Episode 229

2nd March – 5th March 2026

Sanctions 

US Seeks Forfeiture of Tanker and 1.8 Million Barrels of Crude 

The US Department of Justice has initiated a civil forfeiture action targeting an oil tanker and approximately 1.8 million barrels of crude oil which authorities say were used to support illicit trade between Iran and Venezuela in violation of US sanctions. According to the announcement, the shipment was allegedly connected to networks which help Iran generate revenue and supply Venezuela with sanctioned petroleum products, with the US asserting jurisdiction on the basis that the transaction involved deception and money‑laundering practices falling under US law. The filing forms part of broader US efforts to disrupt sanctions‑evasion schemes and seize assets tied to prohibited financial activity. 

OFAC Issues New Nicaragua Designations and Updates Russia‑Related Authorisations 

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has announced new sanctions designations against five Nicaraguan officials and issued an amended Russia‑related general licence authorising certain transactions linked to the potential sale of Lukoil International GmbH, alongside updates to two related FAQs and the Specially Designated Nationals list. 

Treasury Sanctions Rwandan Officials for Violations of Washington Peace Accords 

The US Department of the Treasury announced sanctions against several Rwandan officials, citing what it described as clear violations of the Washington Peace Accords and actions which have contributed to instability in the region. The designation targets individuals alleged to be involved in activities which undermine peace commitments and exacerbate conflict dynamics, with the measures intended to restrict their access to the US financial system and signal Washington’s concern over ongoing regional tensions. The Treasury Department framed the sanctions as part of broader efforts to support accountability and reinforce diplomatic agreements aimed at reducing violence and promoting stability. The State Department press release is here. 

UK Government Revokes Sanctions Against John Michael Ormerod 

On 2nd March 2026, the Foreign, Commonwealth & Development Office updated the UK Sanctions List to revoke the designation of British national John Michael Ormerod. This revocation follows an official decision-making process and removes all previous restrictions, including an asset freeze, trust services sanctions, director disqualification, and transport sanctions. Ormerod was originally designated on 20th May 2025, based on allegations that he supported the Government of Russia through his involvement in the Russian energy sector. As a result of this update, he is no longer subject to any of the sanctions listed under the Russia (Sanctions) (EU Exit) Regulations 2019. 

UK Delists Al-Nusrah Front for the People of the Levant from ISIL and Al-Qaida 

On 2nd March 2026, the UK’s Foreign, Commonwealth & Development Office officially updated the UK Sanctions List to delist the entity "Al-Nusrah Front for the People of the Levant," including its numerous aliases such as the Al-Nusra Front and Hay'at Tahrir al-Sham. This removal follows a decision by the United Nations and means the group is no longer subject to the asset freeze or arms embargo previously imposed under the Isil (Da'esh) and Al-Qaeda (United Nations Sanctions) (EU Exit) Regulations 2019. While the notice outlines the group's historical ties to Al-Qaida and its various name changes during the Syrian insurgency, the delisting status confirms that it is no longer targeted by these specific UK and UN sanctions. 

OFSI outlines new framework for prioritising financial sanctions licence applications 

A new blog post on the OFSI website explains how the UK sanctions authority is formalising its approach to prioritising financial sanctions licence applications, setting out seven criteria used to assess urgency, risk, and potential harm to applicants or wider stakeholders. The post notes that OFSI handled more than 900 licensing decisions in 2024–25 and cannot process all applications immediately, so cases are categorised as high, medium, or low priority based on factors such as humanitarian need, economic impact, timing pressures, and complexity. While the framework provides structure, caseworkers retain discretion, and even urgent applications may take time to resolve. The blog also advises applicants on how to support timely decisions by providing clear legal bases, complete information, evidence of deadlines, and by avoiding speculative or duplicate submissions. 

UK issues updated Global Anti‑Corruption sanctions notice 

A new sanctions notice published by the UK government reports a variation to the designation of Kamlesh Mansukhlal Damji Pattni under the Global Anti‑Corruption regime, confirming he remains subject to an asset freeze and a director‑disqualification sanction, with updated identifying details and an expanded statement of reasons citing alleged involvement in serious corruption, including bribery linked to illicit gold‑trading enterprises. 

