Episode 201

10th November – 13th November 2025

Sanctions

UN Security Council Delists Syrian Leaders, Signals Support for Post-Uprising Transition

In a landmark move, the UN Security Council adopted Resolution 2799 (2025), removing Syria’s transitional President Ahmed al-Sharaa and Interior Minister Anas Hasan Khattab from the ISIL and Al-Qaida sanctions list, following the country’s December 2024 uprising. With 14 votes in favour and one abstention (China), the resolution reflects broad international support for Syria’s political transition and economic recovery. Delegates hailed the decision as a “new era” for Syria, emphasising the importance of sovereignty, counterterrorism commitments, and inclusive rebuilding. Syria welcomed the resolution as a “badge of honour,” marking renewed global confidence in its leadership. The UK announced their removal from the UK Sanctions List, and that announcement is here.

UN Assembly Condemns Sanctions on ICC as Threat to Global Justice

The UN General Assembly has denounced recent sanctions imposed by the United States on International Criminal Court (‘ICC’) officials, calling them deliberate attacks on international law and judicial independence. These measures followed ICC arrest warrants for Israeli leaders over alleged war crimes in Gaza. Assembly President Annalena Baerbock emphasised the court’s role in combating impunity and urged member states to uphold its independence. ICC President Judge Tomoko Akane warned that threats and coercion undermine global justice, highlighting the court’s achievements and the vital role of victim reparations in places like Uganda.

US Suspends Caesar Act Sanctions to Support Post-Assad Syrian Recovery

On 10th November 2025, Secretary of State Marco Rubio announced the suspension of mandatory Caesar Act sanctions following the fall of the al-Assad regime, marking a pivotal shift in US policy toward Syria. This move, aligned with President Trump’s commitment to fostering peace and prosperity for the Syrian people, aims to facilitate economic rebuilding, reestablish international partnerships, and encourage a peaceful future. The suspension, enacted under Section 7432(b)(1) of the Caesar Syria Civilian Protection Act of 2019, is accompanied by a joint advisory from the Departments of State, Treasury, and Commerce outlining permissible activities under the new sanctions relief framework.

UK Supreme Court Ruling Spurs Debate on Sanctions Policy and Public Accountability

In a thought-provoking opinion piece on the RUSI website, Andrea Marchesetti reflects on the UK Supreme Court’s July 2025 decision upholding sanctions against British-American billionaire Eugene Shvidler and a super-yacht-owning company, framing it as a pivotal moment for UK sanctions policy. While the majority of justices endorsed the Foreign Office’s approach as lawful and proportionate, Lord Leggatt’s trenchant dissent raised critical concerns about arbitrary designations, the coercive use of sanctions to elicit speech, and the lack of transparent principles. Marchesetti argues that these tensions reveal both the global reach and domestic fragility of UK sanctions, urging greater public scrutiny, clearer policy frameworks, and a more robust theory of change to ensure legitimacy and effectiveness.

Final Reminder: Frozen Assets Reporting 2025

OFSI is currently undertaking its annual frozen assets review, requiring anyone holding or controlling funds or economic resources belonging to, owned, held, or controlled by a designated person to submit a report by Sunday, 30th November 2025. The report must provide details of all frozen assets in the UK and overseas which fall under UK financial sanctions legislation, including their value as of close of business on Tuesday, 30th September 2025. Where these assets involve shares, securities, or other debt or payment instruments, the GBP value must be specified. Even if you have previously reported frozen assets to OFSI, you are still obligated to submit a return for the 2025 Frozen Asset Review, including a nil return if assets reported in 2024 are no longer held. Reports must be completed using the updated template available on gov.uk and sent to ofsi@hmtreasury.gov.uk, ensuring the latest version of the template is used.

Fraud

FCA Warns of Clone Scam Impersonating Northern Trust Firms

On 10th November 2025, the UK Financial Conduct Authority (‘FCA’) issued a warning about fraudulent websites, in this instance northerntrustuk.com and northerntrustwealth.com, posing as authorised Northern Trust entities to deceive consumers. These clone firms are not FCA-authorised and have been using fake contact details to impersonate legitimate firms, potentially exposing victims to financial loss without access to the Financial Ombudsman Service or FSCS protection. The FCA urges the public to verify firms using its Firm Checker and report any suspicious approaches.

