Episode 196

24th October – 26th October 2025

Sanctions

US Sanctions Russia’s Oil Giants Rosneft and Lukoil to Choke War Financing

In a sweeping escalation of economic pressure, the US Treasury has sanctioned Rosneft and Lukoil, Russia’s two largest oil companies, along with dozens of subsidiaries, citing their role in funding the Kremlin’s war machine amid continued aggression in Ukraine. The sanctions, issued under Executive Order 14024, block all US-linked assets and prohibit transactions involving these entities, with secondary sanctions looming for foreign financial institutions which facilitate related dealings. Treasury Secretary Scott Bessent emphasised the move as part of President Trump’s push for an immediate ceasefire, warning that further action may follow if Moscow refuses to negotiate in good faith. New and Amended Russia-related General Licences have been issued as a consequence of the action.

UK Sanctions Balkan Crime Networks Fuelling People-Smuggling Trade

The UK government has imposed sanctions on Balkan-based criminal gangs and illicit financiers accused of enabling illegal migration through the Western Balkans. Announced during the Western Balkans Summit in London, the measures target the Krasniqi forgery network in Kosovo, a Croatian passport fraud ring, and the ALPA financial network supplying small boat components. Sanctioned individuals face asset freezes and travel bans under the UK’s Global Irregular Migration Sanctions Regime. Prime Minister Sir Keir Starmer emphasised the crackdown as part of a broader strategy to dismantle smuggling routes and enhance border security through international cooperation.

UK Updates Russia Sanctions List, Maintaining Asset Freezes and Trust Service Restrictions on Designated Persons

On 23rd October 2025, the Office of Financial Sanctions Implementation (‘OFSI’) updated the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019. Several individuals and one entity, including Aleksandr Aleksandrovich Shulgin, Mihajlo Perencevic, Alisher Burkhanovich Usmanov, Narmina Dadashova, and USM Holdings Limited, remain subject to asset freezes and trust service sanctions. All UK persons must identify and freeze any assets linked to these designated parties, and refrain from engaging with their funds or providing trust services unless authorised by OFSI or permitted by exception.

UK General Licence Grants Temporary Sanctions Exemptions for Operations of Listed Iranian Entities

The Interim Necessities General Licence (INT/2025/7628424), issued under Regulation 40 of The Iran Nuclear Regulations, exempts certain activities for specified subsidiaries, namely Bank Melli, Bank Saderat Iran, Bank Tejarat, Persia International Bank plc, and Iran Insurance Company. It allows these entities and their representatives to make payments for operating expenses in the UK, including salaries, redundancy payments, pensions, IT and accountancy services, provided payments are made only to relevant UK accounts, not to Designated Persons. Entities must report all payments to HM Treasury within 14 days after each month and keep records for at least six years. The licence is valid from 23rd October 2025 until 22nd April 2026.

Fraud

Greece Arrests 37 in €19.6m EU Farm Subsidy and Money Laundering Scandal

In a sweeping operation led by the European Public Prosecutor’s Office (‘EPPO’), Greek authorities arrested 37 individuals linked to an organised criminal group accused of orchestrating a large-scale agricultural subsidy fraud and money laundering scheme. Since at least 2018, the group allegedly exploited loopholes in the EU’s Common Agricultural Policy by submitting falsified applications for land and livestock subsidies, despite many having no real ties to farming. The illicit proceeds, estimated to have cost the EU over €19.6 million, were laundered through fictitious invoices, layered bank transfers, and luxury purchases. The scandal has triggered asset freezes and intensified scrutiny of Greece’s subsidy oversight mechanisms.

Money Laundering

EBA Finds AML/CFT Colleges Effective but Still Fragmented Ahead of AMLA Transition

The European Banking Authority has announced its final report on AML/CFT colleges reveals that while these supervisory structures have improved information exchange and oversight across EU jurisdictions, they still fall short of coordinating responses to shared money laundering and terrorism financing risks. Key shortcomings include inconsistent application of risk-based approaches and limited progress in fostering joint action among authorities. As responsibility shifts to the new Anti-Money Laundering Authority (AMLA) in January 2026, the EBA’s findings will shape the next phase of EU-wide AML/CFT supervision.

Platinum Gaming Fined £10m for Major AML Failures and Repeat Breaches

Platinum Gaming Limited has been fined £10m by the UK Gambling Commission for serious anti-money laundering (‘AML’) failures, including allowing previously blocked customers, flagged for money laundering or terrorist financing concerns, to reopen accounts and gamble. The operator’s AML risk assessment failed to account for these high-risk individuals, and its policy lacked clarity on due diligence thresholds. Despite identifying high-risk factors like large transactions and high-loss behaviour, customer reviews did not consistently apply enhanced scrutiny. This marks Platinum Gaming’s second enforcement action, following a £2.9 million fine in 2023. The decision also concerned its corporate social responsibility failings.

