Episode 205

24th November – 27th November 2025

Sanctions

UK Updates Cyber Sanctions List: Asset Freeze on Andrei Valerevich Kozlov

On 24th November 2025, the UK Foreign, Commonwealth and Development Office updated the Cyber (Sanctions) (EU Exit) Regulations 2020, confirming that Russian national Andrei Valerevich Kozlov remains subject to an asset freeze. Kozlov, identified as an employee of Media Land LLC, is considered a key enabler of the cybercrime ecosystem, having been involved in supplying goods, technology, or financial services which contribute to malicious cyber activity. The Notice reminds institutions to freeze relevant accounts, refrain from dealing with designated persons without a license, and report findings to the Office of Financial Sanctions Implementation. It also warns that facilitating ransomware payments to sanctioned individuals may result in civil or criminal penalties. The Notice is here.

OFAC Fines Real Estate Investor $4.7 Million for Sanctions Violations

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has published an enforcement report announcing a $4.7 million penalty against a Georgia-based real estate investor for illegally dealing in property owned by a sanctioned Russian individual. The report details how the investor, acting through King Holdings LLC, purchased, renovated, and sold the blocked property despite a cease‑and‑desist order and subpoena, violating US sanctions regulations. OFAC emphasised that the penalty, which is the statutory maximum, highlights the obligation of all US persons to comply with sanctions laws and highlights Treasury’s commitment to holding violators accountable.

Money Laundering

Videoslots Fined £650,000 for AML and Safer Gambling Failures

The UK Gambling Commission has fined Videoslots Limited £650,000 after uncovering serious anti-money laundering and social responsibility failings across its platforms, including videoslots.co.uk, mrvegas.com, and megariches.com. The investigation revealed ineffective deposit limits which allowed customers to lose thousands beyond set thresholds, inadequate monitoring of high-risk activity such as £75,000 in deposits via digital vouchers, and over-reliance on flawed algorithms which failed to flag suspicious behaviours. Videoslots has been issued a formal warning, required to undergo an independent audit, and instructed to strengthen oversight of open-loop payment systems, which regulators warn pose heightened risks of anonymous and untraceable transactions.

EU Backs UN Resolution on Combating Illicit Financial Flows but Dissociates from Key Provisions

At the UN General Assembly’s Second Committee, the European Union voted in favour of a resolution promoting international cooperation to combat illicit financial flows and strengthen asset return practices, while expressing reservations about certain provisions. Delivered by Denmark on behalf of the EU, the statement welcomed the balanced facilitation of the text but regretted the omission of stronger language on FATF recommendations, civil society engagement, and journalist safety. The EU dissociated from paragraphs relating to a special session of the UNCAC Conference and beneficial ownership registries, citing concerns over pre-empting decisions and falling short of Sevilla Commitment standards. Despite these objections, the EU reaffirmed its commitment to tackling illicit financial flows as a threat to governance and sustainable development.

Bribery and Corruption

IMF Report Highlights Governance Weaknesses and Corruption Risks in Pakistan

The IMF’s Governance and Corruption Diagnostic Assessment for Pakistan (2025) identifies persistent governance weaknesses and widespread corruption vulnerabilities undermining economic performance and reform efforts. The diagnostic, requested by Pakistan’s government, examined fiscal governance, market regulation, financial oversight, AML/CFT frameworks, and rule of law. Findings reveal a heavily state-dominated economy plagued by complex regulations, weak institutional capacity, fragmented oversight, and inconsistent accountability, all of which constrain private sector growth and public sector effectiveness. The report recommends strengthening institutional integrity, enhancing transparency, improving enforcement consistency, and fostering inter-agency coordination to build sustainable economic growth and public trust.

Other Financial Crime

Illicit Finance in Africa: Regional Assessment Report

The Global Initiative Against Transnational Organised Crime has published a regional assessment report analysing the scale, complexity, and impact of illicit financial flows across Africa. The report highlights how weak regulation, convergence zones, and global trade hubs enable illicit finance, eroding economic stability and fuelling corruption. Key typologies include trade-based money laundering, the gold trade, informal value transfer systems, and vulnerabilities in Africa’s growing fintech ecosystem. It underscores the urgent need for stronger oversight, beneficial ownership transparency, and balanced regulation to safeguard financial integrity and mitigate risks posed by rapidly evolving criminal networks.

OSCE Workshop in Almaty Highlights Social Reuse of Confiscated Criminal Assets

The OSCE hosted a regional workshop in Almaty on 18–19 November 2025, focusing on how confiscated criminal assets can be repurposed for social good. Officials from prosecution offices, anti-corruption agencies, financial intelligence units, FATF-style bodies, and civil society discussed transparent management, legal frameworks, and innovative reinvestment models to support education, community recovery, and entrepreneurship. Speakers emphasised that social reuse strengthens public trust, promotes integrity, and aligns with FATF guidance encouraging countries to dedicate a share of recovered assets to capacity-building projects. The event formed part of the OSCE’s project on strengthening asset recovery efforts in Central Asia, supported by UK funding.

European Parliament Warns of Hungary’s Escalating Rule of Law Crisis

The European Parliament has adopted its second interim report on Hungary’s persistent breaches of EU values, condemning judicial interference, corruption, misuse of EU funds, and attacks on civil society. MEPs voiced alarm over Hungary’s supreme court revisiting EU Court of Justice rulings, refusal to implement European Court of Human Rights judgments, and systemic weakening of judicial independence. Concerns also focused on unlabelled AI-generated political content ahead of the 2026 elections, including deepfake videos linked to the ruling party, which threaten electoral integrity. Parliament reiterated Hungary’s slide into “electoral autocracy,” urged stronger Article 7 action, and demanded tangible consequences if espionage allegations within EU institutions are proven.

CTSI Urges Budget Funding to Combat Organised Crime on UK High Streets

The Chartered Trading Standards Institute (‘CTSI’) has called on the UK Government to provide urgent, long-term funding in the forthcoming budget to tackle serious and organised crime undermining legitimate businesses and public safety. CTSI warns that criminal “front” shops are proliferating across high streets, serving as hubs for illegal goods, money laundering, and even human trafficking. The Institute is pressing for stronger enforcement powers, improved intelligence sharing, and investment in multi-agency initiatives such as “Clear, Hold, Build” to disrupt criminal networks. CTSI stresses that without greater resources for Trading Standards, police, and partner agencies, organised crime will continue to erode consumer trust, deprive the Exchequer of vital tax revenue, and jeopardise economic growth.

Cybercrime

Security Minister Dan Jarvis Delivers Keynote at Parliament and Cyber Conference on Future Cyber Threats

At the inaugural Parliament and Cyber conference, Security Minister Dan Jarvis gave a keynote speech highlighting the urgent need to protect society against escalating cyber threats. Speaking at the House of Commons, he traced Parliament’s historical “technology gap” before stressing that today’s accelerating pace of innovation demands proactive resilience. Jarvis highlighted the economic and societal risks of cybercrime, with a projected cost of $27 trillion annually by 2027, and outlined government initiatives including the new Cyber Security and Resilience Bill, the Counter Political Interference and Espionage Action Plan, and support tools from the National Cyber Security Centre. He urged business leaders to treat cyberattacks as inevitable, calling for board-level commitment to security and collaboration with the UK’s thriving cyber industry.