Episode 204

21st November – 23rd November 2025

Sanctions

OFSI Expands Lukoil Bulgaria Licence to Cover Aviation and Bunker Subsidiaries

On 20th November 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) amended General Licence INT/2025/7895596 to expand its scope, now covering Lukoil Aviation Bulgaria EOOD and Lukoil Bunker Bulgaria EOOD. The licence permits certain business activities with these subsidiaries, but anyone intending to rely on it must review the official licence document to understand the precise definitions, permissions, and compliance requirements. FAQ 173 has been amended to reflect this update.

Treasury Expands Sanctions on Iran’s Oil Network Supporting Military and Terrorist Proxies

On 20th November 2025, the US Department of the Treasury’s Office of Foreign Assets Control imposed new sanctions targeting Iran’s shadow fleet of oil tankers, front companies, and intermediaries which finance the Iranian armed forces through crude oil sales. Following Iran’s defeat in the 12-Day War with Israel, its military has increasingly relied on oil revenues to rebuild depleted forces. The measures designate shipping firms, vessel operators, and financial facilitators across the UAE, Panama, Greece, India, Germany, and other jurisdictions, as well as Mahan Air and its subsidiary Yazd Airways for aiding the IRGC-QF in supplying terrorist groups. These actions, taken under Executive Orders 13224 and 13902, reinforce the Trump Administration’s maximum pressure campaign to disrupt Iran’s funding for nuclear weapons development and regional proxies. The State Department press release is here.

Europe Cracks Down on Criminal Networks Evading Russia Sanctions

Europol has intensified its efforts to help EU Member States enforce sanctions linked to Russia’s war against Ukraine, as criminal networks develop increasingly sophisticated methods to bypass restrictions. A new Target Group Sanctions team within Europol’s Financial and Economic Crime Centre is supporting investigations by tracing illicit trade routes, financial flows, and related crimes such as money laundering and customs fraud. In parallel, Europol and the European Anti-Fraud Office have launched Project Transporter to address suspicious vehicle exports to third countries which may be diverted to Russia or Belarus, often using forged documents and complex routes. These initiatives, part of the EMPACT cycle, aim to strengthen intelligence sharing, operational coordination, and cross-border cooperation against sanctions evasion.

Fraud

UK’s Confirmation of Payee and Reimbursement Rules Strengthen Fraud Prevention and Inspire Global Adoption

The Payment Systems Regulator (‘PSR’) marked International Fraud Awareness Week by highlighting the success of the Confirmation of Payee (‘CoP’) service with the publication of the APP Fraud Survey Report for 2025. Introduced in 2019, CoP now covers over 99% of Faster Payments and is offered by more than 320 organisations. With over two million checks completed daily, the service has become a routine safeguard against misdirected payments and fraud, giving UK consumers greater confidence in their transactions.

The UK’s approach has attracted international attention, with countries such as Australia and members of the EU developing similar systems to strengthen consumer protection. CoP has been a cornerstone of the PSR’s strategy to combat Authorised Push Payment (‘APP’) scams, and its effectiveness has inspired global adoption.

In October 2024, the PSR introduced a mandatory APP reimbursement requirement, ensuring victims of scams are compensated. Within the first nine months, £112 million was reimbursed, with most claims resolved quickly. This policy has not only reduced fraud losses but also improved consumer trust with half of reimbursed victims reporting greater confidence in their banks, while many consumers have adopted additional security measures.

The PSR also emphasised practical fraud‑prevention advice: verifying contacts, avoiding pressure tactics, and using the “Stop Scams 159” phone initiative. Looking ahead, the regulator has commissioned an independent evaluation of APP fraud policies to ensure continued improvement in consumer protection and resilience against evolving threats.

SFO Launches First Major Cryptocurrency Fraud Investigation into $28 Million Basis Markets Scheme

The UK Serious Fraud Office (‘SFO’) has opened its first major cryptocurrency fraud investigation into the collapse of Basis Markets, a scheme which raised $28 million through NFT sales and a crypto hedge fund in late 2021. Following two raids in London and West Yorkshire, police arrested two men on suspicion of fraud and money laundering. The SFO is urging investors to come forward with information, stressing its growing expertise in tackling crypto-related crime. Officials highlighted the broader harm of fraud to communities and business confidence, pledging strong support for consumer protection and enforcement.

