Episode 223

9th February – 12th February 2026

Sanctions

US Targets Iranian Oil Shippers and Petrochemical Traders

The US Department of State has imposed sanctions on a wide network of entities, individuals, and vessels involved in transporting or trading Iranian-origin crude oil, petroleum, and petrochemical products, citing their role in sustaining revenue streams which support Iran’s destabilising activities. The action identifies 14 “shadow fleet” vessels and designates 15 shipping and management companies, along with several petrochemical traders and associated individuals, under Executive Order 13846. According to the State Department, the targeted actors used deceptive maritime practices to move millions of barrels of Iranian commodities through multiple jurisdictions. The designations block property under US jurisdiction and prohibit US persons from engaging in related transactions, with the stated aim of disrupting illicit energy exports rather than punishing for its own sake.

OFAC Unveils Online Portal to Streamline Voluntary Self‑Disclosures

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has launched a new online Voluntary Self‑Disclosure Portal designed to make it easier and faster for organisations and individuals to report potential sanctions violations. The system offers a secure, centralised method for submitting disclosures, with quicker acknowledgments, clearer communication during reviews, and a more user‑friendly interface. OFAC is encouraging all parties to transition to the portal, which aims to improve efficiency and transparency across the self‑disclosure process.

EU Announces 20th Sanctions Package Targeting Russia’s War‑Support Capabilities

President von der Leyen has outlined the European Commission’s proposal for a 20th sanctions package against Russia, focused on tightening restrictions which limit the Kremlin’s ability to sustain its war effort. The package centres on expanding the EU’s listings of individuals and entities involved in Russia’s military and defence supply chains, strengthening measures against sanctions circumvention, and further constraining access to critical technologies. It also emphasises coordination with international partners to close loopholes and reinforce pressure on Russia, situating these steps within the broader political and economic response to the ongoing conflict.

OFSI Strengthens Financial Sanctions Enforcement with Updated Guidance

The Office of Financial Sanctions Implementation (‘OFSI’) has released enhanced guidance following a recent consultation, aiming to deliver a clearer, more robust enforcement framework for financial sanctions and monetary penalties. Effective immediately, the guidance introduces several key changes: a new Early Account Scheme offering a penalty discount of up to 20% for eligible cases, a Settlement Scheme with a similar discount, and a new policy for assessing financial hardship claims. Case assessment factors have been updated, alongside the replacement of the previous framework with a four-level seriousness model, each tier specifying indicative outcomes from warning letters to monetary penalties. OFSI now provides a single penalty discount of up to 30% for complete voluntary disclosure and cooperation, supported by expanded guidance. Additionally, the revised guidance details the application of £5,000 and £10,000 fixed penalties for information, reporting, and licensing offences, including examples and an expanded interpretation of information offences. OFSI will also host a webinar in March 2026 to explain these changes further, with registration details to be announced.

MONEYVAL issues sanctions evasion warning

A new MONEYVAL report finds that while most jurisdictions have strengthened regulation and supervision of virtual‑asset service providers, significant gaps remain. These gaps are around weak enforcement against unlicensed operators and slow implementation of the FATF travel rule. The review highlights emerging risks including the use of virtual assets to evade targeted financial sanctions, fraud, proliferation financing, and child exploitation, and notes that poor data collection continues to hinder effective oversight. MONEYVAL urges jurisdictions to integrate sanctions‑evasion risks into national assessments, improve suspicious‑activity reporting, and expand cross‑border cooperation to keep pace with rapid developments in the virtual‑assets sector.

Fraud

CFTC Launches Valentine’s Week Push to Warn About Relationship Investment Scams

The Commodity Futures Trading Commission (‘CFTC’) is coordinating a national and international Valentine’s Week campaign to raise awareness of relationship investment scams, a form of romance fraud which costs Americans an estimated $10 billion annually. Working with US federal and state agencies, financial regulators, and global partners, the initiative urges the public to be cautious of online acquaintances who pressure them to move conversations to encrypted apps, claim crypto‑trading expertise, or request money for supposed investments. The CFTC highlights how scammers exploit emotional vulnerability, often directing victims to fraudulent trading platforms controlled by organised criminal networks, and aims to reduce victimisation through targeted education and outreach.

