Episode 192

10th October – 12th October 2025

Sanctions

US Intensifies Sanctions Blitz on Iran’s Energy Networks and Militia Proxies

The United States launched a sweeping sanctions campaign targeting Iran’s sprawling energy export apparatus and its affiliated militia proxies across the Middle East. The Treasury Department designated over 50 entities, individuals, and vessels involved in illicit Iranian petroleum and petrochemical trade, including shadow fleet tankers, Chinese refineries, and Gulf-based intermediaries which facilitated billions in revenue for Tehran’s regime. Simultaneously, the State Department imposed sanctions on foreign firms trading Iranian oil in violation of US law, reinforcing the administration’s maximum pressure strategy. In Iraq, Treasury cracked down on Iran-backed militias like Kata’ib Hizballah and their financial enablers, exposing a web of corruption, money laundering, and intelligence operations which threaten US personnel and regional stability. These coordinated actions underscore Washington’s resolve to disrupt Iran’s funding pipelines and dismantle its influence networks from the Gulf to the Levant. The State Department press release is here.

Money Laundering

European Banking Authority Finds Improvement in Anti-Money Laundering Supervision, But Work Remains

A recent report from the European Banking Authority (‘EBA’) reveals that the supervision of banks' efforts to combat money laundering and terrorist financing has significantly improved across the EU. After a comprehensive six-year review of all 40 competent authorities in the European Union and European Economic Area, the EBA found that most have adopted a risk-based approach, implemented dedicated strategies, and developed consistent guidelines for supervisors. The report also highlights increased cooperation between relevant national and international bodies. However, the EBA also notes that further improvements are still needed, particularly in the full implementation of its recommendations and in strengthening cooperation between anti-money laundering and prudential supervisors in some member states. The findings will be handed over to the new EU Anti-Money Laundering Authority (‘AMLA’), which will build on this work to further enhance the effectiveness of supervision in the EU.

EBA Urges Supervisors to Strengthen Oversight of Crypto Firms Amid Financial Crime Risks

The European Banking Authority (‘EBA’) has released a report urging national supervisors to learn from recent cases and bolster their anti-money laundering and counter-terrorist financing (‘AML/CFT’) oversight of crypto-asset service providers (‘CASP’s). Drawing on EU-wide supervisory experiences, the report highlights vulnerabilities exploited by some firms to evade regulation and emphasises the importance of robust supervision under the new Markets in Crypto-Assets Regulation (‘MiCA’). It offers targeted guidance to help authorities implement the revised AML/CFT framework effectively and safeguard financial integrity in the rapidly evolving crypto sector.

EBA Finds EU Banks Making Strides in AML Supervision, But Gaps Persist Ahead of AMLA Transition

The European Banking Authority’s final implementation review reveals that national regulators across the EU have significantly improved their supervision of money laundering and terrorist financing risks in banks, adopting more risk-based strategies, standardised manuals, and coordinated oversight frameworks. However, persistent challenges, such as staffing shortages, uneven cooperation with prudential supervisors, and resource constraints, continue to hinder full reform. As the new EU Anti-Money Laundering Authority (‘AMLA’) prepares to assume indirect supervisory responsibilities, the report serves as both a progress benchmark and a cautionary roadmap for sustaining momentum in the fight against financial crime.

FinCEN Streamlines Suspicious Activity Reporting to Prioritise High-Risk Threats

The US Treasury’s Financial Crimes Enforcement Network (‘FinCEN’), in coordination with federal banking regulators, issued updated guidance clarifying key aspects of Suspicious Activity Report (‘SAR’) requirements. The FAQs address common compliance pain points—such as structuring-related activity, continuing SAR filings, and documentation of decisions not to file, emphasising a risk-based approach which prioritises actionable intelligence over rote reporting. By refining expectations, FinCEN aims to reduce regulatory burden, sharpen law enforcement focus, and ensure that financial institutions allocate resources toward detecting and deterring the most significant threats to national security and financial integrity.

Bribery and Corruption

Sri Lanka Launches Digital Case-Tracking System to Combat Corruption and Boost Transparency

Sri Lanka’s Commission to Investigate Allegations of Bribery or Corruption (‘CIABOC’), in partnership with UNDP and funded by Japan, has launched a transformative Case-File Tracking System to modernise anti-corruption investigations. The digital platform streamlines case management, enhances workflow efficiency, and enables real-time tracking, marking a “paradigm shift” in institutional transparency. Officials hailed the system as a cornerstone of the country’s “Clean Sri Lanka” vision, aligning with IMF recommendations and broader digital governance reforms. With new infrastructure and staff training, CIABOC aims to strengthen accountability and restore public trust.

Somalia Trains Anti-Corruption Leaders to Strengthen Peacebuilding and Public Integrity

The UNODC has partnered with Somalia’s Federal Government to deliver a Corruption Risk Management Training of Trainers, equipping officials with tools to identify and mitigate corruption risks across public institutions. This initiative supports Somalia’s broader peacebuilding and governance reforms, including its National Reconciliation Framework and security sector overhaul. By fostering a network of trained professionals and embedding corruption risk assessments into institutional practice, the programme aims to enhance transparency, accountability, and public trust, which are key pillars for sustainable development and conflict prevention.

Other Financial Crime

Bosnia and Herzegovina Judges and Prosecutors Trained to Trace Illicit Funds in Financial Crime Crackdown

In early October 2025, the Council of Europe hosted a specialised training in Neum, Bosnia and Herzegovina, equipping judges and prosecutors with advanced skills to combat financial crime, corruption, and money laundering. The programme, part of the Council’s 2022–2025 Action Plan, focused on forensic techniques, asset recovery, and inter-agency cooperation, drawing on real case analyses to highlight investigative challenges and propose reforms. By strengthening institutional capacity and legal expertise, the initiative aims to bolster transparency, accountability, and democratic resilience across Bosnia and Herzegovina.

Cybercrime

Cyberattacks Spur Corporate Spending Surge, But Confidence in Defences Remains Low

In response to a wave of high-profile cyberattacks, including breaches at Ascom and Jaguar Land Rover, 60% of major firms are ramping up cybersecurity investment, yet only 6% feel fully confident in their defences, according to PwC’s global survey. Despite increased spending, vulnerabilities persist across supply chains, legacy systems, and cloud infrastructure, with AI-enabled threats compounding the challenge. Companies are reshaping infrastructure, policies, and vendor relationships, but PwC warns that without executive alignment and empowered CISOs, efforts may fall short. The report urges firms to embed cyber strategy into core business decisions and prioritise upskilling to stay ahead of evolving risks.