Episode 211

Sanctions

US Seizes Venezuela-Linked Tanker Tied to Terror Financing

The US Attorney’s Office for the District of Columbia announced the unsealing of a seizure warrant for the crude oil tanker M/T Skipper, intercepted by the Coast Guard on 10th December 2025, after departing Venezuela. Previously identified by the Treasury’s Office of Foreign Assets Control as part of an oil shipping network supporting Hizballah and Iran’s IRGC-Qods Force, the vessel was seized under federal terrorism asset laws. Officials emphasised the action as part of a broader sanctions enforcement effort, highlighting the government’s commitment to disrupting illicit financing channels and imposing costs on adversarial regimes.

US Treasury Lifts Sanctions on Brazilian Judge Alexandre de Moraes

The US Department of the Treasury has removed Global Magnitsky sanctions against Brazilian Supreme Court Justice Alexandre de Moraes and his wife, Viviane Barci de Moraes, following months of negotiations between Presidents Luiz Inácio Lula da Silva and Donald Trump. Moraes had overseen the conviction of former president Jair Bolsonaro, who was sentenced to 27 years in prison for attempting to overturn Brazil’s 2022 election. The sanctions, initially imposed in mid-2025, were part of Trump’s broader punitive measures against Brazil but were lifted as relations between the two leaders improved, including the rollback of tariffs. The decision marks a setback for Bolsonaro and his son Eduardo, who had lobbied in Washington for harsher US action, while Brazil’s Congress advances legislation which could shorten Bolsonaro’s prison term.

UK Joins European Defence Export Control Agreement

The UK has formally acceded to the Agreement on Defence Export Controls, joining France, Germany, and Spain to strengthen cooperation in defence trade. Led by the Ministry of Defence, the pact aims to streamline licensing processes for joint industrial programmes and supply chain activities, while preventing political interference in exports of jointly produced equipment. Key provisions include consultation mechanisms on licence refusals and a “de minimis” rule for components under 20% of a final system’s value. The Export Control Joint Unit will issue guidance and an open general export licence to support exporters under the agreement.

UK Sanctions Four Sudanese RSF Commanders for Atrocities in Darfur

On 12th December 2025, the UK added four Rapid Support Forces (‘RSF’) commanders, namely Gedo Hamdan Ahmed, Abdul Rahim Hamdan Daglo, Al-Fateh Abdullah Idris, and Tijani Ibrahim Moussa Mohamed, to its Consolidated List under the Sudan (Sanctions) (EU Exit) Regulations 2020. Each is accused of responsibility for grave violations of international humanitarian law, including mass killings of civilians, ethnically targeted executions, sexual violence, abductions, arbitrary detentions, and attacks on health facilities and humanitarian workers. The designations impose asset freezes and prohibit UK persons from dealing with their funds or economic resources, reinforcing international pressure on Sudan’s RSF leadership.

UK Extends General Licence for Russian Passenger Travel Until 2028

HM Treasury has extended the General Licence (INT/2022/1839676) permitting UK nationals and institutions to purchase passenger rail and air tickets from designated Russian providers, including Aeroflot, Rossiya Airlines, Ural Airlines, S7 Airlines, and Russian Railways, along with subsidiaries such as South Caucasus Railway CJSC. Originally issued in May 2022, the licence, which has been amended multiple times, most recently on 12th December 2025, allows transactions necessary for travel within Russia and between Armenia and Georgia, while maintaining safeguards against breaches of wider Russia sanctions. The licence now runs until 22nd May 2028, with HM Treasury retaining authority to vary, revoke, or suspend it.

UK removes sanctions duplications

The Office of Financial Sanctions Implementation has removed duplications from the sanctions list, but that the individuals concerned still remain designation under one regime: Iran, Iran (Nuclear), Syria, and Chemical Weapons regimes.

OTSI Sets Out What Makes Breach Reports Effective for UK Sanctions Compliance

The Office of Trade Sanctions Implementation (‘OTSI’) explains in a recently published blog post that good breach reporting is vital to enforcing UK trade sanctions and supporting national security. A useful report should clearly outline when the activity occurred, who was involved, what goods or services were provided, and how the matter connects to the UK. OTSI emphasises the importance of a straightforward narrative, identifying possible sanctions prohibitions, noting any contact with other authorities, and including supporting documents. Comprehensive reports reduce the need for follow-up and strengthen the UK’s ability to detect breaches, evasion, and wider patterns of non-compliance.

