Episode 207

1st December – 4th December 2025

Sanctions

UK Guidance Outlines Trade Licence Considerations Under Russia Sanctions

The UK government has published statutory guidance detailing when trade licences may be granted for activities otherwise prohibited under Russia sanctions. The guidance covers military goods, dual-use technologies, critical industry items, quantum computing, aviation and space goods, oil refining, energy-related goods, luxury items, and more. Licences may be issued in limited circumstances, such as fulfilling pre-existing contracts, ensuring safety and maintenance of UK capabilities, humanitarian assistance, medical purposes, or critical energy supply. However, applications must clearly justify why they fall within the listed considerations, and businesses are warned not to assume approval or engage in prohibited activities until a licence is granted.

UK Issues Updated Guidance on Sanctions and Humanitarian Operations in Syria

The UK Foreign, Commonwealth & Development Office has published updated guidance for businesses and NGOs operating in Syria, outlining current sanctions regimes, terrorism legislation, and available humanitarian exemptions and licences. The document, released on 2nd December 2025, is designed to help UK organisations navigate prohibitions while supporting recovery and aid efforts, ensuring compliance with financial sanctions and legal frameworks while enabling lawful humanitarian engagement.

UK Exporter Pays £620,515 Settlement for Export Control Breaches

In September 2025, a UK exporter agreed to pay a compound settlement of £620,515.04 to HM Revenue & Customs (‘HMRC’) after admitting to unlicensed exports of military goods regulated under the Export Control Order 2008. HMRC, which enforces export control legislation, offered the settlement in lieu of prosecution, consistent with its policy of using compound settlements where breaches are inadvertent or due to weak internal controls and where the exporter voluntarily discloses the violation.

UK Updates Russia Sanctions General Licence to Safeguard Agricultural Trade

The UK’s Office of Financial Sanctions Implementation (‘OFSI’) has updated General Licence INT/2022/2349952, originally issued in November 2022 under the Russia (Sanctions) (EU Exit) Regulations, to ensure continued trade in agricultural commodities despite sanctions restrictions. The licence permits designated persons, exporters, insurers, and financial institutions to engage in transactions related to food, seed, feed, fertiliser, and reproductive materials, including the provision of insurance and financial services. Amendments in June 2023 expanded permissions to cover the Grain and Feed Trade Association, while the latest update on 28th November 2025 broadened the definition of fertiliser under Schedule 3E Part 2A. The licence, of indefinite duration, requires notification to HM Treasury and strict record-keeping, highlighting the UK’s effort to balance sanctions enforcement with safeguarding global food security. The Publication Notice is here.

US Treasury Settles $11.5M Sanctions Case with IPI Partners

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) announced an $11,485,352 settlement with IPI Partners, LLC for 51 apparent violations of sanctions against Russia. Between 2017 and 2018, IPI solicited and received investments from Russian oligarch Suleiman Kerimov, continuing to maintain those investments for four years after Kerimov was designated by OFAC in April 2018. The settlement, deemed non‑egregious and not voluntarily self‑disclosed, resolves IPI’s civil liability for the violations.

Amnesty Urges ICC Member States to Resist US Sanctions at Assembly of States Parties

At the opening of the 24th Assembly of States Parties to the Rome Statute in The Hague, Amnesty International called on ICC member states firmly to oppose US sanctions targeting the Court, its officials, and Palestinian organisations. The sanctions, enacted by President Trump in February 2025 after ICC arrest warrants against Israeli and Palestinian leaders, threaten the Court’s independence and impartiality. Amnesty warned that any concessions, such as halting investigations into Palestine or limiting jurisdiction, would undermine the ICC’s foundational principles and deny justice to victims in conflicts from Darfur to Ukraine. Member states are urged to demonstrate collective resolve to protect the Court’s mandate and defend accountability against powerful perpetrators.

Russia’s Hopes for Sanctions Relief Set to Fail

In a recent blog post on the CEPA website, Alexander Kolyandr argues that Russia’s hopes for swift and unconditional sanctions relief are unrealistic. The article explains that sanctions will only be lifted gradually, conditionally, and in stages, with snapback provisions if Moscow reoffends. Despite Russia’s push for permanent relief, especially in banking, agriculture, and technology, the sheer scale of over 28,000 measures across multiple jurisdictions makes full reversal impossible. Even limited easing would not restore Russia’s pre-war economic position, leaving its economy weakened, unattractive to investors, and structurally burdened by inflation, worker shortages, and heavy defence spending.

