Episode 221

2nd February – 5th February 2026

Sanctions

US Treasury Announces New Sanctions on Iranian Officials and Entities

The US Department of the Treasury has issued a new round of sanctions targeting several Iranian government officials, security leaders, and financial entities, citing human rights concerns and alleged involvement in sanctions‑evasion activities. The designations include Iran’s interior minister, regional commanders within the Islamic Revolutionary Guard Corps, businessman Babak Morteza Zanjani, and two UK‑registered digital asset exchanges linked to him. According to Treasury, the action is part of its ongoing effort to address human rights abuses, restrict Iran’s access to global financial networks, and respond to the use of digital assets in ways the US views as facilitating prohibited transactions. The sanctions block US-controlled property of the designated individuals and entities and prohibit most transactions involving them under US jurisdiction.

OFAC Opens Path for US Firms to Resume Venezuelan Oil Exports

The new OFAC General License No. 46 (‘GL 46’) authorises established US entities to engage in a wide range of transactions involving the export, sale, and transport of Venezuelan-origin oil, easing long‑standing sanctions while imposing strict contractual, payment, and compliance conditions. The licence permits commercially reasonable oil‑for‑product swaps, requires payments to flow through designated government accounts, and mandates US governing law and dispute resolution for contracts. It excludes involvement by entities linked to Russia, Iran, North Korea, Cuba, or China, and does not authorise investment in Venezuelan oil fields or activity in the gas and petrochemical sectors. Although open‑ended, GL 46 can be revoked at any time, and companies must still navigate export controls and reporting obligations as US policy toward Venezuela continues to evolve.

UK Targets Iranian Officials Over Protest Crackdowns

The UK government has imposed sanctions on 10 Iranian officials and one organisation for their roles in violent crackdowns on peaceful protesters, including senior police chiefs, Revolutionary Court judges, IRGC commanders, and the Minister of the Interior. The measures, including asset freezes, travel bans, and director disqualifications, are part of a broader effort to hold Iranian authorities accountable for systemic human rights abuses, aligning the UK with recent actions by the EU, US, and G7 partners. The announcement emphasises the UK’s ongoing criticism of Iran’s human rights record and its commitment to coordinated international pressure. The press notice is here, and the official Notice is here.

Updates to OFSI General Licence and Reporting Guidance

On 2nd February 2026, the UK amended General Licence INT/2025/7328184 to expand the definition of “Revenue Authority” to include the Welsh Revenue Authority and Revenue Scotland and reminded users to review the full licence for detailed permissions and conditions. OFSI has also updated FAQ 133 to clarify reporting obligations for relevant firms when they refuse business to a designated person.

Australia Imposes New Sanctions on Iranian Officials Over Deadly Protest Crackdown

Australia has announced a new round of targeted financial sanctions against 20 individuals and three entities linked to Iran’s Islamic Revolutionary Guard Corps (‘IRGC’), citing the regime’s mass killings, violent suppression of peaceful protesters, and nationwide communications blackouts since late December 2025. The measures build on Australia’s earlier designation of the IRGC as a state sponsor of terrorism and expand a sanctions framework which now covers more than 200 Iranian individuals and entities. The government framed the action as part of its commitment to stand with the Iranian people and oppose the regime’s escalating campaign of repression and destabilisation.

Fraud

Warning Fraud Controls Must Strengthen as Part of the UK’s National Payments Vision

In a speech on the role of the Financial Conduct Authority (‘FCA’) and Payment Systems Regulator (‘PSR’) in delivering the National Payments Vision, David Geale, executive director, payments and digital finance and PSR managing director, emphasised that modernising the UK’s payments landscape must go hand‑in‑hand with stronger protections against fraud and abuse, highlighting the scale of authorised push payment (‘APP’) scams and the regulatory response designed to curb them. He points to the new reimbursement scheme, which is built on enhanced data‑sharing, improved analytics, and clearer liability rules, as evidence that coordinated action can materially reduce fraud losses, with 88% of claimed funds now returned to victims and overall claim volumes falling. Geale also stressed the importance of tools such as Confirmation of Payee, which now covers more than 99% of transactions and performs 26 checks per second, directly reducing misdirected payments and fraud attempts. Throughout the speech, he framed fraud prevention as a core pillar of trust and resilience in the national payments system, essential to ensuring that innovation, competition, and new technologies can scale safely.