EU Council Sanctions Nine Shadow Fleet Enablers to Curb Russia's War Revenue

On 15th December 2025, the Council of the European Union imposed sanctions on five individuals and four entities for their role in facilitating Russia’s "shadow fleet," a covert network used to circumvent oil export restrictions and fund the war against Ukraine. The targeted individuals are businessmen linked to state-owned giants Rosneft and Lukoil, while the entities operate as shipping companies in Russia, the UAE, and Vietnam; together, they manage tankers which obscure the origin of Russian oil through dangerous and irregular shipping practices. These new restrictive measures, which include asset freezes and travel bans, are part of the EU's intensified effort to dismantle the logistical and financial networks which sustain Russia's military aggression.

EU Council Imposes Sanctions on 12 Individuals and 2 Entities Over Russian Hybrid Threats and Cyber Attacks

On 15th December 2025, the Council of the European Union adopted restrictive measures against 12 individuals and two entities in response to Russia's intensifying hybrid warfare tactics, specifically foreign information manipulation and malicious cyber activities. The sanctions target key figures within the Kremlin’s messaging apparatus, including foreign-policy analysts, online influencers, and even former Western military and police officers accused of spreading pro-Russian propaganda. Additionally, the measures hit the International Russophile Movement and the 142nd Separate Electronic Warfare Battalion, which is responsible for disrupting GPS signals in Europe, as well as members of the GRU's Unit 29155 and the cyber group Cadet Blizzard for their role in cyberattacks against Ukraine and NATO allies. This decision brings the total number of listed actors under the EU’s hybrid threat framework to 59 individuals and 17 entities, subjecting them to asset freezes and travel bans.

Fraud

Three City Fund Managers Convicted in £11.4m Fraud Targeting Libyan Wealth Fund

Three former fund managers, namely Frederic Marino, Yoshika Ohmura, and Aurelien Bessot, have been convicted of defrauding Libya’s sovereign wealth fund of approximately £11.4 million. Marino and Bessot established FMCP to manage investments but, with Ohmura’s support, diverted funds for personal gain through undeclared fees and shell companies. The Crown Prosecution Service and National Crime Agency proved the trio abused their positions of trust, prioritising lavish lifestyles over fiduciary duty. The convictions, secured at Southwark Crown Court after a re-trial, demonstrate the CPS’s commitment to tackling large-scale financial fraud.

FTC Warns of Rising Scam Losses Among Older Adults

The Federal Trade Commission’s latest annual report to Congress reveals that fraud losses reported by older adults quadrupled between 2020 and 2024, soaring to $2.4 billion, with many victims losing over $100,000 to investment, romance, and impersonation scams. The report highlights that social media is the most common contact method for investment fraud, and adults over 80 face the highest median losses, exceeding $1,600. While older adults report losing money at a lower rate than younger people, they are disproportionately affected by tech support, sweepstakes, romance, and government impersonation scams. The FTC highlights its enforcement actions, outreach campaigns like Pass It On, and partnerships under the Stop Senior Scams Act as part of its multipronged strategy to protect older Americans.

Treasury Issues Annual Holiday Advisory Warning of Surge in AI-Enabled Cyber Scams

On 15th December 2025, the US Department of the Treasury’s Office of Cybersecurity and Critical Infrastructure Protection released its annual consumer advisory regarding the heightened risk of cyber-enabled fraud during the holiday shopping season. The alert warns that financial losses from scams have reached unprecedented levels, costing consumers and institutions billions of dollars annually, as criminals increasingly use advanced technologies like artificial intelligence to automate schemes and convincingly impersonate trusted entities. Deputy Assistant Secretary Cory Wilson urged the public to remain vigilant, verify unexpected offers, and adopt protective measures to counter these evolving and sophisticated digital threats.

Money Laundering

FATF Flags Gaps in Belgium’s Fight Against Money Laundering and Terrorist Financing

The Financial Action Task Force’s 2025 mutual evaluation of Belgium found the country broadly aligned with international AML/CFT standards but highlighted serious weaknesses in effectiveness, particularly around virtual assets, resource shortages, and fragmented supervision. While Belgium has improved since its 2015 review introducing a beneficial ownership register and strengthening financial intelligence, the report notes insufficient oversight of high‑risk sectors, limited sanctions, and under‑resourced investigations. Terrorist financing risks linked to radicalised individuals and proliferation financing remain pressing concerns. Belgium has been placed in enhanced follow‑up and given a three‑year roadmap to allocate resources, strengthen supervision, and target organised crime networks.

