Episode 208

5th December – 7th December 2025

Sanctions

EU Strikes Landmark Deal to Ban Russian Gas Imports by 2027

The Council of the EU and European Parliament have reached a provisional agreement to phase out Russian natural gas imports, a key step in the REPowerEU roadmap to secure energy independence. The regulation introduces a binding ban on liquefied natural gas by the end of 2026 and pipeline gas by autumn 2027, with transition periods for existing contracts. Member states must submit diversification plans, while customs will enforce strict authorisation procedures to prevent circumvention. The deal also includes penalties for non-compliance and a suspension clause for emergencies, marking a decisive move to end the EU’s reliance on Russian energy.

US Treasury Sanctions Venezuelan Entertainment Network Tied to Tren de Aragua

The US Department of the Treasury’s Office of Foreign Assets Control has sanctioned Venezuelan entertainer Jimena Romina Araya Navarro, known as “Rosita,” and several associates for providing material support to the terrorist cartel Tren de Aragua (‘TdA’). Rosita, a DJ and actress with millions of followers, reportedly aided cartel leader “Niño Guerrero” in a 2012 prison escape and funnelled nightclub revenues to TdA leadership. Her former manager, Eryk Manuel Landaeta Hernandez, also sanctioned, organised drug-fuelled parties in Colombia to launder proceeds for cartel leaders. Additional sanctions target TdA lieutenants across Venezuela and Colombia, as well as affiliated shell companies. The designations block US assets, prohibit transactions, and aim to disrupt TdA’s narcotrafficking, human smuggling, and money laundering operations. Allied to this, the US Department of State’s Bureau of International Narcotics and Law Enforcement Affairs announced a reward offer increase under the Transnational Organised Crime Rewards Program (‘TOCRP’) of up to $5 million for information leading to the arrest and/or conviction of Giovanni Vicente Mosquera Serrano, a leader of Tren de Aragua. The press release is here.

OFAC Fines Gracetown $7 Million for Violating Russia Sanctions

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has imposed a $7.1 million penalty on Gracetown Inc., a New York property management company, for violating Russia-related sanctions and failing to report blocked assets. Despite receiving explicit notice from OFAC, Gracetown continued to process payments on behalf of an entity owned by sanctioned Russian oligarch Oleg Deripaska between 2018 and 2020. The company also withheld reporting of blocked assets for over 45 months. Treasury officials emphasised that this enforcement action, near the statutory maximum, demonstrates the severe consequences of ignoring US sanctions and aiding adversaries.

UK’s Trade Sanctions Watchdog Marks First Year with Strong Compliance Push

The Office of Trade Sanctions Implementation (‘OTSI’), launched in October 2024, has completed its first year as the UK’s civil enforcement body for trade sanctions. In its inaugural year, OTSI built core capabilities, processed 60 licence applications, and received 146 reports of potential breaches, mostly from the financial sector. While no civil monetary penalties have yet been imposed, several investigations are underway, with referrals made to HMRC and international partners. Alongside enforcement, OTSI has prioritised business engagement, issuing guidance, hosting over 200 stakeholder events, and launching a shared sanctions update platform. Looking ahead, OTSI plans to expand its licensing remit in 2026, strengthen proactive enforcement, and broaden outreach across UK industries.

UK Expands Cyber and Russia Sanctions with 12 New Designations

On Thursday 4th December, the UK Government announced 12 new sanctions designations targeting individuals and entities under its Cyber and Russia regimes. Eight individuals were added to the Cyber sanctions list, including Boris Alekseyevich Antonov, Anatoliy Vladimirovich Istomin, Igor Andreyevich Bochka, Aleksey Andreyevich Umets, Pavel Vyacheslavovich Yershov, Nikolay Yuryevich Kozachek, Denis Igorevich Denisenko, and Dmitriy Yuryevich Goloshubov. In parallel, four designations were made under the Russia sanctions regime, including the Main Directorate of the General Staff of the Armed Forces of the Russian Federation, along with Yuriy Alekseevich Sizov, Vladimir Lipchenko, and Denis Alexandrovich Smolyaninov. These measures reinforce the UK’s commitment to countering cyber threats and Russian aggression through targeted restrictions on individuals and entities deemed complicit in hostile activity. The Cyber Notice is here, and the Russia Notice here.

UK Imposes Asset Freezes on Gurpreet Singh Rehal and Babbar Akali Lehar

On 4th December 2025, HM Treasury updated the UK Consolidated List to designate Gurpreet Singh Rehal and the group Babbar Akali Lehar under the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019. Both are now subject to asset freezes, with Rehal additionally facing a director disqualification sanction. Authorities cite Rehal’s involvement in promoting and financing terrorist organisations, including Babbar Khalsa and Babbar Akali Lehar, through recruitment, financial services, and procurement of weapons. Linked entities such as Saving Punjab CIC, WhiteHawk Consultations Ltd, and Loha Designs are also subject to restrictions. Babbar Akali Lehar itself is accused of promoting terrorism and recruiting on behalf of Babbar Khalsa. The notice warns that failure to comply with these sanctions may constitute a criminal offence.

Preparing for the UK’s Single Sanctions List Transition

On Wednesday 17th December, the Foreign, Commonwealth & Development Office and the Office of Financial Sanctions Implementation will host an online webinar from 11:00 to 12:00 to explain the upcoming move to a single UK sanctions list, effective 28th January 2026. The session will outline improvements to the UK Sanctions List and its search tool, while providing practical guidance on steps organisations should take to ensure readiness for the transition. You can register for the webinar here.