Bribery and Corruption

Federal Jury Finds Two Brothers and Local Official Guilty in Ohio Fraud and Bribery Scheme

A federal jury in the Northern District of Ohio convicted two brothers and a public official for running an extensive fraud and bribery conspiracy which involved manipulating public processes for personal gain. According to the Justice Department, the group orchestrated a scheme which relied on corrupt payments and coordinated deception to secure benefits they were not entitled to receive, undermining public trust in local governance. The convictions follow a detailed investigation and now position the defendants for sentencing in federal court.

Market Abuse

Upper Tribunal Upholds FCA Findings of Lack of Integrity in Market Manipulation Scheme Targeting Qatar

The Upper Tribunal (Tax and Chancery Chamber) has issued its decision in the references made by Rangecourt SA (formerly Banque Havilland SA), Edmund Lloyd Rowland, and Vladimir Bolelyy against the Financial Conduct Authority (‘FCA’). The case arose from the 2017 creation of a "Disputed Document" which outlined an improper and potentially unlawful strategy to engage in market manipulation against the State of Qatar. At a time when the UAE and other states were imposing sanctions on Qatar, the document described a plan to put pressure on the Qatari currency to break its peg with the US dollar through tactics such as "wash trading" and "painting the tape" to give a false impression of market activity.

The Tribunal found that the Bank failed to conduct its business with integrity, ruling that the actions of its senior employees were so closely connected to their roles that their conduct was attributable to the firm. Edmund Lloyd Rowland, then a director and senior manager, was found to have lacked integrity by initiating the project, reviewing the document despite his persistent denials, and later attempting to orchestrate a cover-up by encouraging colleagues to lie and take sole responsibility. Similarly, Vladimir Bolelyy, a senior investment analyst, was found to have lacked integrity because he understood the improper nature of the strategy he helped draft and subsequently provided false information to both the Bank’s investigators and the FCA.

While the Tribunal upheld the core findings of misconduct, it directed the FCA to reduce the Bank's financial penalty from £10 million to £4 million, citing mitigating factors such as the Bank's extensive £2.5 million internal investigation and the fact that the improper strategy was never actually implemented. Conversely, the Tribunal confirmed the individual penalties: Edmund Rowland was fined £352,000 and Vladimir Bolelyy was fined £14,200, with both men being prohibited from performing functions related to regulated financial activities. Notably, the Tribunal made no adverse findings against David Rowland, the Bank’s Honorary President, concluding there was no reliable evidence he influenced the production of the document or the management of the Bank. Regarding Mr. Bolelyy’s recent autism diagnosis, the Tribunal accepted that he has the condition but concluded that it did not explain or excuse his sustained course of dishonest conduct during the investigations.

Other Financial Crime

New Blog Post Outlines Proposal for Market‑Based Financial Crime Detection Model

A blog post by Miles Kellerman introduces the concept of Licenced Detection Agents (‘LDA’s), a proposed market‑driven mechanism for improving financial crime detection. LDAs, which are private, licenced firms with regulated access to financial data, could help resolve what Kellerman calls the “Detection Trilemma,” balancing data access, incentives, and privacy in ways current gatekeeper‑based AML systems do not. By professionalising whistleblowing and rewarding successful detection, the model aims to enhance enforcement outcomes while reducing conflicts of interest and limiting direct state access to personal financial information. The blog post is here, and here the link to the forthcoming article in the Berkeley Business Law Journal where the idea is discussed in greater depth. The link is to the Social Science Research Network and so is open access, as it seems the article will be when it is eventually published.

US and Indonesia Complete Nationwide Training Effort to Strengthen Financial Crime Enforcement

The United States and Indonesia have concluded a multi‑year series of Asset Tracing and Recovery Workshops designed to improve Indonesia’s capacity to investigate and recover assets linked to financial and economic crimes, including cases affecting US interests. The final session in Jakarta brought together investigators, prosecutors, and analysts from multiple provinces for training on money‑laundering laws, financial‑investigation techniques, digital forensics, and cross‑border cooperation. According to the US Embassy, the programme has enhanced inter‑agency coordination, expanded skills in tracing illicit funds, including those involving cryptocurrency, and contributed to progress in several public‑sector financial crime cases.