Episode 210

12th December – 14th December 2025

Sanctions

UK Government Removes Munir Al Qubaysi from Iraq Financial Sanctions List

On 10th December 2025, the UK's Office of Financial Sanctions Implementation (‘OFSI’) issued a Notice regarding the Iraq (Sanctions) (EU Exit) Regulations 2020, announcing the removal of Munir Al Qubaysi (Group ID: 8278) from the Consolidated List. As a result of this delisting, Al Qubaysi, who was previously sanctioned under the regime targeting the former Government of Iraq and its associates, is no longer subject to an asset freeze. The notice follows updates to the UK Sanctions List by the Foreign, Commonwealth and Development Office and provides relevant administrative details and contact information for further enquiries. This decision aligns with the United Nations Security Council Committee on 9th December 2025, which removed Al Qubaysi from its sanctions list.

UK Sanctions China-Based Firms Over Reckless Cyberattacks

The UK government has sanctioned two China-based technology companies, Sichuan Anxun Information Technology Co. Ltd (i-Soon) and Integrity Technology Group Incorporated, for conducting reckless and indiscriminate cyberattacks against more than 80 government and private IT systems worldwide, including UK public sector networks. The National Cyber Security Centre assessed that these firms are part of a wider ecosystem of private actors supporting Chinese state-linked cyber operations. The move follows earlier exposures of companies tied to the Salt Typhoon espionage campaign and demonstrates the UK’s commitment to challenging threats while promoting responsible state behaviour in cyberspace.

US Treasury Sanctions Maduro Regime Insiders and Shipping Firms Over Venezuela’s Oil Sector

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has imposed sanctions on three nephews of Venezuelan First Lady Cilia Flores, a Maduro-linked businessman, and six shipping companies for supporting Nicolás Maduro’s regime through drug trafficking and oil trade. The action reverses previous concessions under the Biden administration and targets vessels engaged in deceptive practices to transport Venezuelan oil. These measures block all US-linked assets of designated individuals and entities, aiming to disrupt financial flows to Maduro’s administration.

Fraud

Derby Businessman Jailed for £80,000 Bounce Back Loan Fraud

Temidola Ojelabi, a 43-year-old businessman from Derby, has been sentenced to two years and four months in prison and banned as a company director for eight years after fraudulently obtaining £80,000 through two Bounce Back Loan applications during the Covid pandemic. Instead of using the funds to support his company, Platinum Gates Limited, Ojelabi transferred the money to his personal account and spent it on online trading platforms. The Insolvency Service described his actions as a blatant abuse of taxpayer money, and efforts are underway to recover the funds under the Proceeds of Crime Act.

Money Laundering

FATF and APG Mutual Evaluation Finds Malaysia Strong on AML Framework but Weak on Prosecutions

The 2025 FATF and Asia/Pacific Group mutual evaluation of Malaysia highlights significant progress in strengthening anti-money laundering, counter-terrorist financing, and proliferation financing measures since 2015, including improved legal frameworks and supervisory systems. However, Malaysia struggles to convert money laundering investigations into prosecutions and convictions, despite recovering €8 billion largely linked to the 1MDB case. Key risks include corruption, fraud, smuggling, and terrorist financing due to regional proximity. While financial institutions show substantial compliance, designated non-financial businesses need stronger preventive measures. Malaysia has improved international cooperation and terrorist financing enforcement but must enhance sanctions, increase prosecutions, and address gaps in beneficial ownership transparency. A three-year roadmap of recommended actions has been issued, with progress to be reported to FATF and APG.

Dutch FIU Chief Hennie Verbeek-Kusters Confirmed for AMLA Executive Board

EU lawmakers are set to formally appoint Hennie Verbeek-Kusters, head of the Netherlands Financial Intelligence Unit (FIU) and former Egmont Group Chair, to the AMLA Executive Board next week. Her selection addresses concerns about under-representation of FIUs on the board and brings extensive experience in global anti-money laundering efforts. Verbeek-Kusters has led major initiatives, including IT modernisation for FIUs, strategic planning, and expanding Egmont membership, while championing gender diversity in leadership. Her appointment follows a private session with MEPs where she impressed lawmakers and will strengthen FIU representation at the highest level of EU financial crime governance.

ICPC Chairman Urges Nigerian Lawyers to Tighten AML Compliance and Client Due Diligence

Dr. Musa Adamu Aliyu, Chairman of Nigeria’s Independent Corrupt Practices and Other Related Offences Commission (‘ICPC’), has called on legal practitioners to rigorously vet clients and their sources of wealth to prevent the profession from being exploited for money laundering and terrorism financing. Speaking at a Kano Bar Association seminar on new anti-money laundering obligations, he stressed recent amendments to the Rules of Professional Conduct requiring lawyers to report suspicious transactions and apply enhanced due diligence, especially in high-risk cases like property purchases and company formations. Aliyu also advocated for a joint national sensitisation programme by ICPC, EFCC, SCUML, and NFIU to ensure uniform compliance and strengthen public trust in the legal profession.

