Episode 219

26th January – 29th January 2026

Sanctions

Treasury Sanctions Vessels Linked to Iranian Oil Exports

The US Department of the Treasury announced new sanctions targeting nine vessels and several associated companies alleged to be part of Iran’s “shadow fleet,” which the department says has transported significant volumes of Iranian oil and petroleum products to foreign markets. According to the announcement, the revenue from these shipments supports Iranian government activities rather than public needs, and the action, taken under Executive Order 13902, aims to increase economic pressure on Iran amid its crackdown on protestors and restrictions on internet access. The designations block any US-linked property of the listed entities and vessels and prohibit US persons from engaging in related transactions, with potential civil or criminal penalties for violations. The State Department press release is here.

UN Expert Urges US to Lift Sanctions on ICC Officials

A United Nations human rights expert has called on the United States immediately to withdraw sanctions imposed on 11 judges and prosecutors of the International Criminal Court, warning that the measures undermine global justice and intimidate victims seeking accountability. Margaret Satterthwaite, the UN Special Rapporteur on the independence of judges and lawyers, said the sanctions pose a “grave threat” to judicial independence and send a chilling message to those pursuing redress for atrocities. She urged Washington to repeal the order and restore political and financial support for the ICC, stressing that justice personnel must be able to perform their duties free from coercion or retaliation.

OFSI Issues financial penalty to Bank of Scotland plc for sanctions breaches

The Office of Financial Sanctions Implementation (‘OFSI’) has fined Bank of Scotland plc £160,000 for breaching Russia‑related financial sanctions after the bank processed 24 payments worth £77,383.39 for a UK‑designated individual between 8th and 24th February 2023, thereby unlawfully dealing with and making funds available to a sanctioned person. The case demonstrates the need for firms to strengthen sanctions‑screening systems with enriched data, establish robust contingency and escalation procedures for automated screening, especially in higher‑risk contexts involving PEPs, regularly to update staff training to reflect evolving geopolitical and regulatory conditions, and to consider prompt voluntary disclosure of breaches, which can significantly reduce penalties; in this instance, a 50 per cent discount was applied for early self‑reporting.

OFSI amends Consolidated List before its retirement

The Office of Financial Sanctions Implementation (‘OFSI’) has made administrative amendments to the OFSI Consolidated List to ensure the Consolidated List and UK Sanctions List match before the Consolidated List is retired. The DPRK Notice is here, Iran (Nuclear) Notice is here, Russia Notice is here, and the Syria Notice is here. The UK Sanctions List is here.

Fraud

International Fraud Courier Sentenced to 18 Years for Preying on Elderly Americans

A 23‑year‑old Indian national has been sentenced to 18 years in federal prison for serving as a courier in a sprawling international fraud scheme which stole more than $6.6 million in cash and gold from elderly victims across multiple US states, according to the US Attorney’s Office for the Northern District of Florida. Prosecutors said Atharva Shailesh Sathawane travelled repeatedly to collect victims’ life savings, often after they were coerced into liquidating retirement accounts, before laundering the proceeds to co‑conspirators overseas. The scheme unravelled after one victim alerted authorities, triggering an undercover operation which led to Sathawane’s arrest. Officials described the case as part of a growing wave of elder‑targeted gold‑bar scams and urged the public to remain vigilant.

Bribery and Corruption

Former NATO Official and Turkish Contractor Charged in International Bribery Scheme

US prosecutors have unsealed an indictment charging a former NATO procurement official and a Turkish defence contractor with orchestrating a years‑long bribery scheme which allegedly corrupted construction contracts for both the US military and NATO operations. According to the Justice Department, contractor Bahadir Hatipoglu is accused of providing cash, luxury favours, and even assistance building a house for former official Ralf Grywnow in exchange for falsified performance reviews, confidential bid information, and preferential treatment on multimillion‑dollar projects. The two men were arrested in Lithuania and Poland and now face extradition to the United States, where they could receive up to 20 years in prison if convicted. Investigators say the case highlights ongoing efforts to protect the integrity of military procurement and combat corruption across international defence partnerships.

EU Reaffirms Anti‑Corruption Commitments at Global Conference

The European Union used the 11th Conference of States Parties to the UN Convention Against Corruption in Doha to highlight its ongoing efforts to combat corruption and illicit financial flows, emphasising the importance of strong legal frameworks, transparency, education, and civil‑society participation. EU representatives outlined progress on the forthcoming EU Anti‑Corruption Strategy and the new Directive on combating corruption by criminal law, while also supporting the launch of the second phase of the Implementation Review Mechanism. Despite differing views among participants, all eleven resolutions, including the Doha Declaration, were adopted by consensus, demonstrating broad international commitment to strengthening global anti‑corruption efforts.

EU Parliament Committee Backs Provisional Deal on Anti‑Corruption Directive

The European Parliament’s Civil Liberties, Justice and Home Affairs Committee (‘LIBE’) has endorsed a provisional agreement on the EU Anti‑Corruption Directive, marking a key step before a final plenary vote. The directive aims to harmonise criminal laws on corruption across the EU by establishing common definitions for offences such as bribery, misappropriation, and abuse of functions, while also setting binding standards for penalties and limitation periods. It also includes a prevention package requiring Member States to adopt measures to reduce corruption risks. MEP David Casa, the EPP Group’s lead negotiator, described the vote as a significant advance following months of negotiations and earlier rejections of weaker proposals.

