Episode 184

12th September – 14th September 2025

Sanctions

Frozen Assets Reporting Deadline: 30th November 2025

HM Treasury’s Office of Financial Sanctions Implementation (‘OFSI’) requires all individuals and entities holding funds or economic resources linked to designated persons to submit a comprehensive report by Sunday, 30th November 2025. The report must detail all frozen assets—both in the UK and overseas—subject to UK financial sanctions legislation, with valuations as of close of business on Tuesday, 30th September 2025. This includes shares, securities, and other instruments, which must be reported in GBP. Even if previously submitted, a new return is mandatory for the 2025 review, using the updated template available on GOV.UK and sent to ofsi@hmtreasury.gov.uk. The Notice and reporting template are here.

Sanctions Update: Ilya Brodskiy Delisted from UK Russia Regime

On 11th September 2025, HM Treasury’s Office of Financial Sanctions Implementation (‘OFSI’) announced that Ilya Borisovich Brodskiy has been removed from the UK’s Consolidated List and is no longer subject to asset freeze or trust services sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019. Then, on 12th September 2025, OFSI designated 27 entities, three Individuals, and specified 70 ships under the Russia Sanctions Regime. These designations aim to undermine Russia’s revenues and military supplies, including its ‘shadow fleet’ carrying oil.

US Treasury Targets Houthi Global Revenue and Weapons Networks in Largest Sanctions Action to Date

On 11th September 2025, the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) imposed sanctions on 32 individuals and entities, along with four vessels, in its most extensive action yet against Iran-backed Ansarallah (the Houthis). These sanctions target a vast network spanning Yemen, China, the UAE, and the Marshall Islands, involved in illicit oil imports, money laundering, and procurement of advanced weaponry used in attacks on US forces and allies. The Houthis’ operations include fraudulent asset seizures, front companies, and smuggling routes which fund their military campaigns and destabilise maritime security in the Red Sea. This action builds on previous designations and aligns with broader US efforts to exert maximum economic pressure on Iran and its proxies.

Fraud

London Fraudster Jailed for Exploiting Covid Loan Scheme to Fund Ghana Trade

Eric Agyeman, a 46-year-old from London, has been sentenced to two years and two months in prison for fraudulently securing £130,000 through three Bounce Back Loan applications during the Covid-19 pandemic. Despite businesses being eligible for only one loan, Agyeman fabricated turnover figures for his company, DOK Logistics UK Ltd, which never traded. He used over £40,000 of the funds to purchase goods for export to Ghana, where an associate sold them and returned commission payments. The Insolvency Service’s investigation revealed a blatant misuse of taxpayer-funded support, with Agyeman admitting he simply “made up” the figures. In addition to his jail term, he has been banned from serving as a company director for five years. Authorities are now pursuing recovery of the funds under the Proceeds of Crime Act.

Money Laundering

MONEYVAL Begins Sixth Evaluation of Hungary’s Anti-Money Laundering Framework

MONEYVAL has officially launched its sixth round of mutual evaluations for Hungary, marking a significant step in assessing the country’s anti-money laundering and counter-terrorism financing measures. The process began with a high-level exchange involving key national figures, including the MONEYVAL Chair and representatives from Hungary’s Ministry of National Economy and anti-money laundering commission. A targeted training session followed, bringing together over 130 participants from government, law enforcement, judiciary, financial institutions, and the private sector. The training aimed to deepen understanding of FATF standards and MONEYVAL’s evaluation methodology, reinforcing Hungary’s commitment to international compliance and financial integrity.

Bribery and Corruption

Whistleblower Tips Uncover 43% of Corruption Cases in Ukraine, Study Finds

A recent study supported by UNDP Ukraine and the Government of Japan reveals that whistleblower tips were responsible for exposing 43% of corruption cases, highlighting their critical role in promoting transparency. Despite 85% of employees expressing willingness to report misconduct, only 46% of Ukrainian state-owned enterprises have policies to protect whistleblowers, creating a significant gap in support. The study, based on surveys from 888 employees across 24 enterprises, found that fear of retaliation and unclear reporting procedures remain major barriers. Recommendations urge the Ministry for Communities and Territories Development, enterprise management, and anti-corruption officers to strengthen whistleblowing systems through training, policy development, and cultural change to foster integrity and accountability in Ukraine’s post-war recovery.

