Episode 213

5th January – 8th January 2026

Sanctions

US Sanctions Four Entities and Tankers Linked to Venezuela’s Oil Sector

The US State Department announced sanctions on four entities and the blocking of four associated oil tankers for allegedly operating illegally within Venezuela’s oil sector and helping to finance Nicolás Maduro’s government, which the United States describes as illegitimate and corrupt. The action, taken under Executive Order 13850, is part of the Trump Administration’s broader effort to disrupt networks which enable Maduro and his associates to evade existing sanctions. The Department of the Treasury has released additional details in a corresponding press statement.

Russia Dispatches Naval Escorts as US Forces Pursue Sanctioned Oil Tanker

Russia has sent naval vessels to protect the oil tanker Marinera, formerly named Bella 1, as it crosses the North Atlantic, after the US attempted to seize it for allegedly violating sanctions by transporting Iranian and Venezuelan oil. The ship abruptly changed course, name, and flag after a failed US Coast Guard boarding attempt, prompting a tense standoff as American forces consider another operation despite Russia insisting the vessel is operating legally in international waters. The situation unfolds amid heightened geopolitical friction following the dramatic US seizure of Nicolás Maduro from Caracas and broader US efforts to block sanctioned oil shipments.

OFSI updates UK financial sanctions FAQs

The Office of Financial Sanctions Implementation (‘OFSI’) has updated its UK financial sanctions FAQs, adding FAQs 177–183 relating to General Licence INT/2025/5787748 on arbitration costs. The new FAQs explain when arbitrators and arbitration institutions should rely on the General Licence (FAQ 177), the circumstances in which it applies to non‑designated persons and their representatives (FAQ 178), the types of payments it covers (FAQ 179), and whether arbitrations conducted outside the UK fall within the scope of UK sanctions (FAQ 180). They also address whether surplus funds from one arbitration may be used as a deposit for another involving the same designated person (FAQ 181), clarify reporting requirements for payments made by designated and non‑designated persons towards arbitration costs (FAQ 182), and confirm which General Licence legal advisers representing designated persons in arbitrations should rely on to remain compliant (FAQ 183). The FAQs are here.

Money Laundering

UKFIU publishes 2024-2025 Annual Report

The UK Financial Intelligence Unit (‘UKFIU’) has published its 2024-25 annual report, highlighting a record-breaking year with 866,616 total Suspicious Activity Reports (‘SAR’s) received. The report indicates that some £382.6 million in assets was denied to suspected criminals through Defence Against Money Laundering (‘DAML’) requests, representing the highest annual total ever recorded, and a 59% increase over the previous year. The banking sector remains the most significant contributor to these efforts, accounting for approximately 83.7% of all reports submitted across both the new and old reporting platforms. This surge in asset recovery is credited to intensified collaboration between the regulated industry, law enforcement agencies, and government partners to tighten anti-money laundering controls.

Technological modernisation took centre stage this year as the UKFIU transitioned nearly all reporting to its new SAR Portal, which handled 97.86% of the year’s submissions and has already begun improving the quality of the intelligence received. On the global stage, the UK continues to function as a hub for financial security, receiving more inbound international intelligence requests than any other financial intelligence unit in the world. The report also details critical work in national security, noting that 1,101 SARs were disseminated to the Counter Terrorist Policing network to disrupt terrorist financing during this period. Looking forward, the unit is preparing for the wider rollout of the SAR Digital Service through 2025 and 2026, a move designed to equip law enforcement with advanced search and analytics tools to better exploit financial data. The Report is here, and the annexes are here.

FinCEN Pushes RIA AML Rule to 2028 After Industry Pressure

FinCEN has formally delayed the compliance deadline for its new anti‑money‑laundering and counter‑terrorist‑financing requirements for registered investment advisers and exempt reporting advisers, moving implementation from January 2026 to 1st January 2028. The agency said the two‑year extension will give it time to refine the rule and better tailor it to the diverse business models and risk profiles across the adviser sector, following significant industry feedback about the complexity, cost, and operational burden of building AML programmes. Critics, however, warn the delay prolongs gaps in US AML coverage and increases exposure to illicit finance risks, while FinCEN argues the revised timeline will support coordination with related regulatory initiatives and ease near‑term compliance costs.

Bribery and Corruption

Nigeria Showcases Bold Anti‑Corruption Reforms and Digital Innovation at UNCAC COSP11

At the 11th Conference of States Parties to the UN Convention against Corruption (‘COSP11’), Nigeria presented a sweeping package of reforms which highlight its renewed commitment to transparency, global cooperation, and technological modernisation. Led by the Attorney‑General, the delegation emphasised Nigeria’s exit from the FATF Grey List, unveiled a national database for forfeited assets, showcased cross‑border asset recovery successes, and demonstrated how digital tools, from judicial case‑management systems to youth‑focused AI chatbots, are strengthening accountability. Nigeria also advanced gender‑responsive anti‑corruption strategies, beneficial ownership transparency, and citizen‑driven oversight innovations, positioning the country as an increasingly trusted partner in global integrity efforts.

CyberCrime

UK Unveils £210m Cyber Action Plan to Strengthen Public‑Sector Defences

The UK government has launched a £210 million Cyber Action Plan to harden cyber‑resilience across public services, introducing a new Government Cyber Unit to coordinate risk management, accelerate incident response, and enforce minimum security standards across departments. The plan aims to protect increasingly digitised services, such as benefits, tax, and healthcare, from fast‑moving cyber threats, while a new Software Security Ambassador Scheme will promote stronger software supply‑chain security with support from major industry partners including Cisco, Palo Alto Networks, Sage, Santander, and NCC Group. The initiative is positioned as essential to maintaining public trust, safeguarding critical infrastructure, and unlocking billions in productivity gains as government services move online.