Fraud

International Operation Dismantles €700 Million Crypto Fraud Network

Europol and Eurojust have coordinated a sweeping international crackdown which dismantled a cryptocurrency fraud and money laundering network responsible for laundering over €700 million. The operation, executed in two phases across October and November 2025, involved raids in Cyprus, Germany, Spain, Belgium, Bulgaria, and Israel, leading to multiple arrests, asset seizures, and the disruption of fraudulent investment platforms and affiliate marketing infrastructure. Criminals had lured victims with fake trading platforms and deepfake-driven ads, then laundered stolen funds through complex blockchain exchanges. Europol provided operational, analytical, and crypto-specialist support, ensuring cross-border intelligence sharing and enforcement, marking a major strike against organised online fraud.

City of London Police Launches New National Fraud Reporting Service

From 4th December 2025, City of London Police has introduced Report Fraud, a new national platform replacing Action Fraud for reporting cybercrime and fraud. The service aims to improve victim experience and provide better intelligence to law enforcement. Key features include a new contact centre, an online reporting tool, and the National Crime Analysis Service (N-CAS) for analysing reports, accessible to all UK police forces. Victim support will continue through the Report Fraud Victim Service. Reports can be made at reportfraud.police.uk or by calling 0300 123 2040, with the old Action Fraud site redirecting to the new platform during the transition.

Money Laundering

EU Adds Russia to List of High-Risk Jurisdictions

The European Commission has formally designated Russia as a high-risk jurisdiction for money laundering and terrorist financing, aligning with international standards and reinforcing EU financial safeguards. This move subjects Russian-linked transactions to enhanced due diligence by banks and financial institutions, tightening scrutiny on cross-border flows and reducing exposure to illicit finance. The designation demonstrates the EU’s broader strategy to protect its financial system from geopolitical threats while ensuring compliance with global anti-money laundering frameworks.

£825,000 Fine Highlights AML and Social Responsibility Failings at Done Brothers

The Gambling Commission fined Done Brothers (Cash Betting) Limited £825,000 after uncovering serious anti-money laundering shortcomings, including inadequate customer due diligence and ineffective risk controls. The penalty also reflected failures in social responsibility, where the operator did not sufficiently identify or intervene with customers at risk of gambling-related harm, underscoring the regulator’s dual focus on financial crime prevention and player protection.

UK and Australia Strengthen Partnership to Combat Illicit Finance

The UK Home Office and Australia’s Department of Home Affairs reaffirmed their commitment to tackling illicit finance during the third annual UK-Australia Illicit Finance Dialogue held in London in October 2025. Senior officials from both nations discussed evolving threats, shared best practices, and explored strategies such as governance structures, public–private partnerships, and anti-corruption measures. Key topics included fraud prevention, crypto-related risks, sanctions against Russia-linked networks, and enhancing corporate transparency. Both countries pledged to deepen cooperation at policy and operational levels, aligning with international standards set by the Financial Action Task Force, and plan to reconvene in 2026 to continue advancing joint efforts.

Bribery and Corruption

Moody’s Anti-Corruption Day 2025: Tackling Corruption Amid Global Risk

An article on Moody’s website highlights how corruption amplifies today’s “era of exponential risk,” where geopolitical tensions, financial instability, and climate challenges intersect. Corruption, defined as the abuse of entrusted power for private gain, undermines trust, weakens institutions, and fuels crises such as income inequality, domestic conflict, arms trade misconduct, and environmental degradation. Global losses from bribery and stolen funds are estimated at $3.6 trillion, with money laundering adding $2 trillion more, equating to 5% of global GDP. Moody’s stresses that illicit financial flows are a core enabler of corruption and calls for stronger transparency, compliance, and collaboration between governments, businesses, and citizens to dismantle corruption’s grip.

Incidentally, International Anti-Corruption Day is the 9th December 2025. Here is the UNODC announcement from last month getting ahead of the game.

Market Abuse

Cross-Border Insider Trading Probe Targets Former IT Executives

European authorities in Switzerland, Germany, and the United Kingdom have launched a coordinated investigation into five former senior executives suspected of insider trading at a Swiss-based international IT company. The individuals allegedly sold large volumes of shares ahead of two damaging press releases, avoiding losses estimated at €2.6 million. While the company itself is not under investigation, searches of private residences and offices were conducted on 2nd December, yielding crucial evidence. The operation, facilitated by Eurojust, highlights the importance of swift cross-border cooperation in tackling complex economic crimes.

Cybercrime

Post Office Reprimanded Over Preventable Data Breach Affecting Horizon IT Scandal Victims

The UK Information Commissioner’s Office (‘ICO’) has reprimanded Post Office Limited after a serious data breach exposed the personal details of 502 postmasters involved in the Horizon IT scandal. The breach occurred when an unredacted legal settlement document containing names, addresses, and postmaster status was mistakenly published online between April and June 2024. ICO investigators found the Post Office lacked proper publication protocols, staff training, and quality assurance processes, concluding the incident was entirely preventable. While a fine of up to £1.094 million was considered, the ICO opted for a reprimand under its public sector approach, emphasising remedial actions such as compensation, identity protection services, and new internal controls.

UK Cyber Tool Blocks Nearly 1 billion Malicious Site Access Attempts

The UK’s National Cyber Security Centre (‘NCSC’) reports that its new Protective DNS service has blocked almost one billion attempts to access malicious websites since its launch, highlighting the scale of online threats facing individuals and organisations. The tool, designed to prevent connections to harmful domains, has already protected government departments, schools, and businesses from phishing, malware, and ransomware attacks, demonstrating its key role as a critical defence in the nation’s cybersecurity strategy.