Episode 194

17th October – 19th October 2025

Sanctions

UK Unleashes Sweeping Sanctions on Russian Oil Giants to Cripple Putin’s War Economy

In its most forceful sanctions package to date, the UK has targeted Russia’s top oil producers, Rosneft and Lukoil, alongside 90 entities linked to Kremlin energy revenues, including Chinese terminals, shadow fleet tankers, and Nayara Energy. Announced by Foreign Secretary Yvette Cooper in Parliament and timed with Chancellor Rachel Reeves’ G7 meetings in Washington, the measures aim to choke off funding for Putin’s war machine and reinforce European security. The UK also banned imports of oil products refined from Russian-origin crude and sanctioned LNG infrastructure, tightening the net around Russia’s military supply chains and global enablers.

OFSI Freezes £37B in Assets as UK Sanctions Enforcement Hits New Heights

The UK’s Office of Financial Sanctions Implementation (‘OFSI’) reported a record £37 billion in frozen assets in its 2024–25 Annual Review, up from £24.4 billion the previous year, reflecting intensified enforcement of Russia-related sanctions and expanded global reach. OFSI issued 19 general licences and processed 904 specific licensing decisions, while deepening international collaboration through its first Memorandum of Understanding with the US Treasury. Enforcement actions rose to 57, including penalties against firms like Herbert Smith Freehills LLP. OFSI also launched targeted advisories, sectoral threat assessments, and a combined e-alert service reaching 56,000 subscribers, all aimed at bolstering compliance and disrupting circumvention. As it nears its tenth anniversary, OFSI is refining its strategy to keep the UK’s sanctions regime agile, transparent, and globally coordinated.

UK Extends General Trade Licence for Russia Sanctions on Software and Technology

The UK government has extended the validity of its General Trade Licence covering sectoral software and technology under Russia sanctions, originally set to expire on 20th October 2025. This extension, announced by the Export Control Joint Unit, aims to ensure continuity for legitimate business operations while licensing processes are finalised. The licence, introduced following the 2025 amendment to The Russia (Sanctions) (EU Exit) Regulations, supports UK businesses navigating compliance challenges related to operations in Russia and Ukraine.

Fraud

FCA Urges Banks to Disrupt Romance Scams as Losses Top £106 Million

The Financial Conduct Authority (‘FCA’) has called on banks and payment firms to strengthen their defences against romance fraud, a growing crime which cost UK victims over £106 million in 2024–25. In its latest review, the FCA found both commendable efforts and critical gaps in how firms detect and respond to these scams, which often begin online and exploit emotional manipulation. Nearly half of victims concealed the true reason for payments, complicating intervention. The FCA recommends improved staff training, enhanced monitoring systems, and compassionate aftercare to help “break the spell” cast by fraudsters. The Report is here.

Money Laundering

ALCB Sets Gold Standard for Cross-Border Anti-Money Laundering Cooperation, Says Transparency France

A blog post from Transparency France spotlights the Anti-Money Laundering Contact Board (‘ALCB’) as a standout model of international cooperation in the fight against financial crime. It explores how the ALCB fosters real-time intelligence sharing, coordinated enforcement, and strategic partnerships across borders, particularly in complex cases involving shell companies and illicit financial flows. By showcasing operational successes and lessons learned, the post argues that the ALCB’s collaborative framework offers a blueprint for other jurisdictions seeking to strengthen their anti-money laundering regimes.

Eurojust Meeting Highlights Cross-Border Challenges in Money Laundering and Asset Recovery

Eurojust hosted its first annual Judicial Focus Group meeting on Money Laundering and Asset Recovery from 15–16 October 2025, bringing together international stakeholders to tackle emerging financial crime trends. Key discussions focused on the rise of crypto-assets, the use of professional laundering services disguised as legitimate businesses, and the complexities of tracing illicit funds across jurisdictions. The event showcased Eurojust’s pivotal role in coordinating multi-agency efforts and featured the launch of its Casework Report on Regulation 2018/1805, offering practical guidance on freezing and confiscation orders. Participants emphasised the need for enhanced judicial cooperation and technological innovation to counter evolving criminal tactics.

Market Abuse

ESMA’s 2024 Sanctions Report Reveals €100M in Fines and Cross-Member State Discrepancies

The European Securities and Markets Authority (‘ESMA’) has published its second consolidated report on sanctions imposed across EU Member States in 2024, revealing over 970 administrative actions and fines exceeding €100 million. Market Abuse and MiFID breaches accounted for the largest penalties, with settlements totalling more than €20 million. The report highlights significant disparities in sanctioning practices among Member States and emphasises that enforcement effectiveness cannot be judged solely by fine amounts. ESMA aims to use these insights to promote supervisory convergence and ensure consistent enforcement across the EU’s financial markets.

Other Financial Crime

Honduras Unveils National Strategy to Combat Organised Crime with UN and UK Support

Honduras has launched a comprehensive national strategy to tackle organised crime, developed in partnership with the United Nations Office on Drugs and Crime (‘UNODC’) and partially funded by the UK’s Integrated Security Fund. Using UNODC’s “Organised Crime Strategy Toolkit,” the initiative emphasises prevention, protection, prosecution, and institutional strengthening, while integrating gender and human rights considerations. The collaboration began after Honduras sought UNODC’s assistance at a 2022 regional meeting in Bangkok, marking a coordinated and sustainable commitment to fighting transnational crime in line with international conventions.

Cybercrime

Capita Fined £14m for Massive Data Breach Affecting 6.6 million People

The UK Information Commissioner’s Office (‘ICO’) has fined Capita £14m for a 2023 cyberattack which exposed sensitive data of 6.6 million individuals, including pension and criminal records. The breach stemmed from a malicious file downloaded onto an employee’s device, which remained unquarantined for 58 hours, allowing hackers to infiltrate Capita’s systems and exfiltrate nearly one terabyte of data. The ICO found systemic failures in Capita’s cybersecurity, including poor alert response, inadequate penetration testing, and lack of privilege controls. Capita accepted liability and agreed to a voluntary settlement, highlighting the critical need for robust data protection across large organisations.