Money Laundering 

US Attorney’s Office Seeks Forfeiture of $327K in Cryptocurrency 

Federal prosecutors in Massachusetts have filed a civil forfeiture action to recover roughly 327,829 USDT allegedly tied to a money‑laundering operation which concealed proceeds from an online romance scam targeting a Massachusetts resident, according to the Justice Department. Investigators say the victim was approached on a dating app in late 2024 by someone using the name “Linda Brown,” who promoted a fraudulent cryptocurrency investment and directed the victim’s funds into wallets controlled by scammers. The complaint states that the money was routed through multiple intermediary wallets and converted into USDT, methods which are commonly used to obscure the origin of illicit funds, and that several unhosted wallets holding the victim’s assets were seized in August 2025. Prosecutors argue the cryptocurrency constitutes property involved in money laundering, and the civil action will allow third parties to contest ownership before any forfeiture and restitution to victims proceeds. 

AUSTRAC outlines AML/CTF reforms and expectations for the legal profession 

In a recently delivered speech, now published on the AUSTRAC website, CEO Brendan Thomas has briefed barristers and solicitors on the scale of money‑laundering threats in Australia and the major AML/CTF reforms which will bring legal professionals into the regulatory regime from 1st July 2026. He explains why lawyers are increasingly targeted by organised crime, outlines new obligations, which include enrolment, AML/CTF programmes, customer due diligence, and reporting requirements, and emphasises a risk‑based, supportive regulatory approach. Thomas highlights real‑world case studies, the role of FATF standards, and AUSTRAC’s growing suite of guidance, starter kits, and education tools designed to help the sector adapt, stressing that compliance is essential to protect Australia’s financial system and prevent exploitation by domestic and international criminal networks. 

UK guidance explains how certified digital identity services can support MLR compliance 

New UK government guidance outlines how digital identities, which have been verified through certified Digital Verification Services (DVS) under the UK Digital Identity and Attributes Trust Framework, can be used by regulated entities to meet certain obligations under the Money Laundering Regulations (MLRs). It explains what constitutes a digital identity, how the trust framework and certification process operate, and the standards required for providers to appear on the DVS Register. The document clarifies that certified and registered digital identity services may be used for identity verification under Regulation 28, including for individuals and company directors, while emphasising that firms must still assess customer risk, apply enhanced due diligence where appropriate, and ensure all other customer due diligence requirements, such as understanding the purpose and nature of the business relationship, are met. 

OPBAS Flags Weak Enforcement and Structural Conflicts in AML Supervision of Professional Services Firms 

The latest OPBAS report finds that while professional body supervisors in the legal and accountancy sectors are more effective than at any point since 2018, significant weaknesses remain, particularly in enforcement, where some bodies still lack the deterrent capability needed to uphold minimum anti‑money laundering standards. OPBAS highlights persistent concerns about supervisors whose dual role as both membership organisations and regulators undermines robust action, even as overall compliance levels remain broadly good. The report notes OPBAS’s first-ever enforcement action against a supervisor last year and situates these findings within the UK government’s 2025 decision to transfer AML/CTF supervision of the sectors to the FCA to simplify oversight and strengthen the fight against financial crime. 

Guernsey Opens Public Consultation on Legitimate‑Interest Access Framework for Beneficial Ownership Information 

The States of Guernsey has launched a public consultation on proposals to introduce a legitimate‑interest access framework governing who may obtain limited beneficial ownership information for Guernsey companies, according to the government’s website. The Policy & Resources Committee proposes allowing access only to individuals or organisations able to demonstrate a clear connection to the prevention, detection, or investigation of financial crime, including journalists and NGOs with relevant mandates. The consultation outlines safeguards such as restricted disclosure, protections for vulnerable individuals, and strict controls on data use, aiming to balance enhanced transparency with privacy and human‑rights obligations while aligning with evolving international and EU standards. Responses are invited by 10th April 2026 via email to the Committee. 

