Episode 212

19th December – 21st December 2025

Sanctions

OFAC Fines Exodus $3.1M for Iran Sanctions Violations

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has announced a $3,103,360 settlement with Exodus Movement, Inc. for 254 apparent violations of Iran sanctions. From October 2017 to January 2019, Exodus supported Iranian users in accessing digital asset exchanges via its wallet software. OFAC determined the violations were not voluntarily self-disclosed, with 12 deemed egregious, leading to the substantial penalty.

Treasury Targets Iranian Shadow Fleet with New Sanctions

On 18th December 2025, the US Department of the Treasury’s Office of Foreign Assets Control announced sanctions against 29 vessels and multiple shipping companies linked to Iran’s petroleum exports through deceptive practices. The measures, taken under Executive Order 13902, block vessels flagged in jurisdictions such as Palau, Panama, Cook Islands, Barbados, and Jamaica, and designate firms across the UAE, Panama, India, and the Marshall Islands. Egyptian businessman Hatem Elsaid Farid Ibrahim Sakr and his companies were also sanctioned for facilitating shipments in coordination with Iranian entities. The action underscores US efforts to restrict Iran’s oil revenue and enforce compliance with sanctions regulations.

Treasury Sanctions Cartel de Santa Rosa de Lima for Fuel Theft and Violence

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has sanctioned the Mexican Cartel de Santa Rosa de Lima (‘CSRL’) and its leader, Jose Antonio Yepez Ortiz (“El Marro”), for large-scale fuel and oil theft operations in Guanajuato, Mexico. CSRL’s activities, including pipeline tapping, refinery theft, and cross-border smuggling, have fuelled deadly conflict with rival cartel CJNG, undermined legitimate US energy companies, and cost Mexico billions in lost revenue. Despite El Marro’s imprisonment, he continues directing cartel operations, forging alliances with other criminal groups. The sanctions block CSRL’s assets in the US and prohibit American entities from engaging in transactions with them.

Department of Justice Unseals Indictments Against Over 70 Members of the Tren de Aragua Terrorist Cartel

On 18th December 2025, the US Department of Justice announced the unsealing of multiple indictments against more than 70 leaders and members of Tren de Aragua (‘TdA’), a designated foreign terrorist organisation. These federal actions across five states, namely Colorado, Nebraska, New Mexico, New York, and Texas, target the group's involvement in violent crimes including murder, kidnapping, extortion, and money laundering, as well as drug and firearms trafficking. Since 20th January 2025, the Department has federally indicted over 260 members of the organisation through the expanded Joint Task Force Vulcan. Significant charges include the indictment of TdA’s top leader, Hector Rusthenford Guerrero Flores, for directing transnational acts of terrorism and cocaine transport, alongside cases involving a multimillion-dollar ATM hacking conspiracy in Nebraska and RICO charges in Colorado related to armed jewellery store robberies. Federal authorities, including the FBI and DEA, emphasised that these efforts aim to dismantle the cartel's financial networks and eliminate its presence as a direct threat to national security.

US Announces Sanctions on Two ICC Judges

The US Department of State has announced sanctions on International Criminal Court judges Gocha Lordkipanidze of Georgia and Erdenebalsuren Damdin of Mongolia, citing their involvement in recent ICC decisions related to Israel. The measures were taken under Executive Order 14203, which allows sanctions against individuals connected to ICC actions involving US or Israeli nationals. The Department emphasised that neither the United States nor Israel are parties to the Rome Statute and outlined plans to continue responding to ICC activities with legal and diplomatic measures.

UK Adds 24 Individuals and Entities to Russia Sanctions List

On 18th December 2025, the UK updated its Russia (Sanctions) (EU Exit) Regulations 2019, designating 24 new individuals and entities for asset freezes and trust service restrictions. The measures target persons and companies suspected of supporting Russia’s government or destabilising Ukraine, particularly through involvement in the Russian energy sector or by providing goods, technology, and financial services that could undermine Ukraine’s sovereignty. Those subject to sanctions must have their accounts frozen, are prohibited from receiving funds or trust services, and all findings must be reported to the Office of Financial Sanctions Implementation. Failure to comply may constitute a criminal offence.