Market Abuse

Finfluencers Face Court in FCA Crackdown on Illegal Promotions

Three social media influencers, Charles Hunter, Kayan Kalipha, and Luke Desmaris, have appeared at Westminster Magistrates’ Court, charged with unlawfully promoting high-risk forex investments without authorisation. The charges stem from a global enforcement operation led by the UK’s Financial Conduct Authority (‘FCA’), targeting illegal financial promotions by finfluencers. All three pleaded not guilty and are scheduled for a hearing at Southwark Crown Court on 8th October 2025. This marks a significant step in the FCA’s broader effort to protect consumers from misleading online investment content.

Other Financial Crime

FCA Calls for United Front to Tackle Financial Crime and Restore Trust

In a speech at the 1LoD Financial Crime Summit, Steve Smart, joint executive director of enforcement and market oversight at the Financial Conduct Authority (‘FCA’), emphasised the urgent need to combat financial crime as a foundation for economic growth. Drawing parallels with football strategy, Smart argued that financial services must adopt a proactive, collaborative approach, pressing high, anticipating threats, and disrupting criminal activity before it takes root.

Smart highlighted the damaging misconception that financial crime is victimless, noting its direct links to serious offences like human trafficking and terrorism. He stressed that fraud erodes public trust, which in turn stifles investment and innovation. The FCA’s recent enforcement actions, including convictions, fines, and the takedown of thousands of fraudulent apps and websites, demonstrate progress, but Smart warned that fraud and money laundering remain widespread and increasingly sophisticated.

To stay ahead, Smart advocated for smarter detection systems, better data sharing, and the use of synthetic data to improve anti-money laundering tools. He praised initiatives like the NECC’s Data Fusion Project and the Economic Crime and Corporate Transparency Act, which foster cross-sector collaboration. International efforts, including crackdowns on rogue “finfluencers,” also underscore the importance of global cooperation.

Smart concluded by calling for a new relationship between regulators and industry, one built on trust, transparency, and shared responsibility. While acknowledging that no system can prevent every harm, he expressed confidence that with the right mindset, teamwork, and strategic focus, the UK can decisively reduce financial crime and strengthen the integrity of its markets.

Record £50 Million Returned to Victims as UK Cracks Down on Criminal Wealth

The UK government has reported a landmark figure in its fight against financial crime, returning nearly £50 million to victims, which is a 165% increase from the previous year. This surge in compensation stems from a broader crackdown which saw law enforcement recover almost £300 million in criminal assets, including cash, property, and luxury items. Under the Proceeds of Crime Act, these funds are being reinvested to strengthen border security and support frontline policing. Greater Manchester Police alone seized £12 million, directing half toward community crime prevention projects. The Serious Fraud Office also made strides, securing £1.1 million through its first unexplained wealth order. Security Minister Dan Jarvis hailed the results as proof that “crime doesn’t pay,” with recovered funds now fuelling public services and safer streets. As fraud continues to affect one in fifteen UK adults annually, a new strategy is set to launch later this year to further protect the public and dismantle criminal networks.

Cybercrime

UK Government Ramps Up Fight Against Cyber Crime and Fraud

In a speech delivered on 9th September 2025, Security Minister Dan Jarvis outlined the UK’s intensified efforts to combat cyber-crime and fraud, highlighting alarming statistics and recent high-profile attacks. He praised the work of the City of London Police and announced expanded responsibilities across the Home Office and Cabinet Office to unify national security efforts. Key initiatives include the National Fraud Squad, the Online Safety Act, international partnerships, and upcoming strategies to tackle ransomware and corruption. Jarvis emphasised the need for cross-sector collaboration to stay ahead of evolving threats and protect UK citizens and businesses.