Episode 209

8th December – 11th December 2025

Sanctions

Australia Launches World-First Autonomous Sanctions Framework Against Taliban Leaders

On 6th December 2025, the Albanese Government introduced a groundbreaking autonomous sanctions framework for Afghanistan, making Australia the first country independently to impose sanctions outside the UN system. The framework allows direct financial sanctions, travel bans, and an arms embargo targeting Taliban leaders responsible for oppressing women and girls and undermining governance. Initial measures include sanctions on three Taliban “ministers” and the group’s “Chief Justice.” Since Kabul’s fall, Australia has provided over $260 million in humanitarian aid, with an additional $50 million allocated for 2025/26, underscoring its commitment to supporting Afghan people while increasing pressure on the Taliban.

UK Sanctions Russian GRU After Inquiry Links Putin to Salisbury Poisonings

The UK government has imposed sweeping sanctions on Russia’s military intelligence agency, the GRU, after the Dawn Sturgess Inquiry concluded that President Vladimir Putin personally ordered the 2018 Salisbury nerve agent attack on Sergei and Yulia Skripal, which led to Sturgess’s death. The measures target the GRU in its entirety, along with specific officers involved in cyber operations and hostile activities across Europe. Prime Minister Keir Starmer and senior ministers condemned the Kremlin’s reckless aggression, vowing to defend European security and counter Russia’s hybrid threats through coordinated action with NATO allies.

UK Imposes Dual Sanctions on Russia-Linked and Malicious Cyber Actors

On 9th December 2025, the UK Office of Financial Sanctions Implementation (‘OFSI’) announced new financial restrictions targeting destabilising activities under two distinct legal frameworks. Under the Cyber (Sanctions) (EU Exit) Regulations 2020, Integrity Technology Group Incorporated and Sichuan Anxun Information Technology Co., Ltd. were designated and subjected to an asset freeze for involvement in malicious cyber activity, including supplying botnets and exploiting vulnerabilities which undermined the integrity and security of the UK and other nations. Simultaneously, the Russia (Sanctions) (EU Exit) Regulations 2019 resulted in seven additions to the Consolidated List, including individuals like Aleksandr Geljevitj Dugin and entities such as Rybar LLC, Euromore, and the Centre for Geopolitical Expertise. These Russia-related designations, which included asset freezes and trust service sanctions, were imposed due to the parties' involvement in destabilising Ukraine, undermining its territorial integrity, or supporting the Government of Russia. As a result of both notices, UK entities must freeze and report any funds or economic resources belonging to all designated parties, as failure to comply is a criminal offence. The Cyber Notice is here, and the Russia Notice is here.

Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War

On 9th December 2025, the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) imposed sanctions on four individuals and four entities for their crucial roles in fuelling the civil war in Sudan. This targeted action addresses a transnational network, consisting primarily of Colombian nationals and companies, responsible for recruiting former Colombian military personnel to serve as infantry, artillerymen, drone pilots, and instructors for the Rapid Support Forces (‘RSF’), even training children to fight. The RSF has repeatedly targeted civilians since the conflict began in April 2023, engaging in systematic killings, ethnic torture, rape, and sexual violence, atrocities which the Department of State determined constituted genocide. Key sanctioned entities include International Services Agency (A4SI), the main recruiting node co-founded by Alvaro Andres Quijano Becerra, and Maine Global Corp SAS, which manages and disburses funds, processes fighter payroll, and acts as a foreign exchange intermediary converting millions of US dollars. These individuals and entities were designated pursuant to Executive Order 14098 for destabilising Sudan, resulting in the blocking of all their property and interests in property within the United States or in the possession or control of US persons.

OFAC Settles $1.09M Case with US Trustee Over Russian Sanctions Violations

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) announced a $1,092,000 settlement with an individual (“US Person-1”) for 122 apparent violations of sanctions against Russia. Between April 2018 and June 2022, the individual acted as fiduciary for a US-based family trust belonging to a sanctioned Russian oligarch, dealing in blocked property and providing prohibited services. OFAC classified the conduct as non-egregious and not voluntarily self-disclosed, but the settlement amount reflects both the seriousness of the violations and the individual’s substantial cooperation during the investigation.

Fraud

US Recovers $1.7M in Cryptocurrency Fraud Through Civil Asset Forfeiture

The US Attorney’s Office for the Eastern District of Virginia announced it has recovered nearly $1.7 million in cryptocurrency, 420,740 USDT (Tether) and 1,249,996 BUSD (Binance USD), stolen in a sophisticated investment scam. Fraudsters lured victims via unsolicited texts and social media, gained their trust, and directed them to a spoofed investment site which falsely showed profits while coercing additional payments under the guise of taxes and fees. The perpetrators laundered the funds through rapid crypto exchanges before agents seized them from three wallets. A civil forfeiture action cleared title to the assets, which will now be returned to victims.

