Episode 186

19th September – 21st September 2025

Sanctions

EU Suspends Trade Concessions with Israel Over Humanitarian Concerns

The European Commission has announced the suspension of certain trade concessions granted to Israel under the EU-Israel Association Agreement. This decision follows concerns that Israeli treatment of goods originating from settlements in occupied territories violates international law and EU trade rules. The move reflects the EU’s commitment to ensuring that preferential trade terms are not extended to products from areas considered illegally occupied under international law.

The suspension specifically targets goods produced in Israeli settlements located in the West Bank, East Jerusalem, and the Golan Heights. These areas are not recognised by the EU as part of Israel’s sovereign territory. The Commission emphasised that this action is not a blanket suspension of the entire agreement but a targeted measure to uphold legal and ethical standards in trade practices.

This decision aligns with broader EU efforts to support international humanitarian law and reinforce its stance on the illegality of settlements. It also sends a clear signal that trade benefits must be consistent with human rights obligations. The Commission will continue monitoring the situation and may take further steps if necessary to ensure compliance with EU law.

UK Sanctions Autel Robotics Over Drone Tech Linked to Ukraine Destabilisation

On 18th September 2025, the UK government reaffirmed financial sanctions against Autel Robotics Co., Ltd., a Chinese drone manufacturer known for its EVO and Dragonfish series used in aerial photography, mapping, and surveillance. The company remains subject to asset freezes and trust service restrictions under the Russia (Sanctions) (EU Exit) Regulations 2019, due to its alleged role in supplying uncrewed aerial vehicle systems and related technology which could contribute to undermining Ukraine’s territorial integrity. UK entities must freeze any assets linked to Autel, avoid providing trust services, and report relevant financial activity to the Office of Financial Sanctions Implementation, with non-compliance potentially constituting a criminal offence. Then, towards the end of the week, OFSI made further additions to the Russia Financial Sanctions regime, and updated the Consolidated List.

UK Warns Businesses of North Korean IT Workers Laundering Sanctioned Funds

The UK government has issued a detailed advisory warning businesses, particularly in the IT, crypto, and electronic payments sectors, about North Korean IT workers fraudulently securing remote contracts to funnel income back to the DPRK regime in violation of international sanctions. Operating primarily from Russia, China, and other global regions, these workers often conceal their identities and locations to evade detection. The advisory outlines red flags and deceptive practices used to mask their affiliations, urging UK firms to strengthen due diligence and compliance measures to prevent unwitting involvement in financial crime.

US Treasury Targets Sinaloa Cartel’s Financial Network in Major Sanctions Move

The US Department of the Treasury has imposed sweeping sanctions on a powerful faction of the Sinaloa Cartel, aiming to dismantle its financial infrastructure and disrupt its global drug trafficking operations. The action targets key individuals and entities involved in laundering proceeds from fentanyl and other narcotics, including the use of cryptocurrency and shell companies to obscure illicit flows. By freezing assets and restricting access to the US financial system, the Treasury seeks to choke off the cartel’s economic lifelines and reinforce its commitment to combating transnational financial crime.

Fraud

Property Fraud in England and Wales Remains Rare but Costly, Says HM Land Registry

Despite alarming media reports, HM Land Registry confirms that property fraud in England and Wales is relatively rare. In the financial year 2024–25, out of over 4.4 million applications to update or create entries in the Land Register, only 86 were found to be fraudulent, merely 0.0019%. However, the emotional and financial toll on victims can be severe, prompting the agency continually to refine its fraud detection methods and collaborate with other government bodies to raise awareness.

Property fraud can take many forms, including identity theft falsely to transfer ownership or register mortgages. HM Land Registry shared real-life examples where fraudulent applications were successfully intercepted, such as a suspicious transfer of a £360,000 bungalow and a £200,000 mortgage registration on a property whose owner had no knowledge of the transaction. In total, the agency prevented fraud against properties worth over £59 million in 2024–25, and more than £194 million since 2020.

To protect homeowners, HM Land Registry offers a state-backed indemnity scheme which compensates victims of registered title fraud. In 2024–25, four payments totalling nearly £399,000 were made. The agency also encourages property owners to take proactive steps: registering unregistered properties, keeping contact details current, signing up for the free Property Alert service, and considering a Counter Fraud restriction on their title.

For those suspecting fraud, HM Land Registry provides a dedicated fraud helpline and urges vigilance. They also support broader anti-fraud initiatives, directing citizens to the Home Office’s “Stop! Think Fraud” campaign for general fraud prevention.

Other Financial Crime

FCA Closes Investigation into Wellesley & Co Limited After Finding No Fraud

The Financial Conduct Authority (‘FCA’) has concluded its investigation into Wellesley & Co Limited (‘WCL’), determining that there was no evidence of serious misconduct or fraud. Launched in 2022 following concerns over Wellesley Finance Ltd’s Company Voluntary Arrangement (‘CVA’), the probe examined thousands of banking transactions, marketing materials, and investor testimonies. Although around £80 million of the £134.7 million owed to 12,000 investors has been returned, though some, particularly those who received preference shares, lost their entire investment. The FCA found that risks were clearly communicated and that WCL’s financial promotions were not misleading, leading to the decision to take no further action.

Strengthening Defences: FCA’s Tech-Driven Fight Against Financial Crime

Jessica Rusu, Chief Data, Information and Intelligence Officer at the Financial Conduct Authority (‘FCA’), delivered a forward-looking speech at the Future of Fintech 2025 event, outlining the regulator’s evolving strategy to support innovation while safeguarding financial integrity. While the overarching theme centred on growth and technological advancement, Rusu placed notable emphasis on the FCA’s commitment to tackling financial crime, particularly in high-risk sectors like crypto and emerging AI applications.

