Episode 183

8th September – 11th September 2025

Sanctions

US Sanctions on Palestinian NGOs Spark Global Outcry from Human Rights Groups

The International Federation for Human Rights (‘FIDH’) and Amnesty International have condemned recent US sanctions targeting three leading Palestinian human rights organisations—Al-Haq, Al Mezan, and the Palestinian Centre for Human Rights—as a direct assault on justice and civil society. The sanctions, issued by the US Treasury’s OFAC, freeze assets and criminalise transactions, effectively isolating the groups and obstructing their work documenting alleged war crimes and genocide in Gaza. Both organisations argue the move shields perpetrators and undermines international accountability efforts, including those linked to the ICC. They call on states, especially EU members, to activate legal protections and publicly oppose what they describe as politically motivated repression. The FIDH press release is here, and the Amnesty press release is here.

US Treasury Sanctions Southeast Asian Cyber Scam Networks Exploiting Americans

The US Department of the Treasury has imposed sanctions on a vast network of scam operations across Southeast Asia which defrauded Americans of over $10 billion last year. These criminal enterprises, based in regions like Shwe Kokko, Burma and Cambodia, use forced labor and violence to run cyber scams—particularly virtual currency investment frauds. The crackdown targets 19 entities, including those shielded by the OFAC-designated Karen National Army, marking a significant step in disrupting transnational cybercrime and protecting vulnerable victims. The State Department press release is here.

Vanquis Bank Censured for Delay in Enforcing Counter-Terrorism Sanctions

The Office of Financial Sanctions Implementation (‘OFSI’) has issued a Disclosure Notice to Vanquis Bank Limited for breaching the Counter-Terrorism Regulations 2019. The breach involved an eight-day delay in restricting access to a designated individual's account, during which the person retained full access and conducted transactions. OFSI emphasised that all financial institutions, regardless of size, must maintain robust systems for swift sanctions enforcement, ensure operational resilience in screening processes, and act promptly upon receiving designation alerts.

Money Laundering

“Global Crime, Global Response”: FATF, INTERPOL, UNODC & Egmont Group Unite to Accelerate Cross-Border Action Against Money Laundering

On 5th September 2025, four major international bodies, the FATF, INTERPOL, UNODC, and the Egmont Group, jointly launched a new Handbook on International Cooperation Against Money Laundering, aimed at strengthening cross-border collaboration among financial intelligence units, law enforcement, and prosecutors. The handbook responds to persistent global weaknesses in investigating and prosecuting money laundering, which often exploits jurisdictional gaps.

Key features include:

-    Promotion of informal cooperation tools like secure communication channels, rapid response mechanisms, and joint analysis to complement slower formal legal processes.

-        Three tailored guides for financial intelligence units, law enforcement agencies, and prosecutors to operationalise cross-border collaboration.

-        Real-world case studies demonstrating impact, including:

o   €95M laundering scheme dismantled via joint FIU efforts in Italy, Spain, and the Netherlands.

o   Operation AVARUS-X in Australia, with US support, targeting billions in illicit transfers.

o   A US-India crypto seizure worth $150M linked to drug trafficking.

o   INTERPOL-backed rhino horn trafficking convictions in Singapore using South African evidence.

The initiative sets the stage for deeper commitments at the upcoming 2026 UN Crime Congress in the UAE, where member states will exchange best practices and renew efforts to target criminal proceeds.

Jersey Investigates Abramovich Over Suspected Money Laundering and Sanctions Breaches

Authorities in Jersey are investigating Russian billionaire Roman Abramovich for suspected money laundering and sanctions violations linked to his 1990s control of the oil company Sibneft. Swiss court judgments reveal that hundreds of millions of dollars flowed through Swiss accounts tied to companies under Abramovich’s control, with prosecutors suspecting “corruption payments” and post-sanctions financial activity. Jersey’s probe has drawn cooperation from Swiss and Cypriot officials, who provided extensive banking and corporate records. Abramovich denies wrongdoing and has not been charged, while legal representatives argue prior judgments do not prove unlawful conduct.