FCA Charges Ex-Bank Director Henrik Schliemann with Fraud and Forgery

The UK Financial Conduct Authority has charged Henrik Schliemann, a former director of a merchant bank, with nine criminal offences including fraud by abuse of position, fraud by false representation, and forgery. Schliemann allegedly transferred $1.45 million and €3.1 million from company accounts into his own, while also paying himself over £1.3 million in excess dividends. He appeared before Westminster Magistrates’ Court without entering a plea, and the case has been sent to Southwark Crown Court for a hearing scheduled on 5th January 2026. Schliemann, a German national residing in the UK, has been released on conditional bail.

UK Taxpayer Lost £10.9 Billion to Covid Fraud, Report Finds

An independent report by the Covid Counter Fraud Commissioner has revealed that UK taxpayers lost £10.9 billion to fraud and error during the previous government’s pandemic support schemes, including Bounce Back Loans, which were rolled out with weak safeguards. The report highlights poor accountability, bad data quality, and flawed contracting as key drivers of the losses, which are enough to fund free school meals for 2.7 million children for eight years. Chancellor Rachel Reeves confirmed that nearly £400 million has already been recovered, with tougher fraud powers, a voluntary repayment scheme, and specialist recovery teams being introduced to claw back funds and prevent similar failures in future crises. The Report is here.

Money Laundering

HM Treasury Issues 13th Annual AML/CTF Supervision Report

HM Treasury has published its 13th annual report on anti-money laundering (‘AML’) and counter-terrorist financing (‘CTF’) supervision, covering activities between 6th April 2024 and 5th April 2025. The report fulfils statutory obligations under Regulation 51 of the Money Laundering Regulations (MLRs) and draws on data provided by appointed supervisors. The Report provides context for the UK’s comprehensive regime, emphasising the critical role 25 supervisors (including the FCA, HMRC, GC, and PBSs) play in identifying and preventing economic crime. The Report highlights significant structural reform decided upon following a 2022 review, specifically that the Financial Conduct Authority (‘FCA’) is slated to become the AML/CTF supervisor for all professional services firms, encompassing Legal Service Providers, Accountancy Service Providers, and Trust and Company Service Providers, thereby consolidating supervision and strengthening oversight across the system. This supervisory transition and concurrent changes to the Money Laundering Regulations (MLRs), which aim at closing loopholes and clarifying targeted, risk-based obligations, support the Government’s wider Anti-Corruption Strategy and Economic Crime Plan. Furthermore, the Report uses an enhanced methodology, featuring several new metrics designed better to evaluate supervisory effectiveness, measure persistent non-compliance, and align the UK's reporting with the new requirements set by the Financial Action Task Force ahead of the UK's in-depth peer evaluation scheduled to be published in 2028.

FinCEN Fines Paxful $3.5M for Major Bank Secrecy Act Violations

The US Treasury’s Financial Crimes Enforcement Network (‘FinCEN’) has imposed a $3.5 million civil penalty on Paxful, Inc. and Paxful USA, Inc. for wilfully violating the Bank Secrecy Act. The peer-to-peer virtual currency platform facilitated over $500 million in suspicious transactions linked to illicit actors and high-risk jurisdictions, including Iran, North Korea, Venezuela, and the now-defunct Backpage.com. Paxful failed to register as a money services business, implement an effective anti-money laundering program, and file suspicious activity reports. While FinCEN acknowledged Paxful’s remediation efforts and leadership changes, the enforcement underscores the agency’s commitment to safeguarding the US financial system and promoting responsible innovation.

Bribery and Corruption

UK Launches Landmark 2025 Anti-Corruption Strategy, Targeting Dirty Money and Rogue Insiders

The UK government has unveiled its ambitious new Anti-Corruption Strategy 2025, detailing a comprehensive plan spanning over a hundred commitments designed to root out corruption, strengthen national security, and drive economic growth. The strategy, which is jointly owned by the Home Office, HM Treasury, and the Foreign, Commonwealth and Development Office, focuses on three key pillars: combating corrupt actors and funds, tackling UK vulnerabilities, and building global resilience.

This crackdown comes amid stark warnings regarding the scale of illicit finance, with the National Crime Agency estimating that over £100 billion could be laundered through the UK every year. Domestically, corruption continues to undermine fair competition, with UK businesses reporting approximately 117,000 bribe offers in the past year alone, collectively valued at over £300 million. Internationally, the UK's reputation for integrity has also suffered, achieving its lowest ever ranking of 20th on Transparency International’s Corruption Perceptions Index in 2024.

The new strategy directly addresses these concerns, which are widely shared by the public: a Home Office survey published in December 2025 revealed that 87% of respondents are concerned about the possibility of corruption among politicians, and 86% hold similar concerns regarding public sector employees. Furthermore, 70% of the public are concerned about UK professional services using financial structures like shell companies or trusts to conceal wealth for corrupt actors from abroad.

The government’s response includes a major escalation in enforcement capabilities. The Domestic Corruption Unit in the City of London Police will see a significant expansion, backed by £15 million in new funding to take on more investigations into bribery and money laundering across the country. Additionally, the Serious Fraud Office is committed to speeding up investigations by harnessing the power of artificial intelligence and machine learning.

