jaguar Land Rover Production, Staff Sent Home Amid IT Disruption

Jaguar Land Rover (‘JLR’) has suspended production at key UK sites and instructed factory staff to stay home following a major cyberattack which forced the company to shut down critical IT systems. The disruption has impacted car sales, parts supply, and repair services, with garages unable to access essential databases. The hack—allegedly carried out by a group calling itself “Scattered Lapsus$ Hunters”—occurred during a peak sales period and has triggered a complex recovery process. JLR, owned by Tata Motors, is working to restore systems while investigating the breach, though no customer data theft has been confirmed.