FinCEN Issues Guidance to Boost Cross-Border Information Sharing in Fight Against Financial Crime

On 5th September 2025, the US Treasury’s Financial Crimes Enforcement Network (‘FinCEN’) released new guidance encouraging voluntary cross-border information sharing among financial institutions to combat money laundering, terrorist financing, and other illicit financial activity. While reaffirming strict confidentiality around Suspicious Activity Reports (‘SARs’), the guidance clarifies that the Bank Secrecy Act does not prohibit broader data exchange with foreign affiliates and correspondent banks. Developed in consultation with federal banking regulators, the guidance supports the President’s Working Group on Digital Asset Markets and aims to strengthen global financial system resilience by enabling institutions to build a more complete picture of emerging threats.

Wolfsberg Group Issues Guidance for Banks Serving Stablecoin Issuers

The Wolfsberg Group has released new guidance to help banks manage financial crime risks when providing services to fiat-backed stablecoin issuers. As global regulation around digital assets evolves, the document outlines a framework for offering operating accounts, reserve management, and client settlement while maintaining robust oversight. It emphasises that traditional financial crime risk principles still apply, but also addresses the unique challenges posed by stablecoin issuers operating in regulated jurisdictions. The guidance reflects a consensus among the Group’s twelve member banks and aims to clarify expectations for compliance and monitoring in this rapidly developing sector.

Fraud

John Burford Jailed for Two Years Over £1 Million Investment Fraud

John Burford has been sentenced to two years in prison following a successful prosecution by the Financial Conduct Authority (‘FCA’) for a £1 million investment fraud. As the sole director of Financial Trading Strategies Limited, Burford defrauded over 100 investors between 2016 and 2021 by offering unauthorised investments and misrepresenting the performance of his funds. He used the invested money for personal expenses, including property and lifestyle costs, while lulling investors into a false sense of security with self-published materials. The FCA is now pursuing confiscation proceedings to compensate the victims of what it described as a "sustained fraud."

Money Mule Surge and Stablecoin Abuse Signal Escalating Fraud Threat in US Financial System

A new report from BioCatch reveals a staggering 168% surge in US money mule cases during the first half of 2025, underscoring a sharp escalation in financial crime linked to organised networks. The study, based on data from over 200 financial institutions, also highlights a threefold increase in bot-driven account opening fraud. Scammers are increasingly exploiting blockchain-based stablecoins—particularly Tether (USDT)—to launder proceeds from romance and investment scams, which cost Americans over $6.5 billion in 2024 alone. Experts warn that stablecoins and authorised push payments now serve as the primary conduits for real-time fraud and laundering, enabling criminals to move illicit funds with minimal friction. The findings point to a growing need for enhanced regulatory oversight and technological defences in the face of evolving digital threats.

Market Abuse

FCA Flags Market Abuse Risks in Corporate Finance Firms

The Financial Conduct Authority (‘FCA’) has published Market Watch 83, highlighting key findings from its reviews of corporate finance firms advising small and mid-cap companies. These firms often handle sensitive inside information, and the FCA found that inadequate controls pose a heightened risk of market abuse.

The newsletter emphasises poor practices in managing Market Sounding Recipients (MSRs), including excessive outreach without proper governance and risks of unlawful disclosure—even when gatekeeper protocols are in place. It also notes inconsistencies in how deal-specific information is shared, urging firms to adopt approved scripts to ensure uniformity.

A concerning trend involves brokers delegating market soundings to third parties without issuer consent, potentially breaching UK MAR regulations. Smaller firms were found to be especially vulnerable due to informal compliance cultures, lack of independent oversight, and weak personal account dealing (PAD) controls.

The FCA calls for stronger systems, clearer policies, and a compliance culture led from the top to safeguard market integrity and prevent abuse.