Bribery and Corruption

The Eroding Guardrails: A Global Leadership Crisis in the Fight Against Corruption

In 2025, the global struggle for transparency reached a troubling milestone, according to the latest Transparency International Corruption Perceptions Index (‘CPI’), where the average dropped to just 42 out of 100, marking a decline for the first time in over a decade. This downward trend signals a widespread failure of public sector integrity, with 122 out of 182 countries now scoring below 50, indicating serious corruption problems. The sources describe a "dangerous disregard for international norms" and a global order under strain from power rivalries, armed conflicts, and the climate crisis.

The most alarming finding of the 2025 report is the backsliding of established democracies. Nations which once seemed secure, such as the United States (64), Canada (75), the United Kingdom (70), and New Zealand (81), have all seen their scores sink to new lows. In the UK, this decline is attributed to a "supercharged" reliance on wealthy political donors and scandals involving "cash for access". In the US, the normalisation of transactional politics and the weakened enforcement of the Foreign Corrupt Practices Act have sent a dangerous signal that bribery may be acceptable.

This erosion of leadership has a significant human cost. When corruption flourishes, public funds are mismanaged, leading to underfunded hospitals, unbuilt infrastructure, and worsening poverty. The data shows a direct link: countries with higher corruption scores consistently provide lower-quality essential health services. Furthermore, the environment for those who expose these crimes has become increasingly lethal. Since 2012, 150 journalists have been murdered while investigating corruption-related stories, with over 90 per cent of these killings occurring in countries scoring below 50 on the index.

Yet, amid this decline, a surge of resistance is rising. Gen Z-led protests erupted across the globe in 2025, from Serbia to Peru, as young people took to the streets to demand accountability. In Nepal and Madagascar, these popular movements were so powerful they successfully brought down the governments of the day. These protestors are united by a shared sense that those in power are abusing their positions for private gain while failing to deliver basic opportunities for the public.

To reverse this tide, Transparency International argues that leaders must choose to act for the public interest over private gain. Their "blueprint" for reform calls for strengthening independent justice systems, protecting the "civic space" where NGOs and journalists operate, and closing the secrecy loopholes which allow "dirty money" to be laundered across international borders. Without bold leadership to restore these guardrails, the index warns that corruption will continue to undermine global stability and human rights.

Watchdog Opens Inquiry into Australia’s Anti‑Corruption Chief Over Defence‑Related Work

Australia’s inspector of the National Anti‑Corruption Commission has launched an investigation into commissioner Paul Brereton over concerns about his continued consulting work for the Inspector‑General of the Australian Defence Force (‘IGADF’) while leading the NACC. The probe focuses on Brereton’s involvement in defence‑related referrals and his ongoing engagement with the IGADF, amid questions about potential conflicts of interest. The NACC says any conflicts have been appropriately managed and that Brereton has not participated in matters involving the IGADF, while the government maintains that the commission’s oversight mechanisms are functioning as intended. Critics, including Greens senator David Shoebridge, argue the situation undermines public confidence and have called for Brereton’s removal.

Money Laundering

DoD Employee Charged with Laundering Millions for Overseas Fraud Network

Federal prosecutors in the Eastern District of Pennsylvania have indicted Samuel D. Marcus, a Department of Defense logistics specialist, for allegedly acting as a money mule for a group of Nigeria‑based scammers who ran multiple fraud schemes targeting US victims. According to the indictment, Marcus received and moved millions of dollars in illicit proceeds between 2023 and 2025, converting funds to cryptocurrency and transferring them to foreign accounts while knowing they were tied to fraud. Authorities say he continued the activity even after being warned by the FBI and also misled banks and investigators with false invoices.

