Episode 185

15th September – 18th September 2025

Sanctions

US Treasury Sanctions Sudanese Islamist Figures Over Iran Ties and Civil War Atrocities

The US Department of the Treasury has imposed sanctions on Sudan’s Finance Minister Gebreil Ibrahim and the Al-Baraa Bin Malik Brigade, citing their roles in Sudan’s ongoing civil war and their connections to Iran’s Islamic Revolutionary Guard Corps. These groups have contributed thousands of fighters, committed human rights abuses, and obstructed peace efforts, worsening what is now the world’s worst humanitarian crisis. The sanctions aim to disrupt Islamist influence in Sudan and prevent the country from becoming a hub for threats to US and regional security.

US Treasury Sanctions Global Network Funding Iran’s Military and Terrorist Activities

On 16th September 2025, the US Department of the Treasury’s Office of Foreign Assets Control imposed sanctions on a network of Iranian, Hong Kong, and UAE-based individuals and entities for facilitating illicit financial transactions which support Iran’s military and terrorist operations. These actors, including Alireza Derakhshan and Arash Estaki Alivand, used front companies and cryptocurrency to launder proceeds from Iranian oil sales, benefiting the IRGC-Qods Force and Iran’s Ministry of Defence. The sanctions target entities involved in hundreds of millions of dollars in transactions, aiming to disrupt Iran’s shadow banking infrastructure and its funding of ballistic missile development and regional proxy groups. This action follows a broader US campaign of maximum pressure against Iran under Executive Order 13224.

OFAC Reminds Holders of Blocked Property to File Annual Report by 30th September

The US Department of the Treasury's Office of Foreign Assets Control (‘OFAC’) has issued a reminder to all individuals and entities holding property blocked under its regulations as of 30th June 2025, that they are required to file the 2025 Annual Report of Blocked Property (‘ARBP’) by 30th September 2025. The notice clarifies that "blocked property" does not include assets which have been unblocked or those belonging to sanctions programmes which have been terminated. The mandatory report must be filed online using the specified form, and failure to comply with this requirement can result in legal consequences.

Bribery and Corruption

OSCE and Moldova's National Anticorruption Centre Host "Anti-Corruption Café" to Promote Integrity in Education

The Organisation for Security and Co-operation in Europe (‘OSCE’) and Moldova's National Anticorruption Centre (‘NAC’) have established an open dialogue platform, the "Anti-Corruption Café," to foster integrity and transparency within Moldova's education sector. The most recent event, held on 15th September 2025, brought together 45 anti-corruption volunteers and young people with representatives from the Ministry of Education and the NAC. Discussions centred on preventing informal payments in educational institutions, ensuring fair examinations, and increasing community involvement in promoting a culture of integrity. This initiative is part of the OSCE's project "Supporting anti-corruption efforts of the Government of Moldova," funded by France, Germany, Italy, and Romania.

Market Abuse

DOJ Charges Chinese Tech Executives in $100M Pump-and-Dump Fraud Targeting US Investors

The US Department of Justice has indicted Lai Kui Sen, co-CEO of Ostin Technology Group (‘OST’), and financial advisor Yan Zhao for orchestrating a $100 million securities fraud scheme. The pair allegedly distributed millions of OST shares to co-conspirators through sham transactions, then launched a deceptive social media campaign to inflate the stock’s value. Once the price surged, they dumped the shares for massive profits, leaving unsuspecting American retail investors with devastating losses. Indeed, OST’s market value plummeted by over 94% in June 2025. The DOJ, FBI, and SEC-OIG are pursuing aggressive prosecution, emphasising their commitment to protecting US financial markets from foreign exploitation.

Other Financial Crime

Global Anti-Financial Crime System Faces Crisis of Effectiveness and Innovation

A recent commentary from the Royal United Services Institute (‘RUSI’) argues that the global anti-financial crime system is fundamentally broken. Despite over $200 billion spent annually on compliance, there's little evidence that current frameworks, especially those built around suspicious activity reports (‘SAR’s), are effectively curbing money laundering or related crimes. Studies show that only a tiny fraction of SARs lead to investigations or convictions, while defensive filing and regulatory fear stifle innovation. RUSI’s “Think the Unthinkable” campaign invited experts to challenge the status quo, revealing widespread frustration with outdated compliance models, poor cross-border collaboration, and perverse incentives which discourage transparency. Contributors called for systemic reform, real-time data sharing, and bold leadership to modernise the fight against financial crime. The message is clear: the current system is not just lagging, but it’s actively enabling the very threats it aims to stop.