Money Laundering

MONEYVAL Flags Progress and Persistent Gaps in Anti-Money Laundering Efforts

MONEYVAL’s 2024 annual report highlights notable progress among its 33 member jurisdictions in aligning with international standards to combat money laundering, terrorism financing, and proliferation. While improvements were seen in international cooperation, beneficial ownership transparency, and financial institution supervision, the report identifies persistent weaknesses in areas such as investigations, prosecutions, asset confiscation, and oversight of non-financial professions. With 193 technical compliance upgrades and only nine downgrades, MONEYVAL launched its sixth evaluation round in 2024, marking a new phase in global efforts to strengthen legal and institutional frameworks amid evolving geopolitical and technological challenges.

MLB Pitchers Charged in Federal Sports Betting and Money Laundering Scheme

Federal prosecutors have charged Cleveland Guardians pitchers Emmanuel Clase de la Cruz and Luis Leandro Ortiz Ribera with wire fraud, bribery, and money laundering for allegedly rigging pitches to benefit corrupt sports bettors. The indictment reveals that Clase coordinated with gamblers from May 2023, manipulating pitch types and speeds to influence prop bets, while Ortiz joined the scheme in June 2025, throwing deliberately rigged pitches in exchange for bribes. The conspiracy led to at least $460,000 in fraudulent winnings, undermining the integrity of Major League Baseball and online betting platforms.

Bribery and Corruption

Six Former Glencore Executives Charged in West African Oil Bribery Case

The UK Serious Fraud Office has charged six former Glencore employees, namely Martin Wakefield, David Perez, Alex Beard, Andrew Gibson, Paul Hopkirk, and Ramon Labiaga, with conspiring to make corrupt payments linked to oil contracts in Cameroon, Nigeria, and Côte d’Ivoire between 2007 and 2014. Additional charges against Gibson, Wakefield, and Perez involve falsifying documents to disguise bribes as service fees to a Nigerian consultancy. All defendants have pleaded not guilty, and the trial is scheduled for 4 October 2027.

UNDP Paper Charts Digital Path to Clean, Accountable Energy Transitions

The UNDP’s November 2025 policy paper, Energy, Digital, and Anticorruption, outlines a practical “integrity-by-design” agenda for just energy transitions, emphasising how digital tools can mitigate corruption risks as systems evolve. It proposes embedding accountability across the energy value chain through AI-driven forecasting, real-time anomaly detection, open fiscal data, blockchain registries, and e-participation platforms. The paper also highlights the need to bridge AI capacity gaps in public institutions via regulatory sandboxes, algorithm audits, and skills development, positioning clean governance as a digital capability essential for transparency, trust, and investment readiness.

Other Financial Crime

Dinosaur Fossils and London Properties Forfeited in £20m Money Laundering Settlement

The UK’s National Crime Agency has recovered over £20 million in assets from Chinese national Binghai Su, including three dinosaur skeletons, nine London apartments, and Chinese artworks, as part of a settlement under an Unexplained Wealth Order. Su, linked to Singapore’s largest-ever money laundering case, was not charged but agreed to forfeit assets deemed criminal proceeds. The fossils, two Allosaurus and one Stegosaurus, were bought at auction for £12.4 million, and the NCA will retain 75% of the sale proceeds, marking a rare but symbolic use of the Proceeds of Crime Act.

EU Reaffirms Commitment to Ending Impunity for Crimes Against Journalists

On the 11th International Day to End Impunity for Crimes against Journalists, the European Union voiced deep concern over escalating threats to media freedom, including harassment, surveillance, and gender-based violence targeting journalists. It highlighted 2025 developments such as the European Media Freedom Act and the Anti-SLAPP Directive, which bolster protections for journalists and combat abusive legal tactics. The EU also endorsed initiatives like the “Journalists Matter” campaign and Ukraine’s wartime protection roadmap, urging all Member States to ensure justice and uphold democratic accountability.

