Episode 228

27th February – 1st March 2026

Sanctions

OFSI Extends General Licence INT/2025/8031092 and Updates Related FAQ

OFSI has amended General Licence INT/2025/8031092, extending its expiry to 25th August 2026. Anyone planning to rely on this licence should review the updated text to ensure full understanding of the permissions and conditions attached. FAQ 174 has also been revised to reflect the changes made to the licence.

UK Updates Sudan Sanctions Listings Following UN Committee Additions

The UK Government has updated the designations of four individuals under the Sudan Sanctions Regime, following their addition to the UN Sanctions List on 24th February by the UN Security Council Resolution 1591 (2005) Sanctions Committee. The amended listings apply to Abdul Rahim Hamdan Daglo, Al‑Fateh Abdullah Idris, Gedo Hamdan Ahmed, and Tijani Ibrahim Moussa Mohamed.

US Treasury Sanctions Iran’s Shadow Fleet and Procurement Networks

The US Department of the Treasury has imposed sanctions on more than 30 individuals, entities, and vessels linked to Iran’s illicit petroleum trade and to networks supplying materials and machinery for the country’s ballistic missile and advanced conventional weapons programmes, including UAV production. The action targets 12 vessels operating within Iran’s “shadow fleet,” several maritime companies across multiple jurisdictions, and procurement networks in Iran, Türkiye, and the UAE which support the IRGC and MODAFL. Additional designations include firms and individuals involved in securing precursor chemicals for missile propellants and providing technical support for Iranian UAVs abroad. All designated parties’ US-linked property is blocked, and US persons are prohibited from engaging in related transactions, with potential secondary sanctions for foreign financial institutions which facilitate significant dealings. The State Department press release is here.

OFAC Announces $3.77 Million Settlement with US Individual

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has announced that a US individual agreed to pay $3,777,000 to settle potential civil liability for 20 apparent violations of Syrian sanctions regulations, after providing managerial services between 2018 and 2021 as an officer and board member of four Syrian real estate companies involved in luxury development projects. OFAC determined the conduct to be egregious and not voluntarily self‑disclosed, resulting in a settlement reflecting the seriousness of the violations and the individual’s role in supporting activities in Syria during a period when such services were prohibited.

OFAC outlines favourable licensing policy for resale of Venezuelan‑origin oil to Cuba

A recently published Office of Foreign Assets Control (‘OFAC’) FAQ explains that the agency would apply a favourable licensing policy to specific applications seeking authorisation to resell Venezuelan‑origin oil for use in Cuba, provided the transactions align with the terms of Venezuela General Licence 46A, with certain Cuba‑related limitations removed. The guidance emphasises that the policy is intended to support the Cuban people, including the private sector, and excludes any dealings involving Cuban military, intelligence, or other restricted government‑associated entities. The FAQ also clarifies the respective roles of OFAC and the US Department of Commerce in regulating exports and reexports of US-origin oil and petroleum products to Cuba, noting that items covered under Commerce’s Licence Exception SCP do not require separate OFAC authorisation.

US Treasury Moves to Cut Swiss Bank MBaer Off from American Financial System

The US Treasury’s Financial Crimes Enforcement Network (‘FinCEN’) has proposed a rule which would bar US financial institutions from maintaining correspondent accounts for MBaer Merchant Bank AG, citing findings that the Swiss bank facilitated more than $100 million in transactions for illicit actors linked to Iran and Russia, including entities associated with the Islamic Revolutionary Guard Corps and its Quds Force. The proposal, issued under Section 311, USA Patriot Act, designates MBaer as a primary money‑laundering concern and frames the bank as a key access point to US dollar networks for sanctioned or high‑risk clients, posing risks to US national security and financial‑system integrity. If finalised, the measure would effectively sever the bank’s access to the US financial system, with a 30‑day public comment period now open. FinCEN’s release on the issue is here.

TI highlights Russia‑linked trade routed through UK Overseas Territories

Recently published research by Transparency International Russia in Exile finds that companies registered in the UK’s Overseas Territories facilitated approximately $8 billion (£5.9 billion) in trade with Russia since the 2022 full‑scale invasion, despite extensive UK, US and EU sanctions intended to restrict Russia’s access to global markets. The analysis identifies 145 opaque offshore entities involved in transactions, including commodities subject to UK sanctions and luxury goods such as yachts, raising concerns about whether these activities were properly licensed under local regimes, where transparency and public reporting remain limited. The findings point to persistent gaps in beneficial ownership disclosure and regulatory oversight in jurisdictions such as the British Virgin Islands and Bermuda, which Transparency International argues continue to undermine effective sanctions enforcement and weaken the UK’s broader foreign‑policy objectives.

