Episode 193

13th October – 16th October 2025

Sanctions

UK Sanctions Lists to Merge: OFSI Consolidated List Retires January 2026

The UK Government has announced a major change in how sanctions designations will be published and accessed. As of 09:00 GMT on 28 January 2026, the UK Sanctions List (‘UKSL’) will become the sole official source for all UK sanctions designations. This move consolidates the current dual-list system, comprising the UKSL and the OFSI Consolidated List of Asset Freeze Targets, into a single, streamlined list.

The UKSL, maintained under the Sanctions and Anti-Money Laundering Act 2018 (‘SAMLA’), already includes financial, immigration, trade, and transport sanctions. In contrast, the OFSI Consolidated List has focused exclusively on financial sanctions. The transition responds to industry feedback calling for simplification and reduced duplication in compliance processes.

Businesses and compliance teams must update their systems to source data from the UKSL instead of the OFSI Consolidated List. Crucially, identifiers will change: the ‘OFSI Group ID’ will be retired for new designations, replaced by the UKSL’s ‘Unique ID’ and ‘Sanction Type’ fields. Historic OFSI Group IDs will remain valid for pre-2026 designations but will no longer be issued.

To support the transition, the UKSL will expand its file formats to include CSV, PDF, and TXT, alongside existing ODS, ODT, HTML, and XML options. A new search tool—live since July 2024—will be enhanced with fuzzy logic and improved usability. Designation notices will also be broadened to cover all sanction types, not just financial.

The government urges organisations to begin adapting immediately and consult third-party screening providers to ensure continuity. No structural changes to the UKSL format are planned, and no draft templates will be issued, as the list is already live and usable.

Compliance Clarity: How One Bank’s Due Diligence Averted a Sanctions Breach

In a recent blog post from the Office of Trade Sanctions Implementation (‘OTSI’), a real-world case study illustrates how a UK branch of a multinational bank identified and halted payments linked to sanctioned Russian goods, thereby avoiding a breach of UK trade sanctions. The post highlights the importance of enhanced due diligence, internal screening procedures, and timely reporting, especially for financial institutions operating across jurisdictions. It also offers practical takeaways for businesses beyond the financial sector, encouraging wider adoption of risk-based compliance strategies and use of OTSI’s reporting tools to support the global effort against Russian sanctions evasion.

Fraud

Fraud Is Evolving—Banks Must Rethink Resilience, Says Grant Thornton

In an opinion piece from Grant Thornton, risk advisory experts argue that banks are underprepared for the surge in AI-driven fraud, which is exploiting fragmented defences, unclear tech ownership, and outdated response models. They advocate for enterprise-wide fraud resilience assessments, not as a cure-all, but as a strategic roadmap to identify gaps, unify teams, and embed a culture of proactive defence. With deepfakes, automated probes, and customer trust at stake, the authors urge banks to move beyond reactive fixes and embrace holistic, forward-looking fraud governance as a competitive differentiator.

Bribery and Corruption

Liberia Concludes Final Anti-Corruption Training for Local Officials with UNDP Support

The Liberia Anti-Corruption Commission, backed by UNDP and the UN Peacebuilding Fund, wrapped up its final three-day anti-corruption training for local officials in Harper, Maryland County, engaging participants from five southeastern counties. The workshop emphasised ethical leadership, whistleblower protections, and the role of local governance in fostering transparency and public trust. Concerns over whistleblower safety sparked active dialogue, while officials pledged reforms. This session marked the culmination of a nationwide initiative empowering officials from all 15 counties to champion accountability, supported by a coalition of government bodies and civil society partners.

Ethics Reform Stalls: UK Government Implements Just Two of 28 Key Integrity Recommendations

Transparency International UK’s latest analysis reveals that the UK Government has made minimal progress on improving standards in public life, implementing only two of the 28 outstanding recommendations from the Committee on Standards in Public Life’s 2021 report. While the launch of the new Ethics and Integrity Commission is welcomed, it does not directly address the committee’s proposals, many of which remain untouched—including reforms to lobbying transparency and post-government employment rules. The findings suggest a piecemeal approach which falls short of the comprehensive ethical overhaul promised by the current administration

Other Financial Crime

“Bitcoin Jesus” Roger Ver Admits Tax Fraud in $48M Deferred Prosecution Deal

Roger Ver, a prominent early cryptocurrency investor known as “Bitcoin Jesus,” has admitted to filing false tax returns and concealing substantial offshore assets in a deferred prosecution agreement with US authorities. Ver renounced his US citizenship in 2014 but failed to report the sale of tens of thousands of bitcoins—worth over $240 million at the time—and misrepresented the value of his holdings to the IRS. As part of the agreement, he will pay $48 million in restitution and cooperate with ongoing investigations. The case underscores the US government’s increasing scrutiny of crypto-related tax evasion and offshore asset concealment. US Attorney’s Office press release is here, and the Department of Justice press release is here.

Cybercrime

US and U.K. Launch Historic Crackdown on Southeast Asian Cybercrime Empire

In a sweeping joint operation, the US Treasury and U.K. Foreign Office have imposed unprecedented sanctions on Cambodia-based Prince Group TCO and its leader Chen Zhi, dismantling a vast transnational cybercrime network responsible for billions in online scam losses. The Prince Group’s operations—linked to human trafficking, torture, and financial fraud—used over 100 shell companies to launder illicit gains and exploit trafficked workers in scam compounds. Concurrently, the US cut off Huione Group from its financial system for laundering funds tied to North Korean cyber heists and Southeast Asian scams. This coordinated action marks the largest-ever bilateral move against cybercriminal networks in the region. This is the UK government press release.

WEF Blog Warns of Cybersecurity Blind Spot in Critical Infrastructure

A recent blog post from the World Economic Forum highlights a dangerous oversight in global cybersecurity: the vulnerability of operational technology (‘OT’) within critical infrastructure. While IT systems often receive robust protection, OT, used in power grids, water systems, and transport networks, remains under-monitored and poorly defended. The post cites the April 2025 Iberian blackouts as a stark example, where investigators struggled to determine whether the outages were caused by technical faults or cyberattacks. Without forensic visibility, responders are left guessing, undermining recovery, accountability, and national security. The WEF urges governments, executives, and operators to treat OT monitoring as a core necessity, not an afterthought.

UK Government Urges Business Leaders to Prioritise Cyber Resilience at Board Level

In a joint ministerial letter, senior UK officials, including the Secretaries of State for Science, Business, and the Chancellor, called on CEOs and chairs of leading UK companies to treat cyber security as a strategic board-level priority. Citing increasingly sophisticated cyber threats to national and economic security, the letter outlines three immediate actions: adopt the Cyber Governance Code of Practice, register for the NCSC’s Early Warning service, and require Cyber Essentials certification across supply chains. The government emphasises that cyber resilience is essential for economic growth and operational continuity, and invites industry leaders to collaborate on shaping forthcoming legislation and strengthening national defences.

UK Faces Surge in Cyber Threats: NCSC Reports Four Major Attacks Weekly

The UK’s National Cyber Security Centre (‘NCSC’) Annual Review 2025 has revealed a dramatic rise in cyber threats, handling 204 nationally significant attacks in the year to September, up from 89 the previous year, averaging four major incidents each week. Of these, 18 were deemed “highly significant,” posing serious risks to essential services and national infrastructure. Many attacks were linked to advanced persistent threat actors, including hostile states and sophisticated criminal groups. In response, the government is urging businesses to bolster their cyber defences, launching new resources like the Cyber Action Toolkit and promoting the Cyber Essentials scheme, which includes free insurance for eligible small organisations.