UK Updates Russia Sanctions: RBRU Specialised Depository Remains Under Asset Freeze

On 19th December 2025, the UK amended its Russia (Sanctions) (EU Exit) Regulations 2019, confirming that the Limited Liability Company Responsibility of "RBRU Specialised Depository" remains subject to an asset freeze and additional restrictions. The measures include prohibitions on correspondent banking relationships and trust services, reflecting the entity’s involvement in supporting the Russian government through activities in the financial services sector. The designation, first imposed in May 2025, underscores the UK’s continued enforcement of sanctions against entities benefiting from or aiding Russia’s strategic industries.

UK Expands Syria Sanctions List with New Individuals and Militias

On 19th December 2025, the UK updated its Syria (Sanctions) (EU Exit) Regulations 2019, adding six individuals and three militia groups to the Consolidated List. Those designated, including Mohammed Hussein Al-Jasim, Sayf Al-Din Boulad, Ghaith Suleiman Dalla, Miqdad Loay Fatiha, Mudallal Khoury, Imad Mtanyus Khoury, and the Hamza, Sultan Murad, and Sultan Suleiman Shah Divisions, are now subject to asset freezes. The designations cite involvement in repressing Syria’s civilian population, violations of international humanitarian law, and activities supporting or benefitting the Assad regime, including chemical weapons-related operations and financial services.

UK Grants Temporary Licence for Russian Oil Firms to Wind Down

HM Treasury’s Office of Financial Sanctions Implementation has issued a general licence allowing PJSC Russneft, PJSC Tatneft, LLC Rusneftegaz Group, LLC NNK-Oil, and their subsidiaries to wind down transactions until 31st January 2026. The licence, effective from 18th December 2025, permits individuals, companies, and UK financial institutions to close out positions and conduct necessary activities with these designated parties, provided records are kept for six years. It does not override other prohibitions under the Russia (Sanctions) Regulations 2019, and HM Treasury retains the right to vary, revoke, or suspend the licence at any time.

OFSI Updates Two General Licences

On 17th December 2025, OFSI amended General Licences INT/2025/7628424 and INT/2025/7323088, updating the definition of “IT Providers,” revising permissions under INT/2025/7628424, and clarifying the definition of “Legal Services” in INT/2025/7323088. Users are advised to review the full licences and FAQ 175 for detailed guidance.

UK Expands OFSI General Licence for Russian Energy Projects

On 17th December 2025, OFSI amended General Licence INT/2025/5635700, broadening permissions to cover shareholder rights and payments linked to Exempt Projects where the share registrar is a designated person. The update also added the Zohr project to the list of Exempt Projects, following earlier expansions to include ventures such as the Caspian Pipeline Consortium and Shah Deniz. The licence continues to allow UK persons and institutions to conduct limited business operations with designated Russian subsidiaries, provided activities remain strictly tied to the listed projects and comply with record‑keeping requirements.

UK Issues Interim Licence Allowing Limited Payments by Designated Iranian Entities

HM Treasury has granted an interim general licence (INT/2025/7628424) under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, effective from 23rd October 2025 to 22nd April 2026. The licence permits designated Iranian entities and their UK subsidiaries to make restricted payments for salaries, pensions, IT services, and accountancy fees to UK employees, directors, and service providers, provided transactions are processed through UK-regulated institutions. Strict reporting and record-keeping obligations apply, and payments cannot be made directly or indirectly to designated persons.

UK Issues Final Ultimatum to Abramovich Over £2.5bn Chelsea Sale Funds

The UK Government has demanded that Roman Abramovich transfer £2.5 billion from the 2022 sale of Chelsea Football Club to aid victims of Russia’s war in Ukraine, warning of imminent legal action if he fails to comply. The funds, frozen since the sale to Todd Boehly’s consortium, have been stalled amid disputes over whether they should benefit only Ukrainians or all victims of the conflict. Chancellor Rachel Reeves, Foreign Secretary Yvette Cooper, and Prime Minister Keir Starmer, stressed that the money must reach Ukrainians urgently, with ministers prepared to enforce the commitment in court.

