Episode 218

23rd January – 25th January 2026

Sanctions

Treasury Targets Hamas’s Hidden Support Network

The US Treasury announced new sanctions against a network of Gaza-based organisations and an overseas political group which officials say secretly operate on behalf of Hamas, diverting charitable donations and using nonprofit fronts to fund the group’s military wing. The designations, made under counterterrorism authorities, aim to expose how Hamas embeds itself within civilian institutions, disrupt its financing channels, and protect legitimate humanitarian aid efforts, particularly as international partners prepare for Gaza stabilisation efforts.

US Treasury Sanctions Major Costa Rica–Based Cocaine Trafficking and Money Laundering Network

On 22nd January 2026, the US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) sanctioned one of the Caribbean’s largest cocaine trafficking networks, designating five Costa Rican nationals and five Costa Rica‑based entities for their roles in large‑scale narcotics trafficking and money laundering. The network, led by Luis Manuel Picado Grijalba, is responsible for transporting multi‑ton quantities of cocaine from Colombia through Costa Rica for distribution to the United States and Europe, using key ports such as Moín as transshipment hubs. The action, taken under Executive Order 14059, follows a coordinated investigation involving US and Costa Rican authorities and targets not only trafficking operations but also a family‑run money laundering structure which used front businesses to conceal illicit proceeds.

UK to Retire OFSI Consolidated List as Single Sanctions List Goes Live

The OFSI Consolidated List of Asset Freeze Targets will close on 28th January 2026, after which the UK Sanctions List becomes the sole authoritative source for all UK sanctions designations with no structural changes to the list itself.

Fraud

City of London Police Launch “Report Fraud,” a Major Overhaul of the UK’s Fraud and Cyber‑Crime Reporting System

The City of London Police has launched Report Fraud, a new national service designed to modernise and unify how victims and businesses across England, Wales and Northern Ireland report fraud and cybercrime, strengthening intelligence-sharing and law‑enforcement response across the UK. The platform creates a single gateway for reporting, triage and investigation, enabling faster identification of serious cases, improved victim support, and closer collaboration with industry and government. Leaders describe it as the most significant upgrade to the UK’s anti‑fraud capability, backed by major investment from the City of London Corporation and accompanied by a national awareness campaign promoting the message that “Every Report Counts.”

SFO Charges Two Former Executives as Safe Hands Plans Fraud Investigation Advances

On 22nd January 2026, the Serious Fraud Office charged Richard Wells, former director of SHP Capital Holdings, and senior executive Neil Debenham with conspiracy to defraud following its investigation into the collapse of Safe Hands Plans Ltd, a prepaid funeral plan provider which ceased trading in 2022. The company, which failed to secure the regulatory approval required to continue selling plans, left around 46,000 customers, many of whom were vulnerable, financially exposed and uncertain about future funeral arrangements. The charges mark a significant step in an investigation launched in October 2023, with both defendants due to appear at Westminster Magistrates’ Court on 5th February 2026.

Bribery and Corruption

IMF Launches Governance and Corruption Diagnostic for Nepal

An IMF technical mission has completed its initial scoping visit to Nepal to prepare a comprehensive Governance and Corruption Diagnostic, engaging with government institutions, oversight bodies, civil society, and development partners to map vulnerabilities in fiscal governance, financial‑sector oversight, rule of law, and anti‑corruption frameworks. The forthcoming full mission will deepen this work and produce a diagnostic report outlining key weaknesses and a sequenced reform plan aimed at strengthening integrity and improving economic outcomes.

Money Laundering

Azerbaijan Upgrades Its Anti‑Money‑Laundering Defences

A new MONEYVAL follow‑up report finds that Azerbaijan has significantly strengthened its framework for combating money laundering and terrorist financing, earning upgraded ratings on key FATF recommendations related to nonprofit oversight, wire transfers, beneficial ownership transparency, financial‑sector supervision, and statistical tracking. The country is now compliant or largely compliant with 36 of 40 FATF standards, with no areas rated non‑compliant, though it will remain under enhanced follow‑up and is expected to report further progress within a year.

TD Bank Employee Admits Role in $26 Million Colombia ATM Laundering Scheme

A former TD Bank employee in New Jersey, Oscar Marcel Nunez‑Flores, pleaded guilty to taking bribes and using his position to help a money‑laundering network move more than $26 million from the United States to Colombia by opening shell‑company accounts, issuing hundreds of debit cards, and enabling over 120,000 ATM withdrawals abroad. Federal investigators from DEA, IRS‑CI, and FDIC‑OIG described his actions as a serious breach of trust which allowed transnational criminal organisations to exploit the US financial system, and Nunez now faces up to 50 years in prison across the two charges.

Estonia Strengthens Anti‑Money Laundering and Counter‑Terrorism Financing Framework, MONEYVAL Finds

In a follow‑up report released on 22nd January 2026 by MONEYVAL, the Council of Europe’s anti‑money laundering monitoring body, concludes that Estonia has made significant progress in strengthening its legal and institutional framework to combat money laundering, terrorist financing, and the financing of weapons of mass destruction. The report highlights marked improvements in the implementation of targeted financial sanctions related to proliferation financing and the regulation of new technologies, with Estonia now rated compliant or largely compliant with most of the FATF’s 40 recommendations and none deemed non‑compliant. While the country remains under MONEYVAL’s enhanced follow‑up process, it is expected to report further progress within a year, reflecting continued momentum in addressing financial crime risks.