Market Abuse

FCA fines two men over £108k for insider dealing breaches

The FCA has fined two individuals a combined £108,731 for insider dealing, concluding that both men traded on confidential information to profit from upcoming market‑sensitive announcements. The regulator states that their actions undermined market integrity and investor confidence, and the penalties reflect both the seriousness of the misconduct and the FCA’s continued focus on deterring unlawful use of inside information.

Other Financial Crime

UK and China Commit to Stronger Joint Action on Financial Crime Risks

The UK and China have committed to a range of financial‑sector issues, including several commitments directly relevant to financial crime. Both governments reaffirm their intention fully to implement the Financial Action Task Force Standards and to deepen cooperation against money laundering, fraud, and other cross‑border criminal activity, recognising shared vulnerabilities in their financial systems. They also highlight the need for stronger bilateral mechanisms to address counterfeit currency, emphasising legal frameworks and efficient information‑sharing channels to curb the manufacture and export of counterfeits and related materials. These elements sit within the wider context of regulatory coordination, market development, and financial stability discussed in the document.

Montenegro’s Push for Secure Instant Payments

Dr Irena Radović’s speech at the Regional Conference “AML/CFT and anti‑fraud procedures for instant payments” in Podgorica set out Montenegro’s commitment to integrating instant payments and aligning fully with European financial standards. She highlighted the region’s growing cooperation among Western Balkan central banks, the strategic importance of SEPA accession, and Montenegro’s progress toward implementing instant payments through the upcoming TIPS Clone project. Radović stressed that innovation must be matched by strong AML/CFT safeguards, noting recent reforms, enhanced supervision, and closer coordination with European partners. She framed instant payments as both a technological and strategic transformation, emphasising shared regional responsibility, the need for real‑time risk management, and the goal of contributing to a secure, integrated European payments ecosystem.

Saudi Central Bank governor warns that financial crime threatens global growth

At a side event of the IMF–World Bank Annual Meetings, Saudi Central Bank Governor Ayman Al‑Sayari stressed that financial crime, fraud, and corruption pose systemic risks to global stability and economic development. He outlined Saudi Arabia’s system‑wide response, including strengthened risk‑based supervision, an empowered financial intelligence unit, enhanced beneficial‑ownership transparency, and governance reforms. He also highlighted the dual imperative of embracing digital innovation while safeguarding against its misuse, arguing that international cooperation and robust controls are essential to protecting financial integrity.

Cybercrime

UK launches world‑first framework to expose gaps in deepfake detection

The UK government is partnering with Microsoft, global tech firms, academics and law‑enforcement agencies to create a pioneering deepfake detection evaluation framework designed to set consistent standards for identifying harmful synthetic media. With deepfake incidents surging to an estimated eight million in 2025, the initiative aims to evaluate detection tools against real‑world threats such as fraud, impersonation and image‑based abuse, strengthening national security and protecting victims. The framework follows a major government‑funded Deepfake Detection Challenge and sits alongside new laws criminalising deepfakes, forming part of a broader effort to curb AI‑enabled abuse and bolster public safety.

State-backed hackers intensify personalised attacks on defence-sector workers, Google warns

Google’s latest threat‑intelligence report, released ahead of the Munich Security Conference, finds that state-sponsored hacking groups are increasingly targeting individual employees across the US and European defence sectors, often by exploiting hiring processes and personal devices rather than corporate networks. The campaigns span Russia, China, Iran and North Korea, with tactics ranging from spoofed contractor websites and fake job portals to highly tailored phishing messages based on personal details, geography and family life. Smaller industrial firms are also being hit with extortion attempts, while Ukraine reports a sharp rise in individualised attacks on military personnel and foreign partners involved in defence projects.

European Commission investigates cyberattack on its mobile device management system

The European Commission is examining a cyber intrusion detected on 30th January which exposed staff names and mobile numbers but did not compromise any devices, according to its advisory. The attack targeted the Commission’s mobile device management platform, which was contained and cleaned within nine hours, with CERT‑EU now leading the investigation. Officials warn the stolen data could enable targeted phishing or vishing attempts, while the incident highlights persistent threats facing EU institutions and follows earlier security breaches affecting multiple EU bodies.