Florida Man Convicted of Laundering $300 Million for Cartels

Alain Bibliowicz Mitrani, a 51‑year‑old Miami resident and dual citizen of France and Colombia, was convicted in Brooklyn federal court of leading a $300 million money laundering scheme for drug cartels, including the Sinaloa Cartel. Prosecutors proved that between 2020 and 2024, Mitrani used shell companies and a purported tech firm, Treebu, to disguise illicit proceeds, funnelling them through US banks and cryptocurrency transactions. He charged hefty commissions while funding a lavish lifestyle with luxury jewellery, a $4 million mansion, and international travel. Facing up to 70 years in prison, his conviction highlights the DOJ’s Operation Take Back America initiative to dismantle transnational criminal networks.

US and Bangladesh Launch Joint Money Laundering Bench Book

The US Embassy in Bangladesh announced the launch of a collaborative Money Laundering Bench Book, developed jointly by the United States and Bangladesh to strengthen judicial understanding and enforcement against financial crime. This resource is designed to provide judges, lawyers, and policymakers with practical guidance on money laundering cases, reinforcing both countries’ commitment to combating illicit finance and promoting transparency in the financial system.

RUSI Examines Vulnerabilities of Professional Football to Money Laundering

A December 2025 paper by the Royal United Services Institute (‘RUSI’) explores the susceptibility of professional football to money laundering, fraud, and corruption. The authors, Kathryn Westmore and Georgia Jones, highlight how the sport's significant financial flows, opaque corporate structures, and weak governance make it an attractive target for criminal actors. Citing the UK's National Risk Assessment and recent EU regulatory shifts, the paper discusses whether the UK should extend anti-money laundering (‘AML’) obligations to football clubs and agents. Drawing on insights from a roundtable of experts, the analysis points to specific risks such as inflated player transfer fees, ticket fraud, and the exploitation of financially unstable lower-league clubs. While there was no consensus on applying full AML regulations to the sector, experts agreed that more proportionate and effective oversight is essential to curb the influx of illicit funds.

Bribery and Corruption

TIGO Guatemala Pays $118M to Resolve US Foreign Bribery Probe

The US Department of Justice announced that TIGO Guatemala, a subsidiary of Luxembourg-based Millicom, paid over $118 million in November 2025 to settle charges of conspiring to violate the Foreign Corrupt Practices Act. Court filings revealed that between 2012 and 2018, the company engaged in a systematic bribery scheme involving monthly cash payments to Guatemalan lawmakers, some funded by laundered narcotrafficking proceeds, in exchange for favourable legislation. Under a two-year deferred prosecution agreement, TIGO Guatemala agreed to strengthen compliance, cooperate with ongoing investigations, and report remediation efforts, while receiving a reduced penalty for its later cooperation and remedial measures.

Global Anti-Corruption Summit Tackles Conflict, AI, and Political Transparency in Doha

The eleventh session of the Conference of the States Parties (CoSP11) to the UN Convention against Corruption (UNCAC), held under the theme “Shaping Tomorrow’s Integrity,” convened over 2,500 participants in Doha starting 15th December 2025, to address the urgent need to modernise anti-corruption strategies. United Nations Secretary-General António Guterres highlighted that corruption is not a victimless crime, as it fuels conflicts, breeds disillusionment, and entrenches inequalities. Corruption acts as both a root cause and an enabler of instability, allowing armed groups and political networks to capture institutions through measures like rigged procurement or diverted salaries, as seen in fragile settings like Haiti and Afghanistan. While new technologies like artificial intelligence (‘AI’) can accelerate financial corruption, they can also be harnessed for detection and prevention, provided there is adequate regulation.

The conference focused on strengthening global standards across various sectors, recognising that regulatory frameworks and technological guardrails must be agile enough to match the pace of corruption which crosses borders seamlessly. Resolutions considered by the Parties to the Convention aimed to address the role of AI in combating corruption and enhance transparency in the financing of political parties and election campaigns, which is a rare opportunity to set a global benchmark for political finance. Furthermore, participants called for tackling the corruption driving environmental crime and climate harm, such as illegal mining and deforestation. For the private sector, integrity is considered the "heart" of Environmental, Social, and Governance performance, which requires companies to implement robust integrity systems, including anti-bribery management and whistleblowing mechanisms, with the "tone from the top" being crucial. The UNCAC mandates strengthening internal controls, transparent accounting, and ethical conduct within companies to safeguard public resources and foster prosperity.

Market Abuse

UK FCA Launches Consultation on Cryptoasset Admissions, Disclosures, and Market Abuse Regime

The Financial Conduct Authority has opened consultation CP25/41 to regulate cryptoassets under the draft Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025. The proposals introduce admissions and disclosure requirements alongside a market abuse regime designed to strengthen safeguards, improve transparency, and tackle fraud, insider dealing, and manipulation. Targeting trading platforms, intermediaries, and firms serving UK consumers, the regime aims to raise standards, build investor confidence, and ensure fair competition while reinforcing the UK’s reputation for combining high regulatory standards with support for innovation. Responses are invited until 12th February 2026.