A central focus of the strategy is shutting down "professional enablers", such as the lawyers, accountants, and bankers who facilitate the flow of dirty money. To improve oversight and enforcement consistency, the government announced it will consolidate the anti-money laundering and counter-terrorist financing supervisory functions of 22 professional services supervisory bodies, moving responsibility to the Financial Conduct Authority.

Integrity across public life is another critical area. The government has committed to establishing an Ethics and Integrity Commission to strengthen probity by reinforcing and reforming the Committee on Standards in Public Life. Actions also target corrupt insiders in high-risk roles: new, robust vetting measures will be rolled out, requiring new recruits to Border Force and Immigration Enforcement to disclose previous convictions, aiming to block organised crime groups from infiltrating frontline services. For local government in England, a new mandatory Code of Conduct for elected officials and a statutory Local Audit Office are planned to mitigate corruption risks. In a move designed to enhance detection, the government will also review and coordinate corruption reporting routes, including assessing the feasibility of introducing financial incentives for whistleblowers reporting economic crime.

On the global stage, the UK is seeking to boost international resilience by hosting a major Countering Illicit Finance Summit in 2026. Transparency is a key driver of this effort, with the Anti-Corruption Champion, Baroness Hodge, leading a new government review into wider asset ownership in the UK to expose how criminals funnel dirty money into the country. The government will also set clear expectations for its Overseas Territories and Crown Dependencies to introduce enhanced registers of beneficial ownership.

The successful implementation of the strategy relies on continuously improving the corruption evidence base. The overall policy definition guiding this comprehensive effort is clearly stated as: "the abuse of entrusted power for private benefit which usually breaches laws, regulations, standards of integrity and/or standards of professional behaviour". The Strategy Report is here. The press release with background information on which the Strategy is based is here. Transparency International UK has cautiously welcomed the Report.

NCAC Side Event Tackles Corruption–Crime Nexus in Conflict

At the 11th Conference of the States Parties to the UN Convention against Corruption, Transparency International Defence & Security and Besa Global hosted a side event exploring how corruption and organised crime fuel instability across the conflict cycle. Speakers from UNODC, UNDP, and the Global Initiative Against Transnational Organised Crime highlighted how corrupt and criminal networks drive violence, undermine peacebuilding, and exploit fragile settings. Building on past resolutions, the session emphasised UNCAC’s role as a tool for prevention and mitigation, urging closer cooperation among UN entities to strengthen rule of law and counter these threats before, during, and after conflict.

International Anti-Corruption Day Spurs Global Calls for Integrity and Action

Marking International Anti-Corruption Day on 9th December, global governing bodies and professional organisations reaffirmed their commitment to combating corruption, recognising it as a pervasive threat which undermines public trust, distorts the business environment, and weakens the rule of law globally. Decisive action is being taken, including the European Union’s provisional agreement on a new Directive to harmonise corruption offences, penalties, and prevention efforts, while simultaneously developing its first comprehensive EU Anti-Corruption Strategy, tentatively planned for 2026. In parallel, the UK published its Anti-corruption Strategy 2025, built upon three pillars: combating corrupt actors and illicit funds, tackling institutional vulnerabilities (such as by establishing a new ethics and integrity commission), and deepening international partnerships to build global resilience. The Council of Europe’s Group of States against Corruption (‘GRECO’) stressed that integrity is the foundation of democracy, with evaluation findings confirming the urgent need for ethical leadership and effective anti-corruption systems within central governments and law enforcement agencies. Furthermore, the International Bar Association highlighted the indispensable role of the legal profession in safeguarding institutions and strengthening accountability against global challenges like illicit financial flows. On the economic front, establishing robust integrity processes is increasingly championed as the "integrity advantage" for businesses, demonstrating that clear standards reduce risk, unlock growth, and deliver a performance premium which attracts investment.

The Council of Europe statement is here; European Commission statement here; World Economic Forum post is here; Parliamentary statement from UK Security Minister is here; and the International Bar Association statement is here.

Other Financial Crime

UK to Host Global Illicit Finance Summit in June 2026

The UK government has announced it will host the Illicit Finance Summit at Lancaster House in London on 23–24 June 2026, bringing together governments, civil society, and the private sector to combat the global flow of dirty money. The summit will focus on tackling illicit gold funding Russia’s war in Ukraine, property used for money laundering, and crypto-assets exploited by smugglers. Foreign Secretary Yvette Cooper emphasised that illicit finance is the “lifeblood of crime” and pledged tough international action, alongside new funding for investigative journalists and civil society groups to expose corruption.

Cybercrime

US Secures Extradition and Charges Against Russian-Linked Cybercriminal in Coordinated Crackdown

The US Justice Department (press release here) and the Environmental Protection Agency (press release here) jointly announced actions targeting two Russian state-sponsored cybercriminals, emphasising the US government’s coordinated approach to combating international cyber threats. A foreign national was indicted and extradited to the United States for their role in Russia-linked cyber schemes, marking a significant enforcement milestone. The case highlights the collaboration between federal agencies to disrupt malicious cyber activity, protect US infrastructure, and hold foreign actors accountable for attacks which threaten national security and public safety.