FATF Warns of Escalating Illicit Finance Risks from Stablecoins and Unhosted Wallets 

A new report from the FATF highlights how the rapid growth of stablecoins, which now exceeds US$300 billion in market value, has intensified illicit finance risks, with criminals increasingly exploiting peer‑to‑peer transfers via unhosted wallets to evade regulated intermediaries. The report notes that stablecoins accounted for 84% of illicit virtual asset transaction volume in 2025 and are being misused by money launderers, terrorist financiers, and state‑linked cyber actors, including DPRK and Iranian networks. It urges jurisdictions fully to implement FATF Recommendation 15, strengthen AML/CFT controls for stablecoin issuers and VASPs, build technical capabilities for cross‑chain and smart‑contract analysis, and adopt measures such as allow‑listing, deny‑listing, and enhanced public‑private cooperation to mitigate emerging threats. 

Other Financial Crime 

Justice Department Begins Distributing $12.4 Million in Forfeited Funds 

The US Department of Justice has begun distributing more than $12.4 million in forfeited assets to over 8,000 victims of the securities fraud scheme run by Roger Knox and his co‑conspirators, with the SEC providing an additional $3.1 million in related payments. Knox operated the Swiss-based firms Silverton and later Wintercap, which facilitated pump‑and‑dump schemes by selling large volumes of microcap shares on behalf of undisclosed control groups which used nominee entities to evade federal disclosure rules. Prosecutors say these groups promoted the stocks to inflate prices, while Knox moved more than $137 million in proceeds through a complex transfer network to obscure the funds’ origins. Knox pleaded guilty in 2020, was sentenced to 36 months in prison in 2023, and ordered to pay over $58 million in restitution in 2024. The distributions form part of the Justice Department’s broader asset‑forfeiture programme, which has returned more than $12 billion to crime victims since 2000. 

EPPO reports €45 billion in VAT and customs fraud 

The European Public Prosecutor’s Office (‘EPPO’) reports that VAT and customs fraud accounted for €45.01 billion of the €67.27 billion in estimated damage under investigation at the end of 2025, highlighting how revenue‑focused schemes are increasingly central to organised crime in the EU. EPPO recorded 3,602 active cases, a 35% rise from 2024, alongside significant growth in new investigations, indictments, and asset‑freezing orders. The report notes that large‑scale organised groups, which often operate across borders involving complex import and trade structures, are driving these high‑profit, low‑risk frauds, with a notable presence of networks linked to goods originating outside the EU. European Chief Prosecutor Laura Kövesi emphasises that tackling these schemes is essential for safeguarding both EU and national budgets. 

NCA Annual Plan 2025-2026 

The National Crime Agency’s (‘NCA’) Annual Plan for 2025-2026 sets out a clear strategic priority to lead the UK law enforcement system in reducing fraud and combating corrupt elites, cyber, and economic crime. Under its "Pillar 1" strategy, the Agency is rebalancing its resources to commit a higher proportion of funding to economic crimes, focusing on disrupting those at the top of criminal chains and the professional enablers who facilitate the laundering of illicit proceeds. This follows a successful 2024-2025 period in which the NCA prevented over 400,000 frauds through targeted disruptions. For the coming year, the Agency will take on new legislative taskings under the Crime and Courts Act specifically related to fraud and will continue to host the International Anti-Corruption Coordination Centre to tackle global allegations of grand corruption. Furthermore, the NCA has identified compliance with Financial Action Task Force (‘FATF’) recommendations as a critical risk management priority for the 2025-2026 financial year, supported by an overall budget of £1,012 million. 

Speech by the AUSTRAC CEO on Cross‑Border Money Flows and Asia‑Pacific Fraud Trends 

A recent speech by the AUSTRAC CEO, published on the AUSTRAC website, outlines current patterns in cross‑border money flows and emerging fraud and financial‑crime risks across the Asia‑Pacific region, emphasising the growing sophistication of criminal networks and the need for stronger regulatory cooperation and intelligence sharing to counter these threats. The address highlights how rapid digitalisation, evolving payment technologies, and increasingly complex criminal methodologies are reshaping the financial‑crime landscape, and stresses the importance of coordinated responses between government, industry, and international partners to protect the integrity of the financial system. 