Other Financial Crime

Congress Grills FinCEN on Surveillance Overreach and Cartel Crackdown Amid Push for Regulatory Reform

In a recent hearing before the House Financial Services Subcommittee on National Security, FinCEN Director Andrea Gacki faced scrutiny over the agency’s expanding surveillance powers and its role in combating illicit finance. Lawmakers expressed concern that the Bank Secrecy Act and related legislation have evolved into burdensome mandates which disproportionately affect small businesses and stifle innovation. Subcommittee Chair Warren Davidson criticised the system as a “bloated surveillance machine,” while Chairman French Hill proposed leveraging existing tax forms to streamline beneficial ownership reporting, rather than creating new databases vulnerable to breaches.

Director Gacki defended FinCEN’s efforts, highlighting aggressive actions against cartel-linked financial institutions in Mexico under the Fentanyl Sanctions Act, and initiatives targeting Iranian oil smuggling and Cuban military assets. She emphasised FinCEN’s commitment to modernising anti-money laundering frameworks, reducing compliance burdens, and enhancing digital asset oversight through the GENIUS Act.

The hearing underscored a growing tension between national security imperatives and civil liberties, as Congress weighs the cost of financial transparency against the risks of overregulation and data misuse.

SFO Recovers £1.1 Million in Landmark Use of Unexplained Wealth Order

The UK’s Serious Fraud Office (‘SFO’) has successfully recovered £1.1 million through its first use of an Unexplained Wealth Order, targeting assets linked to convicted fraudster Timothy Schools. The funds were traced to a Lake District property owned by Schools’ ex-wife, Claire Schools, which was purchased using proceeds from his fraudulent investment scheme involving law firms. Following a High Court order, the property was sold, marking a significant milestone in the SFO’s efforts to reclaim criminal assets. Director Nick Ephgrave emphasised the agency’s commitment to using all available tools to prevent family members and associates from benefiting from illicit gains. The investigation into Schools’ assets continues, with further legal proceedings scheduled.

Transparency International UK Unveils Blueprint to End Offshore Financial Secrecy

Transparency International UK has published a comprehensive set of guidelines aimed at dismantling financial secrecy in Britain’s offshore territories. The blueprint, titled Unlocking Ownership Data, outlines five key standards for implementing transparent beneficial ownership registers in jurisdictions like the British Virgin Islands, Cayman Islands, and Bermuda. These recommendations follow commitments made in 2024 to adopt Legitimate Interest Access Registers, and advocate for broad access to ownership data for journalists, NGOs, and investigators—without requiring justification. The document stresses that public registers remain the most effective tool for combating financial crime, which has enabled billions in tax evasion and global corruption. With the UK hosting a summit on illicit finance, the report urges immediate action to turn long-standing promises into meaningful reform.

Cybercrime

Ukrainian Cybercriminal Added to EU Most Wanted List for Global Ransomware Attacks

A Ukrainian national has been placed on the EU Most Wanted list for his alleged role in orchestrating major ransomware attacks, including the 2019 cyber assault on a Norwegian aluminium company. The suspect is believed to be a key figure in a sophisticated criminal network responsible for billions in global damages. The US Department of Justice is offering a reward of up to $10 million for information leading to his arrest. Europol, along with law enforcement agencies from multiple countries, has been investigating the network, which includes malware developers, intrusion experts, and money launderers. Several members have already been arrested in Ukraine, and the fugitive is accused of deploying the LockerGoga ransomware. Europol urges the public to visit the EU Most Wanted website and share any leads which could aid in his capture.

Beneath the Surface: How Terrorists Exploit the Dark Web and Cybercrime-as-a-Service

A new United Nations report explores the growing intersection between terrorism, violent extremism, and cybercrime on the dark web. It reveals how terrorist groups and cybercriminals are increasingly leveraging Cybercrime-as-a-Service platforms to acquire tools and services for launching cyber-attacks. The report emphasises the challenges faced by law enforcement in attributing and investigating these threats, and calls for stronger investigative capabilities and international cooperation. Jointly developed by UNOCT-UNCCT and UNICRI with support from the Republic of Korea, the report aims to inform global strategies and capacity-building efforts to counter these evolving digital threats.