Episode 206

28th November – 30th November 2025

Sanctions

CEPR Sanctions Watch: November 2025 Update on Global Measures

The Centre for Economic and Policy Research (‘CEPR’) has published its November 2025 Sanctions Watch, providing fact‑based, data‑driven analysis of ongoing international sanctions regimes. The update tracks developments across multiple countries, highlighting humanitarian impacts, shifts in enforcement, and policy debates surrounding the effectiveness of sanctions as a foreign policy tool. CEPR’s report aims to advance democratic debate by offering transparent, evidence‑based insights into how sanctions shape economies and people’s lives.

False Flags Surge: 113 Russian ‘Shadow’ Vessels Evade Sanctions, Transporting €4.7 Billion in Oil

A new Centre for Research on Energy and Clean Air (‘CREA’) report reveals that 113 Russian ‘shadow’ vessels operated under false flags in the first three quarters of 2025, transporting 11 million tonnes of oil worth €4.7 billion. False flagging, which is where ships fraudulently register with non-existent or terminated registries, has increased six-fold since late 2024, undermining global maritime governance and voiding vessel insurance, raising major environmental and security risks. Malawi’s flag has been most exploited, despite the country having no legitimate registry. The findings highlight systemic weaknesses in sanctions enforcement and call for unified international reforms to tighten flag-state oversight.

OFSI Issues General Licence Permitting Business Continuity with Lukoil International Entities

On 27th November 2025, the UK’s Office of Financial Sanctions Implementation (‘OFSI’) issued General Licence INT/2025/8031092 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, authorising the continuation of business operations with Lukoil International Entities. Stakeholders are advised to review the Licence for detailed definitions, permissions, and compliance requirements. To provide clarity, OFSI has also published FAQ 174, confirming whether operations with Lukoil International GmbH can proceed as normal under UK financial sanctions.

OFSI Issues General Licence to Exempt Agricultural Commodities Trade from Russia Sanctions

The UK's Office of Financial Sanctions Implementation (‘OFSI’) has issued General Licence INT/2022/2349952 under the Russia (Sanctions) (EU Exit) Regulations 2019, which, as amended on 28th November 2025, exempts certain activities from key financial sanctions prohibitions (Regulations 11-15 and/or 17A). This licence is specifically granted to facilitate transactions related to Agricultural Commodities, which are defined broadly to include Food, Fertiliser, Seed, Feed, and Reproductive materials. The permission is vital as it allows UK Corporates, Relevant Institutions, Insurance Providers, and Relevant Exporters to engage in the export, sale, production, and transport of these commodities and to receive or transfer Funds and Economic Resources from or to any Person, including a Designated Person, provided the activities relate to agricultural commodities. Furthermore, Designated Persons are explicitly permitted to pay banking fees and insurance costs to institutions necessary to effect these agricultural transactions. Organisations utilising these permissions must notify HM Treasury within seven days of commencing the activity and maintain comprehensive records for a minimum of six years.

OFSI Updates Russia Sanctions List, Reiterating Asset Freeze on ex-TASS Director General

The UK's Office of Financial Sanctions Implementation (‘OFSI’) issued a Financial Sanctions Notice on 28th November 2025, detailing an update to the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019. These regulations impose financial sanctions, including asset freezes and investment restrictions, on persons involved in destabilising Ukraine or obtaining a benefit from or supporting the Government of Russia. The Notice confirms that the entry for Sergey Vladimirovich Mikhailov (Group ID: 15320), the former Director General of the Government of Russia-affiliated TASS news agency, has been amended and he remains subject to an asset freeze and trust service sanctions. Financial institutions are instructed to check whether they maintain accounts or hold funds for Mikhailov or entities owned or controlled by him, freeze those resources, refrain from dealing with them or making them available, and report any findings to OFSI. Mikhailov was originally designated for being involved in obtaining a benefit from or supporting the Government of Russia through his role at TASS.

EU Examines Legal Pathways to Use Frozen Russian Assets for Ukraine Reparations

In response to Russia’s war against Ukraine, the EU has imposed 19 sanctions packages, immobilising around €210 billion of Russia’s sovereign assets and freezing €28 billion in private assets. While steps have been taken regarding private funds and windfall profits, major legal hurdles remain over confiscating or managing state assets, particularly those of the Russian Central Bank, which are protected by state immunity under international law. A proposed solution is an EU Instrument, namely a “Reparations Loan”, which would prolong asset immobilisation through qualified majority voting, ensure reversibility, and link to existing compensation mechanisms. This approach seeks to reconcile EU and international legal frameworks, though it carries significant legal risks.

