Episode 190

3rd October – 5th October 2025

Sanctions

US Unleashes Coordinated Sanctions on Iran’s Nuclear and Ballistic Missile Programmes Amidst Government Shutdown

The United States government announced a significant, coordinated sanctions action on 1st October 2025, targeting a total of 44 individuals and entities involved in Iran’s weapons programmes. Both the Department of State and the Department of the Treasury imposed these sanctions pursuant to Executive Order 13382, targeting proliferators of weapons of mass destruction (‘WMD’), in support of the "snapback" of UN sanctions following Iran’s non-performance of its nuclear commitments. Treasury Secretary Scott Bessent stated that the action aims to deny the regime weapons it would use to further its “malign objectives” and counter a significant threat posed by Iran’s conventional weapons capabilities to US forces and commercial ships. The press release is here, and the fact sheet is here.

The Treasury designated 21 entities and 17 individuals within global procurement networks which facilitate the acquisition of sensitive goods for Iran’s Ministry of Defence and Armed Forces Logistics. These networks spanned multiple continents, procuring components like gyroscopes and microelectromechanical systems for ballistic missile guidance programmes, dual-use electronics for missile radar systems, and equipment including a US-origin helicopter for the military aircraft programme PANHA. Concurrently, the Department of State sanctioned five individuals and one entity connected to Iran’s Organisation of Defensive Innovation and Research (‘SPND'), which is the direct successor to Iran’s pre-2004 nuclear weapon programme. These State targets, which included SPND Director Reza Mozaffarinia and the cover company Andisheh Damavand International Technologies, were sanctioned for seeking sensitive dual-use technologies and technical expertise applicable to nuclear weapons development.

UK Treasury Enforces Dual-Front Financial Sanctions Against Terrorism and Iranian Nuclear Proliferation

The Office of Financial Sanctions Implementation (‘OFSI’) in the UK has announced updates to the UK's financial sanctions lists, targeting both domestic counter-terrorism threats and Iran’s nuclear programme. Under the Counter-Terrorism (Domestic) regime, two entries respecting Embers of an Empire and Rampage Productions have been amended, and under the Iran (Nuclear) Regulations, the Europaisch-Iranische Handelsbank AG entry has been amended.

Money Laundering

AUSTRAC Launches National Campaign to Prepare Industry for Sweeping AML/CTF Reforms

AUSTRAC has launched a nationwide awareness campaign to support the rollout of Australia’s most significant Anti-Money Laundering and Counter-Terrorism Financing reforms in two decades. The new laws will expand regulatory coverage to previously unregulated sectors and shift compliance expectations toward a risk-based, outcomes-focused approach. The campaign, running through July 2026, includes phased guidance, notably awareness, preparation, and enrolment, alongside practical tools, sector-specific kits, and upgraded support services. AUSTRAC aims to embed reform into everyday operations while aligning with global standards set by the Financial Action Task Force.

Other Financial Crime

Malaysia Backs Deferred Prosecution Agreements to Boost Anti-Corruption and Asset Recovery

Malaysia’s Special Cabinet Committee on National Governance, chaired by Prime Minister Anwar Ibrahim, has endorsed the introduction of a Deferred Prosecution Agreement (‘DPA’) framework to modernise the Malaysian Anti-Corruption Commission’s (‘MACC’) enforcement strategy. The proposed legislation, set for parliamentary debate next year, would allow prosecutors to suspend charges against corporations or individuals in exchange for admissions of wrongdoing, financial penalties, and reforms, which mirrors models used in the US and UK. MACC Chief Commissioner Azam Baki emphasised that DPAs would shift financial responsibility for white-collar crimes to offenders, enhance asset recovery in major corruption cases, and reflect a more dynamic, globally aligned approach to enforcement.

Deferred Prosecution Agreements Offer Economic Safeguards but Raise Recidivism Concerns, Study Finds

A new study published in Contemporary Accounting Research reveals that deferred and non-prosecution agreements (‘D/NPA’s), increasingly used in corporate crime cases such as bribery and fraud, often serve their intended purpose of shielding innocent stakeholders from economic fallout. Analysing nearly 300 US cases from 2000 to 2019, researchers found D/NPAs were more common among large, regulated firms facing complex allegations, such as foreign bribery. However, companies granted D/NPAs were 13.2 per cent more likely to reoffend than those accepting plea deals, raising questions about the long-term effectiveness of these agreements in restoring corporate credibility. The findings suggest a strategic trade-off between economic stability and deterrence. The study is open access and available here.

Council of Europe Project Strengthens Anti-Corruption and AML Defences Across 17 European States

The Council of Europe’s “Action against Corruption and Money Laundering in Europe” initiative aims to fortify anti-corruption, AML, and counter-terrorism financing frameworks across 17 European countries. Running from January 2023 to May 2030 with €2.5 million in funding from the EEA and Norway Grants, the project delivers tailored technical assistance, promotes peer exchange, and replicates best practices aligned with GRECO, EU, and FATF standards. Key priorities include lobbying reform, whistleblower protection, beneficial ownership verification, and tackling financial crime linked to environmental offences. The initiative targets law enforcement, asset recovery offices, and AML/CFT authorities to enhance regional cooperation and enforcement resilience.

Cybercrime

Hackers Delete Stolen Nursery Data After Public Outcry Forces U-Turn

Cybercriminals who targeted UK nursery chain Kido Schools have deleted stolen data and images of children following intense public backlash. The group, calling itself Radiant, had posted profiles of over 8,000 children on the darknet and demanded a £600,000 Bitcoin ransom, even contacting parents directly. After widespread condemnation, they blurred the images, then removed all content and issued an apology, claiming to have deleted the data. Experts remain sceptical, noting past cases where hackers falsely claimed to have erased stolen information. The attack, enabled by purchased access to a compromised staff computer, has sparked renewed concern over vulnerabilities in early years education platforms.