Europol-coordinated investigation dismantles multinational laundering network

Europol reports that an international investigation has dismantled a financial network laundering cocaine proceeds for members of the Camorra and ’Ndrangheta, following the identification of suspicious cross‑border financial movements. Authorities in France, Italy, Belgium and Switzerland arrested seven suspects, including a Montenegrin high‑value target alleged to have coordinated both the laundering system and links to large‑scale cocaine shipments from South America into Europe. The inquiry uncovered shell companies, false invoicing, crypto‑asset use, and luxury assets used to reinvest illicit profits, with seizures including high‑end properties and vehicles. Europol and Eurojust supported the case through operational coordination, analysis, and a Joint Investigation Team established in 2024, bringing together multiple European and international partners.

Money Laundering

FATF Highlights Global Counter‑Illicit Finance Work in 2024–2025 Annual Report

The FATF’s 2024–2025 Annual Report outlines the organisation’s work during the first year of the Mexican presidency, detailing efforts across its global network to assess countries’ counter‑illicit finance systems, address emerging risks such as online child sexual exploitation, terrorist financing and proliferation financing, and finalise updates to international standards on payment transparency and financial inclusion. The report emphasises collaboration with more than 200 jurisdictions and partners in both the public and private sectors, reflecting ongoing priorities to strengthen global AML/CFT frameworks and build trust in the financial system.

Other Financial Crime

Unexplained Wealth Orders Rise as Agencies Broaden Use of Powers

The Home Office’s 2024–25 annual report on Unexplained Wealth Orders (‘UWOs’) shows a modest increase in their use, with five applications made and all granted by the High Court, marking the first year an agency other than the National Crime Agency, namely the Serious Fraud Office, used the power. The report highlights how reforms under the Economic Crime (Transparency and Enforcement) Act 2022 have strengthened operational confidence, reduced cost risks, and expanded the scope of UWOs, which remain targeted tools for complex cases where assets appear disproportionate to known lawful income. Although overall numbers remain low, the report emphasises their high impact, citing cases where UWOs facilitated recoveries of £10 million and £14 million, reinforcing their role in tackling illicit wealth hidden in or through the UK.

SFO Secures First £283k Confiscation Order Against Harlequin Fraudster David Ames

The Serious Fraud Office has obtained a £283,321 confiscation order against David Ames, marking the first recovery of assets since his 2022 conviction for a £226 million Harlequin timeshare fraud which deceived thousands of investors. Investigators uncovered hidden assets across multiple jurisdictions, which include suspected land in Thailand, luxury Dubai properties, a concealed bank account, and funds transferred to family members, leading to the order issued after a contested hearing in late 2025. Ames, already serving a 12‑year sentence, faces an additional three years if he fails to pay, with the SFO describing the order as a first step toward ensuring he cannot profit from the scheme which wiped out many victims’ pensions and life savings.

Graham McNulty Named Interim Director of the UK Serious Fraud Office

Graham McNulty has been appointed Interim Director of the Serious Fraud Office, taking over in early April following Nick Ephgrave’s retirement, with the decision made through a process overseen by the Attorney General’s Office. McNulty, currently the SFO’s Chief Operating Officer, brings more than three decades of senior policing and economic‑crime experience, including leadership roles in the Metropolitan Police and National Police Chiefs’ Council. Senior officials highlighted his operational background and recent work on technology upgrades and organisational changes as key factors supporting his appointment.

UNODC Report Exposes $18 Billion Global Waste Trafficking Industry

A new UNODC report, "Waste Crimes and Trafficking," reveals that illegal waste flows generate an estimated $18 billion in annual illicit profits. The analysis highlights how organised crime groups and non−compliant corporations exploit regulatory gaps through "jurisdiction shopping" and sophisticated logistics to move hazardous materials, such as e−waste and plastics, from high−income to low−income regions. These criminal networks often utilise legal front companies and engage in diverse financial crimes, which include document fraud, money laundering, and public embezzlement, to bypass environmental checks. With the legal waste management market worth $1.2 trillion, the financial incentive for illicit trafficking remains high because potential penalties are frequently outweighed by the massive profits earned from even a single illegal shipment. Beyond the economic impact, the UN warns that this activity drives toxic pollution and poses severe risks to global public health, drinking water, and sustainable development. The Report can be accessed here, and the press release is here.