Fourth Person Charged in $71 Million Defence Contract Fraud Investigation

The Australian Federal Police (‘AFP’) have charged a fourth individual, namely a 45-year-old Darwin woman and company director, for her alleged role in a multi-million dollar fraud involving Defence contracts worth nearly $71 million. The charges follow an AFP-led joint investigation, Operation Panton Hill, which began in March 2025 after irregularities were identified in Defence’s contract awarding process. The woman, who is not a Defence employee, is accused of conspiring with a Commonwealth employee, his spouse, and another company director to dishonestly gain benefits from the Department of Defence. She faces one count under section 135.1(1) of the Criminal Code, carrying a maximum penalty of 10 years’ imprisonment, and is expected to appear in Darwin Local Court on 21st November 2025.

Money Laundering

NCA Exposes Billion-Dollar Russian Money Laundering Network in Operation Destabilise

The UK’s National Crime Agency (‘NCA’) has uncovered a billion-dollar money laundering network which purchased a Kyrgyz bank to evade sanctions and fund Russia’s war effort. Through Operation Destabilise, the NCA identified launderers operating in at least 28 UK towns and cities, converting criminal cash from drugs, firearms, and immigration crime into cryptocurrency. The investigation has led to 128 arrests and the seizure of over £25 million in cash and crypto in the UK, alongside international seizures worth tens of millions. Two networks, Smart and TGR, were exposed, with leaders Ekaterina Zhdanova and George Rossi sanctioned by the US and UK after using companies like Altair Holding SA and Keremet Bank to facilitate payments for Russian state-owned Promsvyazbank. The operation has significantly restricted these networks’ access to Western financial systems and highlighted the link between local crime, global organised networks, and state-sponsored activity.

Bribery and Corruption

Local Leaders Take Frontline Role in Europe’s Fight Against Corruption

At a joint event in Strasbourg on 20th November 2025, the Council of Europe’s Congress of Local and Regional Authorities and GRECO highlighted the crucial role of local elected representatives in combating corruption. Congress Secretary General Mathieu Mori stressed that corruption undermines democratic trust, while local officials often face direct threats from organised crime and intimidation when defending integrity. The event, part of GRECO’s sixth evaluation cycle, showcased resilience and commitment to transparency, accountability, and ethical governance at the sub-national level, with examples such as Congress Spokesperson Danela Arsovska’s assaults during anti-corruption inspections in Skopje. Delegates from Germany, North Macedonia, Ireland, Malta, Spain, and Austria contributed to discussions on strengthening democratic safeguards and consolidating integrity across Europe.

Other Financial Crime

FCA Arrests Three in West Midlands Over Suspected Unauthorised Debt Activities

The Financial Conduct Authority (‘FCA’), with support from the National Crime Agency, has arrested three individuals in the West Midlands as part of an investigation into suspected unauthorised debt activities targeting vulnerable people facing repossession. Searches were carried out at two homes, an office, and a storage facility, with the suspects interviewed under caution and released on conditional bail. The FCA stressed that carrying out regulated debt services without authorisation is a criminal offence under the Financial Services and Markets Act 2000, urging consumers to be cautious of firms offering debt help without FCA approval.

Europol-Led Operation Dismantles Major Balkan Art Trafficking Network

On 19th November 2025, Bulgarian authorities, supported by Europol and judicial partners across Europe, dismantled a criminal network trafficking cultural goods looted from the Balkans. The coordinated action involved 131 searches across seven countries, leading to 35 arrests and the seizure of over 3,000 antiquities, including coins, jewellery, masks, and military artifacts, valued at more than €100 million. Investigators traced the network to a high-value target financing illegal excavations, with looted items laundered through international auction houses. The operation highlights the vulnerability of the art market to exploitation and underscores the importance of cross-border cooperation in protecting cultural heritage.

OSCE Strengthens Turkmenistan’s Capacity to Investigate and Recover Virtual Assets

The OSCE held a two-day workshop in Ashgabat on 12–13 November 2025, bringing together 26 representatives from financial authorities, law enforcement, and banks to enhance Turkmenistan’s ability to investigate and recover assets linked to cryptocurrencies and blockchain-based finance. As part of its extrabudgetary project Innovative Policy Solutions to Mitigate Money-Laundering Risks of Virtual Assets, the training focused on applying FATF Recommendations 15 and 16, using blockchain analytics to trace illicit transactions, identifying virtual asset service providers, and integrating blockchain evidence into criminal proceedings. The event emphasised inter-agency and international cooperation, with financial support from Germany, Italy, Poland, Romania, the UK, and the US.