Other Financial Crime

AUSTRAC Intelligence Drives $24M Crime Seizure in Operation SMOKEHAZE

Australian authorities, supported by AUSTRAC’s financial intelligence and the Fintel Alliance, dismantled a sophisticated money laundering and smuggling network through Operation SMOKEHAZE. Triggered by suspicious cash activity in NSW and a separate discovery of four million illicit cigarettes in Fremantle, investigators linked the cases to uncover a major criminal enterprise. The operation resulted in the confiscation of over $24 million in crime proceeds, including cash, luxury goods, vehicles, and properties, highlighting the critical role of industry reporting in enabling law enforcement to disrupt complex financial crime.

AUSTRAC Urges Timely, Accurate 2025 Compliance Reporting

AUSTRAC has reminded current reporting entities that the 2025 compliance reporting period runs from 1st January to 31st March 2026, requiring businesses which provided designated services during 2025 to submit accurate reports through the updated AUSTRAC Online platform. Entities must ensure administrator access, multifactor authentication, and up-to-date contact details before lodging reports, with penalties possible for late submissions. Newly regulated industries beginning obligations in July 2026 are exempt from the 2025 report, while businesses ceasing services must still report if they operated at any point in 2025, or formally deregister to avoid future obligations.

AUSTRAC Strengthens Global Alliances and Pacific Partnerships to Combat Financial Crime

On 15th December 2025, AUSTRAC highlighted its expanded role in combating cross-border financial crime through enhanced international collaboration and regional leadership. The agency successfully championed Nauru’s membership in the Egmont Group, bringing the total number of Financial Intelligence Units to 183, and signed a new Memorandum of Understanding with Tonga. Beyond diplomatic wins, AUSTRAC has deepened its operational impact by deploying staff to key global hubs, sharing its advanced TAIPAN financial intelligence system with ten Pacific nations, and launching new training initiatives like the Financial Intelligence Tradecraft Training programme. These efforts, alongside co-chairing major regional plenaries in Fiji and the Philippines, demonstrate Australia’s commitment to strengthening the financial defences of its Pacific and Southeast Asian neighbours against organised crime.

UK Treasury to Regulate Cryptocurrency Markets by 2027

The UK Treasury is drafting legislation to bring cryptocurrencies under the Financial Conduct Authority’s oversight by 2027, aligning them with traditional financial products to boost transparency, consumer protection, and accountability. Chancellor Rachel Reeves emphasised that clear rules would strengthen the UK’s position as a global financial hub while curbing fraud and illicit activity. The move follows rising investment scams and high-profile cases, including the record seizure of 61,000 bitcoins linked to Zhimin Qian, and comes alongside plans to ban political donations made in digital currency.

MI6 Chief Warns of Expanding Russian Threat in New “Age of Uncertainty”

In her first major speech as head of MI6, Blaise Metreweli cautioned that the UK faces a new “age of uncertainty” marked by Russian assassination plots, sabotage, cyber-attacks, and disinformation campaigns. She described Russia’s “export of chaos” as a deliberate strategy under Vladimir Putin, stressing that the UK’s support for Ukraine will remain steadfast despite wavering US positions. Metreweli highlighted the need for mastery of both technology and human intelligence, warning that national security depends on guiding powerful technologies with wisdom. Her remarks were echoed by Defence Chief Richard Knighton, who highlighted the growing danger to NATO and urged society-wide engagement in defence.

UK Government Releases 2024 Counter-Terrorism Disruptive Powers Report

The UK Home Office has published its 2024 Counter-Terrorism Disruptive Powers Report, outlining how authorities have used legal tools to prevent, disrupt, and investigate terrorist activity. The report provides transparency on powers such as Terrorism Prevention and Investigation Measures, asset freezes, and travel restrictions, highlighting their role in safeguarding national security while balancing civil liberties.

Cybercrime

ICO Fines LastPass £1.2m Over 2022 Data Breach Impacting 1.6m UK Users

The UK Information Commissioner’s Office (‘ICO’) has fined LastPass UK Ltd £1.2 million following a 2022 data breach which exposed personal information of up to 1.6 million UK customers. The breach stemmed from two linked incidents in which hackers compromised employee devices, captured a master password, and accessed LastPass’ backup database containing names, emails, phone numbers, and website URLs. While customer vault passwords remained secure due to LastPass’ “zero knowledge” encryption system, the ICO found the company failed to implement robust security measures. Commissioner John Edwards emphasised that businesses must urgently review their systems to avoid leaving customers vulnerable.