Episode 195

20th October – 23rd October 2025

Sanctions

US Sanctions Haitian Gang Leaders Backing Terrorist Group Viv Ansanm

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has sanctioned Dimitri Herard and Kempes Sanon for materially supporting Viv Ansanm, a violent Haitian gang alliance designated as a global terrorist organisation. Herard, a former police officer linked to the 2021 assassination of President Jovenel Moïse, allegedly provided training and weapons to gang leaders after escaping prison in 2024. Sanon, leader of the Bel Air gang, is accused of orchestrating civilian killings, extortion, and kidnappings. The sanctions block their US-linked assets and prohibit transactions with them, reinforcing US efforts to curb terrorism and restore stability in Haiti.

UK Freezes Assets of Haitian Gang Leaders Amid Escalating Violence and Political Threats

The UK government has also issued sanctions in this matter. It has updated its Sanctions List to include Dimitri Herard and Kempes Sanon, imposing asset freezes under the Haiti (Sanctions) Regulations 2022. Herard, a former police chief implicated in the assassination of President Jovenel Moïse and linked to violent gangs and arms trafficking, is accused of orchestrating attacks against Haitian state institutions. Sanon, leader of the Les Argentins gang, is charged with human rights abuses, extortion, and aiding the Viv Ansanm alliance’s violent campaign to seize control of Port-au-Prince. Both men are fugitives wanted by Haitian authorities and have been designated by multiple international bodies for undermining Haiti’s peace and stability. The OFSI Notice is here.

UK Treasury Imposes Asset Freezes on 12 Individuals and Entity Alpa Trading Fzco Under Global Irregular Migration and Trafficking Sanctions

On 22nd October 2025, HM Treasury's Office of Financial Sanctions Implementation (‘OFSI’) issued a notice adding twelve individuals, including members of the "Krasniqi network," Ali Derakhshan, Vahid Derakhshan, Nusret Seferovic, and the entity Alpa Trading Fzco to the Consolidated List under the Global Irregular Migration and Trafficking in Persons (Sanctions) Regulations 2025. These parties are now subject to asset freezes due to involvement in people smuggling and facilitating unlawful migration, such as document forgery and supplying equipment for Channel crossings. Relevant parties must identify and freeze any assets connected to these individuals or entities, reporting findings to OFSI.

OFSI Grants General Licence

The Office of Financial Sanctions Implementation (‘OFSI’) of HM Treasury issued General Licence INT/2025/7598960 on 22nd October 2025, granting exemptions under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 ("the Russia Regulations"). The licence serves to exempt any act which would otherwise breach the prohibitions outlined in Regulations 11 through 17 and 18C of the Russia Regulations. Specifically, this General Licence permits a "Person" (defined as an individual or body not classified as a UK Designated Person, or UK DP) to continue business operations involving the "Named Subsidiaries" of PJSC Rosneft Oil Company: Rosneft Deutschland GmbH and RN Refining & Marketing GmbH, and any entities they own or control. These permitted operations include making or receiving payments under any existing or new obligations or contracts, as well as the provision and receipt of economic resources from the Named Subsidiaries; furthermore, a Relevant UK Institution may process these authorised payments. This measure takes immediate effect on 22nd October 2025 and is scheduled to expire at 23:59 on 22nd October 2027.

UK General License Sets Financial and Hourly Limits for Legal Services Provided to Sanctioned Individuals

General Licence INT/2025/7323088, valid from 29th October 2025 to 28th April 2026, exempts certain payments for Legal Services from UK Autonomous Sanctions Regulations. Designated Persons can pay professional legal fees, Counsel’s fees, and expenses, excluding defamation or malicious falsehood claims, but cannot receive funds or economic resources via this licence. The permission is split into Part A (for obligations before designation) and Part B (after designation), each with a fee cap of £2 million per provider and expense limits up to 10% of fees or prescribed maximums. If both parts apply together, the combined caps increase. Hourly rates are capped under Part B, with detailed limits for Counsel and solicitors. Users must report specific documents to HM Treasury within 14 days and retain records for at least six years.

Fraud

“Operation Silver Shores” Dismantles $30M Transnational Fraud Ring Targeting Elderly Americans

In a sweeping crackdown dubbed “Operation Silver Shores,” US authorities arrested 15 individuals across California, Texas, and Florida for orchestrating a $30 million telemarketing fraud scheme which preyed on elderly timeshare owners. The transnational criminal network posed as attorneys and officials, duping victims into paying bogus legal fees for fictitious settlements. Funds were laundered through shell companies and fintech platforms, exploiting weak anti-money laundering controls. With over 372 victims identified and ties to gang affiliates like the Norteños, the operation marks a major victory in combating financial crimes against vulnerable populations.

Money Laundering

Switzerland Launches Landmark Transparency Overhaul to Combat Money Laundering

On 15th October 2025, the Swiss Federal Council initiated a pivotal consultation on new ordinances aimed at strengthening anti-money laundering (‘AML’) measures and increasing corporate transparency. Central to the reform is the creation of a federal register of beneficial owners, enabling authorities and AML-regulated entities swiftly to access verified ownership data. The ordinances also extend AML obligations to consultancy services, particularly those linked to real estate and legal entity structuring, long seen as loopholes for illicit finance. This marks Switzerland’s most significant AML update in over a decade, aligning its framework with international standards and preparing for the next Financial Action Task Force evaluation.