FINTRAC Fines Cryptomus $177m for Systemic AML Failures

In a landmark enforcement action, FINTRAC has fined Xeltox Enterprises Ltd, operating as Cryptomus, a record $176.96 million for egregious breaches of Canada’s anti-money laundering laws. The crypto firm failed to report over 1,000 suspicious transactions and more than 1,500 large virtual currency receipts during July 2024, many tied to child sexual abuse material, fraud, ransomware, and sanctions evasion. It also ignored ministerial directives and lacked basic compliance policies, exposing deep vulnerabilities in Canada’s fast-growing virtual currency sector. FINTRAC’s CEO called the action “unprecedented,” underscoring the urgent need for robust AML frameworks to protect Canadians and the financial system. The Notice is here.

OSCE Launches Virtual Asset AML Training in Turkmenistan to Boost Regulatory Readiness

In a two-day workshop held in Ashgabat on 21–22 October 2025, the OSCE launched a targeted training series to help Turkmenistan combat money laundering risks linked to virtual assets and blockchain-based finance. The event brought together 27 regulators, prosecutors, bank representatives, and investigators to align national practices with FATF Recommendations 15 and 16. Participants engaged in practical exercises on licensing Virtual Asset Service Providers, drafting legislation, and managing crypto-related investigations. With follow-up sessions planned for November, the initiative, funded by six OSCE member states, aims to strengthen institutional coordination and legislative reform amid rising crypto crime typologies.

Bribery and Corruption

Uzbekistan’s Anti-Corruption Forum Spotlights Whistleblower Law, Regional Integrity Models, and Open Data Reform

At the Fifth Tashkent Anti-Corruption Forum held on 22–23 October 2025, Uzbekistan’s Anti-Corruption Agency convened government officials, civil society, and international partners to advance integrity reforms. The event featured thematic discussions on a draft whistleblower protection law, civil society training to monitor public spending, and the rollout of the “Islands of Integrity” methodology in three regions. Experts from the EU, OECD, OSCE, and Transparency International shared best practices, while open data specialists emphasised transparency as a cornerstone of anti-corruption strategy. The forum’s theme, “From Discussions to Real Change”, underscored Uzbekistan’s commitment to embedding global standards into local governance.

Market Abuse

FCA Bans Advisor and Imposes £100K Fine for Insider Dealing

The Financial Conduct Authority (‘FCA’) has fined Neil Sedgwick Dwane £100,281 and banned him from UK financial services for insider dealing. As an advisor at ITM Power Plc in 2022, Dwane exploited confidential information about an impending market announcement to sell 125,000 shares before a 37% price drop, then repurchased 180,000 shares at a lower price, profiting £26,575. The FCA condemned his actions as a breach of trust and market integrity, emphasising its commitment to tackling financial crime through robust enforcement.

Other Financial Crime

FCA Chief’s City Dinner Speech Calls for Finance to Anchor UK’s National Security Strategy

In a keynote speech delivered at the Corporation of the City of London’s annual City Dinner, FCA Chief Executive Nikhil Rathi argued that Britain must “hardwire finance into national security,” warning that the financial system is now as critical to defence as traditional military infrastructure. He highlighted vulnerabilities in underinsured civilian assets, undercapitalised resilience technologies, and fragmented investment signals, urging industry leaders to co-invest in dual-use capabilities and close protection gaps. Rathi proposed a national resilience fund, clarified that FCA rules do not block defence investment, and called for faster procurement cycles to align capital with mission. This, he contends, underscores finance’s role in delivering the “triple dividend” of security, growth, and market integrity.

Cybercrime

Jaguar Land Rover Cyberattack Triggers £1.9bn Economic Shock, Exposes UK Supply Chain Fragility

The cyberattack which crippled Jaguar Land Rover’s operations from late August to early October 2025 has been confirmed as the most financially damaging in UK history, with estimated losses of £1.9bn rippling through over 5,000 businesses. The breach halted production for five weeks, disrupted global supply chains, and prompted a £1.5 billion government-backed loan guarantee to prevent supplier collapse. Experts suspect Russian state-linked actors orchestrated the attack, highlighting how a single corporate target can trigger systemic economic fallout. Cyber resilience experts now urge mandatory audits and stronger public-private coordination to defend critical infrastructure.