Bribery and Corruption

Why Tackling Corruption Requires a Whole‑of‑Society Approach

In an opinion piece from the World Economic Forum, Ottilia Anna Maunganidze and Ngaire Woods argue that corruption, which costs the global economy an estimated $3.6 trillion annually, cannot be defeated by governments alone. They stress that trust in institutions, strong democratic frameworks, and community vigilance against even the smallest acts of misconduct are essential to shifting societal norms. By redefining corruption beyond monetary thresholds and emphasising collective responsibility, the article calls for a transformational vision which unites citizens, governments, and businesses in reshaping integrity and accountability.

Market Abuse

FCA Charges Two Men Over £70,000 Insider Dealing Scheme

The Financial Conduct Authority (‘FCA’) has launched criminal proceedings against Bobosher Sharipov, a former Jefferies International banker, and his associate Bekzod Avazov, alleging insider dealing linked to the 2021 takeover of GCP Student Living plc. Sharipov is accused of leaking confidential information to Avazov, who then traded shares and spread bets to secure nearly £70,000 in profit. The FCA’s monitoring systems flagged the suspicious trades, and the case has now been sent to Southwark Crown Court, with both defendants yet to enter pleas.

FCA and Police Arrest Individual in Suspected Market Manipulation Case

The Financial Conduct Authority (‘FCA’), in collaboration with the Metropolitan Police, has arrested an individual at their London home on suspicion of market manipulation, fraud by false representation, and forgery. A search was conducted under warrant, and the suspect was interviewed under caution before being released on bail. The FCA confirmed that its investigation into the matter is ongoing.

Other Financial Crime

Europe Launches Mission to Combat Corruption and Financial Crime

At a Strasbourg event on 25–26 November 2025, the Council of Europe unveiled a new initiative, ‘Action against Corruption and Money Laundering in Europe’, to strengthen resilience against corruption, money laundering, and terrorist financing. Funded by the EEA and Norway Grants and implemented by the Council’s Economic Crime and Cooperation Division, the programme will help European countries develop clearer rules, more effective institutions, and stronger cross-border cooperation. Representatives from 15 EU member states, the European Commission, and other partners joined to set priorities and operational plans for tackling these systemic risks.

SFO Issues Guidance on Evaluating Corporate Compliance Programmes

The Serious Fraud Office has published detailed guidance outlining when and how prosecutors will assess corporate compliance programmes in cases involving fraud, bribery, and related offences. The framework applies to decisions on prosecution, deferred prosecution agreements, sentencing, and statutory defences under the Bribery Act 2010 and the Economic Crime and Corporate Transparency Act 2023. It emphasises that compliance programmes must be genuinely proactive, effective, proportionate, and regularly reviewed, going beyond “paper exercises”, with evaluation focusing on their effectiveness both at the time of the offence and at the time of charge or reporting.

HMRC Announces Higher Economic Crime Levy Rates and New Band Structure

HM Revenue & Customs has published changes to the Economic Crime (Anti-Money Laundering) Levy, effective from April 2026. The measure introduces two new bands by splitting the previous large band: Band B for entities with UK revenue between £36 million and £500 million (levy of £36,000) and Band C for those between £500 million and £1 billion (levy of £500,000). Bands A and D remain but their charges rise to £10,200 and £1 million respectively. These changes apply to businesses regulated for anti-money laundering purposes with annual UK revenue exceeding £10.2 million, aiming to increase funding for tackling economic crime.

Transparency International UK: Offshore Centres Still Failing on Corporate Transparency

Transparency International UK has released a new assessment showing that most UK Overseas Territories, including Bermuda, the British Virgin Islands, and the Cayman Islands, have failed to deliver on long‑promised corporate transparency reforms. Despite commitments made more than seven years ago, beneficial ownership registers in these jurisdictions remain largely inaccessible, with Montserrat standing out as the only strong performer. The report warns that secrecy in these centres continues to enable large‑scale money laundering and corruption, undermining global efforts to protect public funds and strengthen accountability.

INTERPOL Adopts Global Blueprint and Targets Rising Scam Centre Threat at General Assembly

At its 93rd General Assembly in Marrakech, INTERPOL unveiled a five-year Strategic Framework (2026–2030) to strengthen global law enforcement cooperation against evolving transnational crime, including cyber fraud, human trafficking, and illicit finance. The plan emphasises becoming a trusted information hub, providing world-class operational support, and serving as the leading voice for policing worldwide. Alongside this blueprint, delegates adopted a resolution to combat the growing menace of transnational scam centres, which are criminal hubs linked to large-scale fraud and trafficking, by enhancing real-time intelligence sharing, launching multinational operations, and expanding victim rescue and support measures. Both initiatives underscore INTERPOL’s commitment to unified, decisive action against borderless crime.