EU Blacklists Russia Over AML Deficiencies, But Ordinary Citizens Will Bear the Brunt

The European Commission has added Russia to its list of countries with strategic anti-money laundering and counterterrorist financing deficiencies, which is the EU equivalent of the FATF blacklist, following lobbying by Kyiv and several European states. While intended to pressure Moscow, the move will barely affect the Kremlin or major sanctioned businesses, which have adapted through offshore schemes and third-country networks. Instead, the decision imposes onerous enhanced due diligence requirements which will hit Russian nationals legally residing in the EU, small and medium-sized firms engaged in legitimate trade, and European tech startups with Russian roots. These measures risk driving transactions into informal channels, boosting the shadow economy, and making the financial system less transparent. Ultimately, the blacklist serves more as a political signal than an effective economic sanction.

Bribery and Corruption

COSP11 in Doha: Global Push to Combat Corruption and Restore Integrity

The 11th session of the Conference of the States Parties to the UN Convention against Corruption (‘COSP11’) will convene in Doha, Qatar, from 15–19 December 2025, offering nations a critical platform to strengthen global anti-corruption efforts. Corruption continues to erode public trust and drain resources, with one in five people worldwide asked to pay bribes in 2024. The UN reports that $16.9 billion in stolen assets have been recovered, underscoring the impact of robust laws and international cooperation. COSP11, under the theme “Shaping Tomorrow’s Integrity,” will address emerging threats, promote policy reforms, and enhance collaboration among governments, civil society, and the private sector. Reducing corruption could boost global tax revenues by $1 trillion, making decisive action more urgent than ever.

Other Financial Crime

FCA Fines Nationwide £44m for Financial Crime Control Failures

The Financial Conduct Authority (‘FCA’) has fined Nationwide Building Society £44.1m for failing to maintain adequate anti-financial crime systems and controls between 2016 and 2021. Nationwide’s weaknesses included outdated due diligence, poor risk assessments, and ineffective monitoring of personal current accounts, some of which were misused for business activity. These failings left the society unable to properly identify or manage money laundering risks, with one case involving £27.3m in fraudulent Covid furlough payments. Although Nationwide began a transformation programme in 2021, the FCA stressed that banks and building societies must remain vigilant in combating financial crime.

FCA Launches Firm Checker to Combat Financial Scams

The UK Financial Conduct Authority (‘FCA’) has introduced Firm Checker, a new tool designed to help consumers verify whether financial services firms are properly authorised and have the correct permissions, reducing the risk of falling victim to investment or pensions-related scams. FCA research found that around 800,000 people reported losses to such frauds in the year to May 2024, with many scams originating via social media, phone calls, or messaging apps. By confirming firm details against the FCA register, consumers can better protect themselves, while authorised firms must meet FCA standards and provide access to protections such as the Financial Ombudsman Service and the Financial Services Compensation Scheme.

Organised Crime Exploits Mining Sector in Latin America and Caribbean

The United Nations Office on Drugs and Crime (‘UNODC’) warns that organised crime, money laundering, and corruption are deeply infiltrating the mining sector across Latin America and the Caribbean, where vast reserves of lithium, copper, cobalt, and gold attract global investment. Criminal groups exploit weak oversight by using bribery, intimidation, and front companies to secure licences, launder illicit proceeds, and distort markets, undermining governance and deterring legitimate foreign direct investment. UNODC highlights the urgent need for regional cooperation, noting that minerals often cross multiple jurisdictions, making coordinated responses essential. Through its Regional Corruption and Economic Hub, UNODC is supporting 17 countries with an action plan of 28 activities, including training, forfeiture practices, and secure information-sharing, to strengthen institutional coordination and restore investor confidence.

Cybercrime

NCSC Cyber Deception Trials Reveal Key Insights and Next Steps

The UK’s National Cyber Security Centre (‘NCSC’) has shared findings from its year-long cyber deception trials involving 121 organisations and 14 solution providers. The trials tested whether deception techniques, such as honeypots, can uncover hidden compromises, detect new attacks, and influence attacker behaviour. Results show cyber deception can be effective but requires strategic planning, clear terminology, and proper configuration to avoid risks. Most organisations prefer to keep its use covert, despite evidence that disclosure can deter attackers. NCSC plans to develop guidance, standardise language, and explore a new Active Cyber Defence service to help organisations adopt cyber deception, which can impose costs on adversaries and strengthen national cyber resilience.