EU–Namibia Partnership Deepens Country’s Fight Against Financial Crime 

Namibia’s Financial Intelligence Centre and the European Union have launched a week‑long National Risk Assessment workshop aimed at reinforcing the country’s ability to combat money laundering, terrorist financing and proliferation financing, a key step in its efforts to exit the FATF grey list and prepare for its upcoming ESAAMLG mutual evaluation. The workshop brings together a broad coalition of national institutions to build shared understanding, improve data‑driven risk identification and strengthen coordination across sectors, supported by EU‑funded technical assistance through the SecFin Africa project. EU representatives emphasised that the real measure of success will be the reforms and operational improvements which follow, highlighting the joint commitment to safeguarding Namibia’s financial system and reducing illicit financial flows. 

Katharine Braddick Appointed Deputy Governor for Prudential Regulation 

Katharine Braddick has been appointed as the next Deputy Governor for Prudential Regulation and Chief Executive of the Prudential Regulation Authority, succeeding Sam Woods in July 2026, with the government highlighting her regulatory and private‑sector experience and the role’s importance in maintaining financial stability and supporting UK competitiveness. 

Cybercrime 

UK organisations urged to tighten cyber defences amid Middle East conflict 

The National Cyber Security Centre (‘NCSC’) has warned that while there is no major change in the direct cyber threat from Iran to the UK, the fast‑moving conflict in the Middle East has created a clear rise in indirect risks, particularly for organisations with operations or supply chains in the region. It highlights that Iran‑linked actors retain capabilities to conduct cyber activity and advises UK organisations to review their security posture, prepare for potential collateral impacts such as DDoS or phishing campaigns, and follow existing NCSC guidance on heightened‑threat actions, monitoring, and attack‑surface review. The NCSC also encourages sign‑up to its Early Warning service and recommends that critical national infrastructure operators revisit recently issued severe‑threat preparation guidance. 

Germany plans expanded cyber‑security powers for law enforcement 

Germany is preparing legislation which would grant law enforcement and security agencies broader authority to counter foreign cyber threats, including the ability to shut down IT systems, redirect data traffic, and in severe cases delete or alter data on both domestic and foreign servers, according to a draft legislative proposal. The proposal reflects Berlin’s heightened focus on hybrid threats following Russia’s 2022 invasion of Ukraine and includes new “threat hunting” powers for the Federal Office for Information Security, mandatory cooperation from digital service providers, and potential fines of up to €20 million for non‑compliance. 

Europol expands public‑private cooperation to strengthen Europe’s cyber‑intelligence capabilities 

Europol’s European Cybercrime Centre has launched the Cyber Intelligence Extension Programme, a pilot initiative which embeds private‑sector experts inside Europol to work directly with analysts on disrupting cross‑border cybercrime. The programme aims to enhance operational cooperation, accelerate intelligence sharing, and improve Europe‑wide disruption of criminal infrastructure, reflecting the growing need for joint action as cyber threats evolve. Europol highlights the 2025 takedown of the Lumma Stealer malware, supported by Microsoft’s identification of nearly 400,000 infected devices, as an example of how combined technical and investigative capabilities can significantly weaken major cybercriminal operations. 

Warning rising US tariffs are amplifying retaliatory cyber risks and hybrid threats 

A Nasdaq opinion article argues that the sharp increase in US tariffs has heightened the risk of retaliatory cyber operations by nation‑states, with geopolitical tensions creating openings for politically motivated attacks on government and private‑sector systems. The piece highlights Europol’s finding that state actors are increasingly forming “shadow alliances” with criminal gangs, blending espionage, data theft, disinformation, and infrastructure sabotage, while Microsoft reports growing collaboration between cybercriminals and state‑linked groups across Russia, China, Iran, and North Korea. In response, the European Commission plans to strengthen security protocols and significantly expand Europol’s resources, reflecting concern that tariff‑driven economic friction, especially between the US and China, may further escalate hybrid threats and expose supply chains to new vulnerabilities.