UK Sees 15% Increase in Asset Recovery, Denying Criminals Access to Over £780 Million

In the fiscal year ending March 2025, the UK's asset recovery efforts saw a significant increase, with £284.5 million in assets recovered, a 15% rise from the previous year. Additionally, the system successfully denied criminals access to £783.8 million in illicit assets.

Key highlights from the report include:

-        Victim Compensation: A total of £47.2 million was paid to victims from the proceeds of crime, providing some measure of restitution for their losses.

-      Funding for Enforcement: The Asset Recovery Incentivisation Scheme distributed £160.3 million to agencies under the Proceeds of Crime Act, bolstering their capacity to combat financial crime.

UK’s National Crime Agency Takes Helm of Five Eyes Law Enforcement Group Amid Rising Global Threats

The UK’s National Crime Agency (‘NCA’) has assumed the chair of the Five Eyes Law Enforcement Group (‘Five Eyes’), marking its first leadership role in the alliance since 2015. This two-year tenure comes as serious and organised crime, especially cybercrime, child sexual abuse, and fraud, continues to escalate across borders and digital platforms. The NCA aims to intensify operational collaboration among Five Eyes members, including the FBI, DEA, and law enforcement agencies from Australia, Canada, and New Zealand. Key priorities include disrupting violent online gangs known as “com networks,” enhancing data sharing, and strengthening technological capabilities. The UK’s Counter Terrorism Policing has also been promoted to full Five Eyes membership, reflecting the growing overlap between organised crime and national security threats. NCA Director General Graeme Biggar emphasised the need for unified international action to counter evolving criminal tactics and safeguard communities worldwide.

OECD’s Global Forum Scales Up CRS Compliance with Train-the-Trainer Programme

In 2025, the OECD’s Global Forum launched a six-month ‘Train the Trainer’ series to bolster administrative compliance with the Common Reporting Standard (‘CRS’) for Automatic Exchange of Financial Account Information. The initiative trained 102 officials from 50 jurisdictions, spanning Asia-Pacific, the Caribbean, Europe, Latin America, Africa, and the Middle East, who have since cascaded their knowledge to over 800 additional officials. Designed to prepare jurisdictions for the 2026 round of CRS effectiveness reviews, the programme covered key compliance concepts, risk assessment strategies, and supervisory techniques, including desk-based and onsite reviews. Realistic case studies and peer exchanges reinforced learning, creating a global multiplier effect and strengthening cross-border tax transparency.

Cybercrime

Teen Hackers Target Schools: Watchdog Warns of Rising Insider Cyber Threat

The Information Commissioner's Office (‘ICO’) has raised alarms over a surge in cyber-attacks within UK schools, revealing that over half of these insider breaches were caused by students themselves. Rather than sophisticated break-ins, many teens are simply guessing weak passwords or finding them written down. Motivated by dares, curiosity, or online rivalries, some students have used downloadable hacking tools to access sensitive school systems, including personal data of thousands of pupils. The ICO warns that this trend, often misunderstood and unaddressed, could escalate into serious criminal behaviour. With cases involving children as young as seven, experts stress the need to channel young people's interest in cybersecurity into legal and constructive paths.

Gucci Owner Kering Hit by Data Breach as Hackers Steal Customer Information

Kering, the luxury fashion group which owns brands such as Gucci, Balenciaga, and Alexander McQueen, has been targeted by hackers who stole the personal data of its customers. The ransom-seeking group Shiny Hunters claimed responsibility for the breach, which occurred in June 2025, and posted samples of the stolen information, including names, phone numbers, and email addresses, on Telegram. Kering confirmed the attack, stating that no financial data was compromised and that they have secured their systems and notified the relevant authorities and affected customers. This incident is the latest in a series of cyberattacks on major companies, highlighting the growing threat of data breaches.

Jaguar Land Rover Cyberattack Sparks Data Breach and Economic Fallout

The impact of the cyber-attack on Jaguar Land Rover continues to be felt with new impact coming to the news lines this week. The attack, which has crippled production across its UK and global operations, has now been confirmed to have compromised sensitive data in the breach. The shutdown, ongoing since 31st August, has triggered cascading effects throughout the automotive supply chain, forcing thousands of workers into temporary layoffs and prompting MPs to call for COVID-style financial support to protect jobs and businesses. The attack, claimed by a group linked to notorious hacker collectives like Scattered Spider and Lapsus$, has not only disrupted manufacturing but also raised serious regulatory concerns, as JLR begins notifying authorities about the compromised data. In terms of financial impact, Dr Charles Tennant, an Automotive Analyst, has estimated that the attack has cost the company £1bn in lost production, so far.