EU Sanctions 41 Additional Vessels Linked to Russia’s Shadow Fleet

On 18th December 2025, the Council of the European Union imposed restrictive measures on 41 vessels identified as part of Russia’s “shadow fleet,” bringing the total number of designated ships to nearly 600. These vessels are accused of helping circumvent the oil price cap, supporting Russia’s energy sector, transporting military equipment, or moving stolen Ukrainian grain and cultural goods. The sanctions ban port access and related maritime services, reinforcing earlier EU actions against shadow fleet enablers and highlighting the Union’s commitment to using international maritime law to counter threats and protect critical undersea infrastructure.

Fraud

CEO, CFO, and COO Charged in $1 Billion Tricolor Auto Collapse

Federal prosecutors in the Southern District of New York have charged the CEO, CFO, and COO of Tricolor Auto Group in connection with the company’s billion-dollar collapse. The executives allegedly engaged in fraud and misrepresentation which misled investors and customers, ultimately leading to massive financial losses. The Department of Justice asserts that the scheme involved falsified records and deceptive practices, contributing to one of the largest auto finance failures in recent years.

Money Laundering

APRA and AUSTRAC Crack Down on Bendigo Bank Over Risk Failures

APRA and AUSTRAC have taken joint action against Bendigo and Adelaide Bank after a Deloitte review found significant gaps in its money laundering and non-financial risk management. APRA has imposed a $50 million operational risk capital add‑on and ordered a root cause analysis, while AUSTRAC has opened an enforcement investigation into compliance with the Anti‑Money Laundering and Counter‑Terrorism Financing Act. Regulators stressed that although the bank remains financially sound, urgent reforms are needed to address systemic weaknesses in its risk culture.

Bribery and Corruption

US Customs Officer Charged in Bribery Scheme

The US Attorney’s Office for the Southern District of New York has announced charges against a US Customs and Border Protection officer for bribery offences. Prosecutors allege the officer accepted payments in exchange for improperly facilitating the entry of goods and individuals into the United States, undermining the integrity of border enforcement. The case highlights ongoing efforts by federal authorities to combat corruption within agencies responsible for safeguarding national security and trade.

OECD Urges Colombia to Fix Foreign Bribery Enforcement Failures

The OECD Working Group on Bribery’s Phase 4 report warns that Colombia must urgently address major deficiencies in its foreign bribery framework, noting weak detection, lack of prosecutions of individuals, poor coordination among agencies, and inadequate whistleblower protections. While Colombia has sanctioned two companies and strengthened anti-money laundering compliance, the report highlights disengagement from OECD obligations and risks to prosecutorial independence. The OECD calls for stronger inter-agency cooperation, comprehensive whistleblower safeguards, and renewed commitment to enforcement, with Colombia required to present an action plan in 2026 and report on progress by 2027.

Market Abuse

Four Convicted in $600K Insider Trading Scheme

A federal jury in Newark, New Jersey convicted Rouzbeh “Ross” Haghighat, Kirstyn Pearl, Seyedfarbod “Fabio” Sabzevari, and James Roberge for insider trading tied to a $3.2 billion pharmaceutical merger. Haghighat, a board director, leaked confidential acquisition details in 2023, enabling the group to buy shares before the deal’s public announcement and reap over $600,000 in illicit profits. The defendants face sentencing in May 2026, with Haghighat exposed to a maximum penalty of 380 years in prison.

Other Financial Crime

SFO Secures £928,000 Confiscation Order Against Fraudster David Kennedy

The UK Serious Fraud Office has obtained a £928,479 confiscation order against David Kennedy, a former Axiom Legal Financing Fund manager convicted of running a £100+ million fraud with partner Timothy Schools. Kennedy used investor funds to finance properties, a villa in Tenerife, luxury cars, and savings abroad. Already serving an eight-year sentence, he must repay victims within three months or face up to six and a half more years in prison. This follows earlier confiscation orders against Schools and his ex-wife, marking considerable progress in returning stolen assets to defrauded investors.