She announced new proposals to regulate crypto firms, requiring them to be operationally resilient and to enhance their systems and controls to combat financial crime. These measures aim to mirror the standards expected of traditional financial institutions, but with tailored provisions to address the unique vulnerabilities of digital assets. Additionally, Rusu highlighted the FCA’s Supercharged Sandbox initiative, which includes use cases specifically focused on fighting financial crime through AI experimentation. By enabling firms to assess innovative technologies in a controlled environment, the FCA hopes to foster responsible adoption of AI tools which can detect and prevent illicit activity more effectively.

This speech was doubtless timed to coincide with the publication of the FCA Consultation Paper (CP25/25) on the ‘Application of FCA Handbook for Regulated Cryptoasset Activities’ which was published this week. In that Consultation Paper, the FCA proposals for crypto firms include a strong emphasis on tackling financial crime, recognising the sector’s vulnerability to illicit activity due to its rapid growth and technological complexity.

Enhanced Systems and Controls: The FCA is proposing that crypto firms implement robust systems to detect and prevent financial crime. This includes measures to identify suspicious transactions, monitor customer behaviour, and ensure compliance with anti-money laundering regulations. These controls are expected to mirror those used by traditional financial institutions, but with adaptations for the unique risks posed by digital assets.

Operational Resilience and Accountability: Crypto firms will be required to demonstrate operational resilience, meaning they must be able to continue functioning during disruptions and maintain the integrity of their systems. This is crucial for preventing exploitation by bad actors. The FCA also stresses the importance of clear governance structures and accountability, ensuring that senior managers are responsible for maintaining crime prevention standards.

Innovation with Safeguards: While the FCA supports innovation, it is clear that this must not come at the expense of consumer protection or market integrity. The proposals aim to strike a balance by encouraging technological advancement while embedding safeguards against financial crime. This includes leveraging AI and data analytics to enhance monitoring and enforcement.

The Consultation Paper asks for comment on chapters one to five by 12th November 2025, and on chapters six and seven by 15th October 2025.

Cracking Down on Criminal Play: New Insights into Illegal Gambling Behaviours

The Gambling Commission has released the first in a series of reports exploring the illegal online gambling market in Great Britain, with a sharp focus on consumer behaviours and motivations. This initial instalment sheds light on how individuals discover and engage with unlicensed gambling platforms, revealing the psychological and situational drivers behind their choices. The research aims to deepen understanding of this shadowy sector, which the Commission describes as “unsafe, unfair and criminal.”

Andrew Rhodes, Chief Executive of the Commission, emphasised the urgency of tackling this issue, citing a ten-fold increase in disruption activity since April 2024. The report is part of a broader strategy to protect consumers and uphold trust in the regulated market. Future instalments will delve into engagement trends, enforcement efforts, and the challenges of estimating the true scale of the illegal market.

Canada’s Largest Crypto Seizure Targets Money Laundering Network

The Royal Canadian Mounted Police has executed the largest cryptocurrency seizure in Canadian history, recovering over $56 million from the unregistered exchange platform TradeOgre. Triggered by a Europol tip, the investigation revealed the platform’s failure to comply with Canadian financial regulations, including its lack of registration with FINTRAC and failure to identify users, key indicators of money laundering risk. Authorities believe the majority of funds transacted were linked to criminal sources, and the seizure marks the first time Canadian law enforcement has dismantled a crypto exchange, signalling a major step in combating digital financial crime.

Cybercrime

Cybercrime Charges Spotlight Financial Threats to Public Infrastructure

Two young men have been charged in connection with a cyber-attack on Transport for London (‘TfL’), marking a significant escalation in the UK's fight against financially motivated cybercrime. The National Crime Agency (‘NCA’) alleges that the suspects, aged 18 and 19, were part of the notorious online criminal group Scattered Spider, which infiltrated TfL’s network in August 2024. The attack caused substantial disruption and millions in financial losses, underscoring the vulnerability of critical national infrastructure to digital threats.

Beyond the TfL breach, one of the individuals faces additional charges for conspiring to damage the networks of two US healthcare companies, further highlighting the transnational nature of cyber-enabled financial crime. The case reflects growing concerns among UK authorities about the rise of sophisticated cybercriminals operating from English-speaking countries. The NCA, in collaboration with domestic and international partners including the FBI, has intensified efforts to identify and prosecute offenders who exploit digital systems for financial gain.

In parallel action in the US, the 19-year-old, Thalha Jubair, has been charged with multiple counts of computer fraud, wire fraud, and money laundering in connection with a sweeping cyber extortion campaign. Allegedly operating under aliases like “EarthtoStar” and “@autistic,” Jubair is accused of orchestrating at least 120 network intrusions targeting 47 US entities, including critical infrastructure and the federal court system, through the cybercriminal group Scattered Spider. Victims reportedly paid over $115m in ransom, with portions laundered through cryptocurrency wallets linked to Jubair. His arrest, coordinated across international law enforcement agencies, marks a major escalation in efforts to combat financially motivated cybercrime.

Cyber Attacks Inflict €300 Billion Blow to German Economy, Survey Reveals

A recent survey by Bitkom, Germany’s digital industry association, found that cyberattacks, many traced to Russia and China, cost the German economy nearly €300bn over the past year. The report highlights a surge in ransomware incidents, with one in seven companies admitting to paying ransoms. While large firms are better equipped to handle these threats, smaller businesses remain vulnerable. The line between cybercrime and state-sponsored espionage is increasingly blurred, as foreign intelligence agencies exploit criminal networks to infiltrate German companies, leading to massive production losses, data theft, and legal costs.