Council of Europe Launches Anti-SLAPP Training to Safeguard Journalists and Free Expression

On 10th November 2025, the Council of Europe unveiled a new training programme aimed at countering Strategic Lawsuits Against Public Participation (SLAPPs), reinforcing its commitment to protecting journalists and defending freedom of expression. Tailored for legal professionals, including judges, prosecutors, and lawyers, the course equips participants to identify and address SLAPPs in line with European standards, drawing on frameworks like Recommendation CM/Rec(2024)2 and EU Directive 2024/1069. Developed under the EU-Council of Europe Horizontal Facility for the Western Balkans and Türkiye, the programme has already gained traction through regional initiatives and major conferences. Materials are freely available and adaptable, with guidance to ensure quality and impact.

Europol Strikes Against Cyber Financial Crime by Disrupting Massive Phishing-as-a-Service Networks

Europol is aggressively targeting online fraud schemes, which are considered a key threat and represent one of the most rapidly expanding sectors in organised crime. The entire criminal ecosystem, including online fraud and ransomware, is powered by the central theme of the abuse and exploitation of data. These schemes are highly sophisticated and challenging to detect, fuelled by the theft of personal data from payment systems which is then exploited or sold, often leading to repeated victimisation. This well-organised criminal industry leverages the "crime-as-a-service" economy, providing professional services, selling stolen data on dark web forums, and exploiting human oversight through pervasive social engineering techniques and tools like Infostealers and Vishing. A major blow to this infrastructure was delivered when Europol played a key role in disrupting LabHost, identified as one of the world's largest phishing-as-a-service platforms. This platform offered criminals monthly subscriptions for customisable phishing kits and infrastructure, specifically targeting entities like financial institutions. The resulting operation in April 2024 led to the arrest of 37 suspects worldwide and the uncovering of 40,000 phishing domains. Furthermore, Europol tackles the financial impact of malware through operations like “Endgame,” dedicated to disrupting botnets used in the ransomware kill chain, which recently saw the neutralisation of 300 servers and 650 domains.

£5 Billion Bitcoin Seizure Leads to Jail Terms in Landmark UK Fraud Case

Following a seven-year investigation, two individuals have been jailed, Zhimin Qian and Seng Hok Ling, for their roles in a multibillion-pound cryptocurrency fraud involving over 128,000 victims. Qian, who orchestrated the scheme in China and laundered proceeds through Bitcoin, received nearly 12 years in prison, while Ling was sentenced to almost five years. The Met recovered over 61,000 Bitcoin, with a value of around £5 billion, in the world’s largest confirmed crypto seizure. Authorities emphasised the growing use of digital currencies in organised crime and reaffirmed their commitment to tracing illicit assets and securing justice. The CPS press release is here.

FCA Review Reveals Gaps and Good Practice in Firms’ Financial Crime Risk Assessments

The FCA’s 2025 multi-firm review of business-wide and customer risk assessment processes found that while most firms had frameworks in place, many lacked tailored, data-driven approaches and clear documentation of risk mitigation and oversight. Good practice included integrated, weighted assessments and senior management engagement, but weaknesses were noted in scalability, record-keeping, and dynamic risk management. The FCA urges firms to align with regulatory expectations, ensure robust controls, and address identified shortcomings to strengthen financial crime defences.

Cyber Crime

UK Government Research Reveals £14.7 Billion Annual Cost of Cyber Attacks

Independent research commissioned by the UK government highlights the escalating economic impact of cyber-attacks, estimating an annual cost of £14.7 billion to UK businesses, with intellectual property theft alone costing up to £8.5 billion in 2024. The findings underscore widespread vulnerabilities across sectors, including healthcare, finance, and transport, with systemic incidents, such as a hypothetical rail network disruption, potentially costing £1.8 billion per week. The government is responding with new legislation, enhanced guidance, and strategic investment in cyber resilience and skills to safeguard national security and economic stability.

Opinion: Why Human Error and Process Failures Deserve Equal Attention in Data Breach Risk

In an opinion piece on the Slaughter and May website, the authors argue that while cyberattacks dominate headlines, the majority of data breaches reported to the UK Information Commissioner’s Office stem from non-cyber causes, primarily human error and flawed processes. Drawing on recent case law, regulatory guidance, and enforcement actions, the article highlights recurring pitfalls such as misdirected communications, outdated address data, accidental oversharing, and misfiled documents. It urges organisations to strengthen day-to-day data governance, implement practical safeguards, and not overlook the tangible risks posed by internal failures, especially as AI adoption amplifies the consequences of basic mistakes.