Episode 200

7th November – 9th November 2025

Sanctions

UK Exporter Pays £1.1m Penalty for Breaching Russia Sanctions via Third-Country Dealings

In May 2025, HM Revenue & Customs secured a £1.16 million compound settlement from a UK exporter which breached The Russia (Sanctions)(EU Exit) Regulations 2019 by making goods available to Russia through third-country intermediaries. The case highlights the risk of indirect sanctions violations, especially when Russian-incorporated companies operate abroad. HMRC emphasised that ignorance of sanctions is no excuse and urged businesses to monitor updates, assess trading relationships, and seek legal advice to ensure compliance. The enforcement action underscores the broad scope of prohibitions on supplying goods to entities “connected with Russia,” even outside Russian territory.

UK Sanctions Agencies Announce Enforcement Actions to Boost Industry Compliance

The UK government has released a consolidated update on sanctions enforcement actions taken by key agencies including OFSI, HMRC, NCA, and OTSI, highlighting monetary penalties, prosecutions, and disclosure notices under various sanctions regimes. These include civil penalties for financial and trade sanctions breaches, criminal investigations into Russian money-laundering networks, and case studies illustrating indirect supply chain risks. Each enforcement notice and blogpost provides compliance lessons for industry stakeholders, reinforcing the importance of due diligence, regulatory awareness, and proportional application of sanctions rules.

UK Freezes Assets of New IRA and Suspected Terror Facilitator Kieran Gallagher

On 6th November 2025, the UK Government announced new sanctions under the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 against the New Irish Republican Army (New IRA) and Kieran Gallagher, suspected of facilitating terrorism. The measures include an asset freeze and director disqualification, prohibiting any financial dealings with Gallagher or the New IRA without Treasury authorisation. This marks the second use of the Treasury-led domestic counter-terrorism regime targeting Northern Ireland-related terrorism, reinforcing the UK’s commitment to the Good Friday Agreement and national security.

US Sanctions Hizballah Operatives Exploiting Lebanon’s Cash Economy

On 6th November 2025, the US Treasury’s Office of Foreign Assets Control sanctioned key Hizballah operatives who laundered tens of millions of dollars from Iran through Lebanon’s cash-based financial sector. The action targets individuals involved in covert oil sales, unlicensed money exchanges, and illicit business networks which fund Hizballah’s paramilitary and terrorist infrastructure. Following the collapse of Syria’s Assad regime and internal leadership changes, Hizballah’s financial operations have become increasingly reliant on exchange houses and front companies. The sanctions, issued under Executive Order 13224, aim to disrupt terror financing and reinforce Lebanon’s financial integrity.

Money Laundering

Germany Hits JPMorgan with Record €45m Fine Over Anti-Money Laundering Failures

Germany’s financial regulator BaFin has imposed a €45 million fine on JPMorgan’s Frankfurt subsidiary for failing promptly to report suspicious transactions between October 2021 and September 2022. The bank was found to have breached its supervisory obligations under the Money Laundering Act, delaying reports to the Financial Intelligence Unit which could have aided law enforcement. This penalty marks BaFin’s largest ever against a financial institution, surpassing the previous €40 million fine levied on Deutsche Bank in 2015, and reflects Germany’s intensified crackdown on financial crime following recent scandals and systemic lapses.

NetBet Fined £650,000 for AML Failures and Social Responsibility Breaches

NetBet Enterprises Limited has been ordered to pay £650,000 following a Gambling Commission investigation which uncovered serious anti-money laundering deficiencies, including over-reliance on financial triggers, inadequate risk assessments, and failure to flag high-risk gambling behaviours. The operator's systems allowed customers to spend disproportionately to their income and overlooked key risks such as third-party relationships and high-stakes play. The penalty also reflects shortcomings in social responsibility, with ineffective customer interaction processes and delayed identification of harm indicators. An independent audit has been mandated to ensure lasting improvements.

UK Consultation Seeks Views on FCA’s Duties, Powers, and Accountability in New AML/CTF Supervisory Role

Following the government’s decision to transfer anti-money laundering and counter-terrorist financing (‘AML/CTF’) supervision of professional services firms to the Financial Conduct Authority (‘FCA’), HM Treasury has launched a consultation focused on the duties, powers, and accountability mechanisms required to support this reform. The proposals aim to ensure the FCA can effectively oversee legal, accountancy, and trust and company service providers, with legislative changes planned to underpin its new responsibilities. Stakeholders are invited to respond to specific questions outlined in the consultation document by 24th December 2025.

UKFIU SARs Booklet Showcases £3M+ in Criminal Asset Disruption

The UK Financial Intelligence Unit (‘UKFIU’) has released its November 2025 SARs Reporter Booklet, spotlighting how Suspicious Activity Reports have enabled major law enforcement successes. Highlights include a money laundering probe resulting in an Account Freezing Order exceeding £2 million, fraud investigations yielding forfeitures of £800,000 and £450,000, and a romance fraud case recovering £25,000. The booklet also illustrates how UKFIU refusals of Defence Against Money Laundering requests have empowered action against money mule networks, VAT fraud schemes, and organised crime proceeds.

EU-ASEAN Workshop Updates FATF Standards to Combat Terrorism Financing

At a pivotal workshop in Bangkok, ASEAN financial and security experts joined EU representatives to advance implementation of the revised Financial Action Task Force (‘FATF’) Recommendation 8, which aims to prevent the misuse of non-profit organisations for terrorism financing while safeguarding civic space. The event, co-organised by Thailand’s NSC and AMLO with support from the EU’s ESIWA+ project, featured contributions from the EU Global Facility on AML-CFT and endorsed the development of a regionally tailored handbook to guide proportional and effective application of the standards. The workshop fostered cross-regional collaboration, practical strategy sharing, and reinforced ASEAN’s commitment to balancing security with civil society protections.

Other Financial Crime

UK Economic Crime Survey Measures Business Risk

The Home Office has published the Economic Crime Survey 2024, a landmark study conducted by Ipsos to assess UK businesses’ experiences with fraud, bribery, corruption, money laundering, and breaches of financial sanctions. Covering both quantitative data and qualitative interviews, the survey explores the scale, impact, and cost of economic crime, alongside businesses’ risk perceptions and preparedness. As the first comprehensive survey targeting all UK businesses with employees, it offers critical insights to inform policy, enforcement, and industry resilience against financial crime.

The Survey reveals that 27% of UK businesses with employees experienced fraud in the past year, amounting to an estimated 6.04 million incidents, most commonly fake invoice, mandate, and investment fraud. Medium and large firms, and those in information, communications, and utilities sectors, were disproportionately affected. Cyber-facilitated attacks, especially phishing, accounted for 40% of the most recent frauds. While 71% of affected businesses incurred financial or operational losses, only 32% reported incidents externally. The average cost per business was £2,090, with staff time being the most common expense. Despite this, two-thirds of all businesses had at least one fraud prevention measure in place, though preparedness varied widely by size and sector.