OECD Warns Uneven Anti‑Bribery Enforcement Threatens Global Market Integrity

A new blog post from the OECD highlights fresh data showing that while enforcement of foreign bribery laws among the world’s largest economies has remained steady since 1999, progress is highly uneven across countries, raising concerns about fair competition and the rule of law. The post reports that 752 individuals and 315 companies have been sanctioned or convicted for foreign bribery to date, yet 16 participating countries have never recorded a single enforcement action. OECD experts argue that the widening gap, combined with slowing annual sanction rates, demonstrates the need for stronger political leadership, more consistent implementation, and deeper cooperation among governments, businesses, and civil society to sustain global anti‑corruption momentum.

Money Laundering

Chinese National Sentenced to 46 Months for Laundering $36.9m in US Crypto Investment Scam

A US federal court sentenced Jingliang Su, a Chinese national, to 46 months in prison for helping launder more than $36.9 million stolen from 174 Americans through a sophisticated digital asset investment scam run from Cambodian “scam centres”. Su and his co‑conspirators used fake cryptocurrency trading platforms, shell companies, international bank accounts, and stablecoin conversions to move victim funds overseas, ultimately channelling them into wallets controlled in Cambodia. In addition to prison time, Su must pay over $26.8 million in restitution. The case is part of the Justice Department’s broader effort to dismantle global scam‑centre operations and disrupt the cryptocurrency‑based laundering networks which enable them.

Croatia Strengthens Compliance with FATF Standards, MONEYVAL Says

Croatia has significantly improved its adherence to the Financial Action Task Force’s Recommendation 8 on non‑profit organisations, according to a new follow‑up report from MONEYVAL, the Council of Europe’s anti‑money‑laundering and counter‑terrorist‑financing monitoring body. The report finds Croatia now fully or largely compliant with 34 of the 40 FATF recommendations, with no areas rated non‑compliant, and concludes that the country has addressed most technical deficiencies identified in earlier evaluations. As a result, MONEYVAL has decided to remove Croatia from its fifth‑round follow‑up process ahead of the country’s scheduled sixth round onsite evaluation in 2030.

EU and EEA Financial Intelligence Units Advance Standardised Data Model to Strengthen Fight Against Financial Crime

A Council of Europe workshop in Brussels brought together more than 120 participants from EU and EEA Financial Intelligence Units, private‑sector AML/CFT specialists, EU institutions, and international bodies to refine a proposed Standardised Minimum Data Set (‘SMDS’) for suspicious transaction and activity reporting. Over two days, experts reviewed data points, definitions, validation rules, and sector‑specific requirements, which cover payments, remittance, crypto‑asset service providers, and DNFBPs, while also examining how the SMDS aligns with parallel EU and international data‑driven AML initiatives. RegTech firms contributed practical insights on automated monitoring, reporting, and secure information‑sharing. The project will now incorporate workshop feedback and prepare a revised draft for further consultation in early 2026.

Market Abuse

FCA Warns Consumers as New Securities Regime Takes Effect

The FCA’s update highlights the arrival of the new Public Offers and Admissions to Trading regime, stressing that high‑risk securities such as mini‑bonds and loan notes remain dangerous for most investors and are often promoted with misleading claims about safety and returns. The regulator urges consumers to verify whether firms are authorised, understand that protections are limited when dealing with unregulated entities, and remain alert to scams which exploit promises of high yields. It also notes that although the FCA has gained new powers under the regime, its ability to act against unauthorised firms is still constrained, making due diligence and scepticism essential for anyone considering these products.

Other Financial Crime

Home Secretary Unveils “British FBI” to Refocus Local Police on Everyday Crime

The UK government plans to create a new National Police Service, tragically described by various outlets parroting the Home Secretary as a “British FBI,” which will absorb major national functions such as counter‑terrorism, organised crime, and fraud investigations, freeing local forces to concentrate on rising everyday offences like shoplifting and phone theft. The new body will merge agencies including the National Crime Agency, purchase advanced technology centrally, and be led by a national police commissioner, forming part of a wider overhaul which may significantly reduce the number of police forces and introduce mandatory licensing for officers. Supporters argue the current system is outdated, while critics warn that large‑scale restructuring could weaken community policing and prove costly.

Government Receives Final Report Warning Fraud Could Soon Make Up Half of All Crime

The Home Office has received the second and final report of the Independent Review of Disclosure and Fraud Offences, which warns that fraud has rapidly evolved into one of the defining crimes of the digital age and could soon account for up to half of all crime in England and Wales. Chair Jonathan Fisher KC highlights systemic weaknesses across policing, the courts, and corporate accountability, noting that criminals now exploit vast digital data, overseas safe havens, and emerging technologies such as AI to operate at scale. The report identifies chronic delays, fragmented enforcement, and weak deterrence as major obstacles, and urges government to strengthen data‑sharing, modernise technology, improve prevention, and deepen international cooperation to match the global nature of the threat.

Professional launderer ordered to repay £5.6m after aiding massive China-based fraud

A judge at Southwark Crown Court has ordered Seng Hok Ling, a professional money launderer, to repay £5.6 million after helping fugitive fraudster Zhimin Qian move and disguise cryptocurrency linked to a vast investment scam in China which defrauded more than 128,000 victims of roughly £600 million. Ling converted large amounts of Bitcoin into other assets, transferred funds abroad, arranged false documents and accommodation for Qian, and helped her evade capture. The confiscation order, which is backed by an eight‑year default prison term, forms part of the UK’s largest-ever Bitcoin seizure and reflects ongoing efforts by the CPS and Metropolitan Police to strip organised criminals of illicit gains.