Fraud

Italy: EPPO Uncovers €40 Million EU Subsidy Fraud Through Fake Training Courses

The European Public Prosecutor’s Office (‘EPPO’) in Milan has led an investigation into a large-scale fraud scheme involving two corporate consultancy groups which organised fictitious training courses for 1,500 employees across 32 companies, defrauding the EU’s “Fondo Nuove Competenze” project of an estimated €40 million. Precautionary measures were taken against three entrepreneurs, including house arrest and bans on public administration dealings, while seven individuals and seven companies remain under investigation. Evidence shows the illicit proceeds were used to purchase €20 million worth of real estate, with wiretapping, financial flow analysis, and worker interviews exposing the scheme. All suspects are presumed innocent until proven guilty in Italian law.

SFO Secures Conviction in Global Aircraft Parts Fraud

The UK Serious Fraud Office (‘SFO’) has secured the conviction of Jose Alejandro Zamora Yrala, director of AOG Technics, for selling aircraft engine parts with forged documentation between 2019 and 2023. The fraudulent parts, installed in CFM56 engines powering Boeing 737 and Airbus A320 planes, led to widespread grounding of aircraft after safety alerts from UK, US, and EU regulators. The SFO investigation, conducted with Portuguese authorities, exposed falsified safety certifications which threatened global aviation safety. Zamora Yrala pled guilty at Southwark Crown Court and will be sentenced on 23rd February 2026.

Money Laundering

Council of Europe Launches Four‑Year Project to Counter Money Laundering in Albania

The Council of Europe, co‑funded by the Swiss State Secretariat for Economic Affairs, has initiated a €1.18 million project to strengthen Albania’s fight against money laundering and terrorist financing. Running for 48 months from September 2025, the programme supports the Financial Intelligence Agency and supervisory bodies with risk‑based strategies, improved law‑enforcement responses, and guidance for both public authorities and private entities. Expected outcomes include consolidated anti‑money laundering policies, enhanced institutional capacities, and better risk management by non‑financial businesses, ensuring coherent implementation of Albania’s AML/CFT framework.

Europol-Led Operation Dismantles Violent Gambling and Laundering Network in Sweden

A coordinated law enforcement strike in late November targeted a violent criminal network operating in Stockholm, with raids in Sweden and Spain leading to five arrests and the seizure of luxury goods, cash, and drugs. The group, linked to drug trafficking across the Nordic region, ran illegal gambling operations with an estimated annual turnover of €20 million while laundering money for other criminals. Europol connected international intelligence to local enforcement, enabling authorities to disrupt a network notorious for violence, intimidation, and human trafficking indicators.

EU and US Authorities Dismantle Major Cryptocurrency Mixing Service

Eurojust has announced the takedown of a large-scale cryptocurrency mixing service used to launder illicit funds across borders. Coordinated by EU and US authorities, the operation targeted a platform which anonymised digital transactions to conceal criminal proceeds, including money from cybercrime and fraud. The joint investigation disrupted the service’s infrastructure, seized digital assets, and highlighted the growing international cooperation against crypto-enabled financial crime. This marks a significant step in curbing the misuse of blockchain technology for laundering activities.

Bribery and Corruption

UK Makes Significant Strides in Anti-Corruption Reforms, GRECO Confirms

The Council of Europe’s Group of States against Corruption (‘GRECO’) has concluded its latest compliance review of the United Kingdom, noting substantial progress in strengthening transparency and integrity within government and law enforcement. Out of twelve recommendations issued in its 2018 evaluation, eight have been fully implemented, three partly, and one remains outstanding.

In government, reforms have focused on enhancing accountability at the highest levels. The Ministerial Code has been revised to empower the Independent Adviser on Ministers’ Interests to investigate breaches, while guidance on declarations of interests has been updated and published more frequently. Transparency measures for ministers, senior officials, and advisers have also been strengthened, though GRECO observed that disclosures still concentrate mainly on conflicts of interest rather than broader corruption risks.

Law enforcement agencies have achieved full compliance with GRECO’s recommendations. The Policing Code of Ethics is now embedded in training, and the National Crime Agency has adopted a dedicated ethics code alongside a new disciplinary policy. The Metropolitan Police Service has improved vetting and disciplinary procedures, expanded professional standards staff, and introduced confidential channels for reporting misconduct. Protections for whistleblowers have also been reinforced through the Independent Office for Police Conduct.

Despite these advances, GRECO highlighted areas requiring further action. Post-employment restrictions for officials and police officers remain limited, lobbying transparency has yet to be fully addressed, and enforceable sanctions for breaches of restrictions are still lacking. GRECO has urged UK authorities to continue reforms, particularly in revising the Advisory Committee on Business Appointments and introducing disclosure requirements for special advisers’ contacts with lobbyists.