HM Treasury Confirms FCA as Single Professional Services Supervisor to Consolidate UK Anti-Money Laundering Compliance

HM Treasury published its response in October 2025 to a 2023 consultation, announcing a fundamental reform of the UK’s Anti-Money Laundering and Counter-Terrorism Financing (‘AML/CTF’) supervision regime. Recognising that the existing system, which relies on 22 private Professional Body Supervisors alongside statutory public supervisors, is complex, disjointed, and suffers from inconsistencies, the Government decided to adopt the Single Professional Services Supervisor model. Under this structural change, the Financial Conduct Authority will assume responsibility for AML/CTF supervision for Legal Service Providers, Accountancy Service Providers, and Trust and Company Service Providers, consolidating the oversight currently spread across 23 different bodies. This policy aims to strengthen the UK’s defences against illicit finance, simplify the regulatory landscape, and improve coordination with law enforcement by integrating these professional services into the FCA’s existing public sector supervisory framework. The FCA announcement is here.

Bribery and Corruption

OECD Launches Phase 4 Review of Latvia’s Anti-Bribery Efforts

The OECD Working Group on Bribery has initiated Phase 4 of its peer review process to evaluate Latvia’s implementation of the OECD Anti-Bribery Convention. This phase focuses on enforcement, corporate liability, international cooperation, and unresolved issues from prior assessments. The OECD invites written submissions from civil society and the private sector by 28 November 2025, and expressions of interest to join an on-site visit in Riga from 26–30 January 2026. Findings will be discussed in June 2026, aiming to strengthen Latvia’s commitment to combating foreign bribery.

Cross-Border Law Enforcement Collaboration Breaks New Ground in Anti-Corruption Fight

A landmark corruption case involving a French company fined €18.3 million showcases the power of proactive international law enforcement cooperation. Authorities from Ukraine, Estonia, and France formed a joint investigative team, coordinated through Eurojust and OECD’s Global Law Enforcement Network (‘GLEN’), to dismantle a complex bribery and money laundering scheme. The French firm entered a judicial agreement, including €3.37 million in compensation to Ukraine and a three-year compliance programme. Innovative use of plea deals and peer learning platforms further accelerated progress, setting a precedent for practitioner-led, cross-border anti-corruption strategies.

Other Financial Crime

FCA Flags Weak Financial Crime Controls Across UK Corporate Finance Sector

A recent Financial Conduct Authority (‘FCA’) survey revealed widespread gaps in financial crime oversight among UK corporate finance firms, with two-thirds potentially falling short of anti-money laundering regulations. Key deficiencies included 11% lacking a documented business-wide risk assessment, 10% failing to retain customer due diligence records, and 29% of principal firms neglecting risk assessments for their appointed representatives. The FCA also found that 6% of principals weren’t monitoring compliance or conducting audits. While some firms demonstrated good practices, such as updating risk frameworks and reporting concerns to senior management, the regulator warned that many firms remain vulnerable and must urgently strengthen controls. This review forms part of the FCA’s broader five-year strategy to combat financial crime and raise sector standards.

Pacific Nations Unite to Combat Financial Crime with AUSTRAC-Led Intelligence Push

AUSTRAC and 15 Pacific financial intelligence units have increased their joint efforts to tackle emerging financial crime threats, focusing on child sexual exploitation, transnational organised crime, and cryptocurrency abuse. Through the Pacific Financial Intelligence Community (‘PFIC’), members are sharing technology, training, and intelligence, including the TAIPAN system and new operational guides, to trace illicit financial flows and strengthen frontline detection. The initiative includes multilateral investigations, scenario-based training, and a regional plenary in Fiji, underscoring the strategic importance of cross-border collaboration in safeguarding vulnerable communities and financial systems.

Cybercrime

SIMCARTEL Cybercrime Network Dismantled in Major Europol Operation

Europol has announced a coordinated, Europol-led, operation across Latvia, Austria, and Estonia which has dismantled a sophisticated cybercrime-as-a-service network known as SIMCARTEL. Seven suspects were arrested and infrastructure seized, including 1,200 SIM boxes, 40,000 active SIM cards, and five servers. The network enabled over 3,200 fraud cases across Europe, with losses exceeding €4.9 million. Criminals used rented phone numbers from 80+ countries to mask identities and commit phishing, smishing, extortion, and child exploitation. Europol and Eurojust coordinated forensic, financial, and technical support, freezing assets and taking down websites used for the illicit service.

AWS Outage Sparks Global Disruption and Renewed Warnings Over Cloud Dependency

A major outage at Amazon Web Services (‘AWS’) on 20th October 2025 disrupted thousands of websites and apps worldwide, including Snapchat, Fortnite, Duolingo, and UK banking services, due to a technical fault in its US-East-1 region, later traced to a DNS issue and internal monitoring subsystem failure. The incident triggered over eight million user reports globally and reignited expert concerns about the internet’s over-reliance on a handful of cloud providers. While Amazon restored most services within hours, cybersecurity experts warned of heightened phishing risks during recovery, and UK lawmakers questioned the wisdom of entrusting critical infrastructure to US tech giants.

Cyber Security Urged as Board-Level Priority for UK Businesses

The UK’s National Cyber Security Centre (‘NCSC’), alongside Ministers and the National Crime Agency, has issued a stark call to FTSE 350 companies and other major firms: treat cyber resilience as a matter of business survival. With cyber incidents up 50% and high-profile disruptions mounting, the NCSC urges leaders to act now, not after a breach has occurred. Their letter outlines three immediate steps: elevate cyber risk to board-level governance, enrol in the NCSC’s Early Warning service, and mandate Cyber Essentials across supply chains. The message is clear: proactive collaboration between government and industry is vital to safeguarding economic stability and public trust. This is a story which we covered a couple of weeks ago, and now the NCSC has acted.