EU Reaches Landmark Deal on Unified Criminal Rules Against Corruption

The European Parliament and Council have reached a provisional agreement on the first-ever EU directive harmonising criminal law against corruption, setting common definitions, sanctions, and operational rules across member states. The directive requires annual publication of corruption data, national anti-corruption strategies developed with civil society, and establishes uniform maximum prison sentences while allowing stricter national penalties. It also strengthens cooperation with OLAF, the European Public Prosecutor’s Office, Europol, and Eurojust, and extends liability to legal entities. Lawmakers hailed the deal as a decisive step toward greater transparency, deterrence, and coherence in protecting the rule of law across the Union.

UNDP Champions Integrity and Data-Driven Coordination to Strengthen Global Anti-Corruption Efforts

The United Nations Development Programme (‘UNDP’) is advancing the fight against corruption by combining practical integrity-building tools with stronger data-driven coordination. In Montenegro, UNDP and the Agency for Prevention of Corruption launched the Guide for Building Integrity, the country’s first model for assessing anti-corruption measures across public institutions, inspired by Korea’s methodology and designed to foster transparency, ethical culture, and citizen trust. At the global level, UNDP emphasises that effective corruption measurement requires better data collection and strengthened coordination among governments, agencies, and civil society, ensuring that prevention strategies are evidence-based and systematically monitored. Together, these initiatives highlight UNDP’s dual approach: equipping countries with practical frameworks to assess integrity while promoting international cooperation and robust data systems to make anti-corruption efforts more coherent, transparent, and impactful. The press releases are here and here.

Other Financial Crime

Former Guyanese Presidential Candidate and Businessman Indicted in $50 Million Gold Export Tax Evasion Scheme

A federal grand jury in Miami has indicted Nazar Mohamed, 72, and his son Azruddin Mohamed, 38, the owners of Mohamed’s Enterprise, for allegedly orchestrating a multi-year scheme to evade millions in taxes and royalties owed to Guyana through fraudulent gold export practices. Prosecutors claim the pair reused official government seals on shipments, bribed officials, and concealed the true quantity of exported gold, causing an estimated $50 million loss to Guyana. The indictment also alleges Azruddin engaged in a separate tax evasion scheme involving a Lamborghini shipment. Both men, sanctioned by the US Treasury in 2024, face charges including money laundering, wire fraud, and mail fraud, with US authorities seeking forfeiture of seized gold bars.

SFO Whistleblowing Report Shows 92% Action Rate

The Serious Fraud Office’s 2024–25 annual whistleblowing report reveals that 167 qualifying disclosures were received, with action taken in 153 cases, which is over 92% of referrals. These disclosures, covering serious fraud, bribery, and corruption, were assessed confidentially and often led to further enquiries with partner agencies. The report demonstrates the vital role whistleblowers have in exposing economic crime and highlights the SFO’s commitment to treating them with dignity and respect.

Cybercrime

NCSC Urges Small Businesses to Act on Cyber Security with New Toolkit

The National Cyber Security Centre (‘NCSC’) has published a blog post highlighting the urgent need for the UK’s 5.5 million small businesses to strengthen their cyber resilience, noting that half suffer a cyber incident each year. To address this, the NCSC has launched its free Cyber Action Toolkit, designed to turn expert advice into simple, achievable steps which build instant protection against threats such as phishing, email hacking, and ransomware. The blog stresses that even non-technical users can benefit, and encourages organisations to progress towards Cyber Essentials certification, which offers added safeguards, customer assurance, and access to cyber insurance and emergency support.

UK Ministers Urge Small Businesses to Act on Rising Cyber Threats

A ministerial letter from the UK government warns that half of small businesses have suffered cyber-attacks in the past year, with phishing hitting 35% of micro firms. Highlighting the growing intensity and sophistication of hostile cyber activity, ministers stress that protecting against attacks is far less costly than recovering from them. To support businesses, the National Cyber Security Centre offers the free Cyber Action Toolkit for accessible, step‑by‑step protection, while the government‑backed Cyber Essentials certification provides recognised standards, insurance, and access to contracts. The letter urges entrepreneurs to take immediate steps to strengthen resilience and safeguard customer trust.

French Football Federation Confirms Cyber-Attack and Member Data Theft

The French Football Federation (‘FFF’) has revealed it was the target of a cyber-attack which compromised software used by clubs to manage registered members, resulting in the theft of personal data such as names, gender, nationality, and contact details. The breach was conducted through a compromised account but has since been contained, with the FFF disabling the account, resetting all user passwords, and filing a complaint. While the Federation stressed that the issue has been resolved, it acknowledged the growing variety of cyber threats and reaffirmed its commitment to strengthening its security measures.