Episode 231

9th March – 12th March 2026

Sanctions

UK updates Russia sanctions list with variation to OJSC Keremet Bank designation

The UK has issued a sanctions notice varying the designation of OJSC Keremet Bank, which remains subject to an asset freeze, trust services ban, correspondent banking prohibitions, and director disqualification, after officials reaffirmed that the bank benefits from and supports Russia’s strategically significant financial sector.

UK publishes cross‑government policy paper setting out a unified strategic approach to sanctions enforcement

A UK government policy paper outlines its consolidated strategy for enforcing sanctions across financial, trade, transport, internet services and immigration regimes, emphasising that robust, proportionate enforcement is essential to national security and the credibility of UK foreign policy. It explains how departments and regulators coordinate civil and criminal powers, clarifies roles for OFSI, OTSI, HMRC, the NCA, DfT, Ofcom and others, and sets out the principles guiding enforcement decisions, including strict‑liability civil penalties, the use of criminal investigation for deliberate or high‑harm breaches, and the importance of voluntary disclosure, cooperation and strong compliance systems. The document aims to give industry clearer expectations, strengthen deterrence, and support a more transparent, consistent sanctions enforcement environment. The policy paper fulfils a commitment made in the May 2025 cross-government review of sanctions implementation and enforcement.

US imposes visa restrictions on senior Rwandan officials over actions undermining peace in eastern DRC

The United States has announced visa restrictions on several senior Rwandan officials for supporting the M23 armed group and violating the Washington Accords, actions it says are fuelling instability and violence in eastern Democratic Republic of the Congo. The policy, issued under Section 212(a)(3)(C) of the Immigration and Nationality Act, targets individuals believed to be responsible for undermining sustainable peace in the Great Lakes region, with certain family members also potentially affected. Washington reiterated that the DRC must neutralise the FDLR and that Rwanda must withdraw its forces and equipment from Congolese territory for regional stability to be restored.

US files civil forfeiture complaints to seize $15.3 million allegedly tied to an Iranian oil‑shipping and sanctions‑evasion network

The Justice Department has filed two civil forfeiture complaints seeking more than $15 million in funds allegedly used to operate the Shamkhani Network, a global web of front companies accused of selling and shipping Iranian oil in violation of US sanctions and laundering profits for the IRGC and IRGC‑QF. Prosecutors say Mohammad Hossein Shamkhani, sanctioned by OFAC in 2025 and described as running a vast fleet of covert shipping and financial entities, used companies such as Wellbred Capital and Sea Lead Shipping to disguise Iranian control and move millions through the US financial system. The action reflects a coordinated effort by DOJ, FBI, HSI, and IRS‑CI to disrupt illicit Iranian revenue streams and prevent US institutions from facilitating sanctions evasion.

Money Laundering

International police operation dismantles global drug‑trafficking and money‑laundering network uncovered from two seized phones in Sweden.

An international law‑enforcement operation spanning Sweden, Spain, Thailand and Australia has arrested 15 suspects and disrupted a highly interconnected criminal ecosystem after Swedish investigators uncovered encrypted communications and corporate structures linking multiple drug‑trafficking and money‑laundering networks across continents. The investigation, triggered by the seizure of two mobile phones in 2023, revealed a decentralised system moving synthetic drugs, coordinating shipments such as a 1.2‑tonne consignment intercepted in Germany, and laundering profits through layered business entities. Coordinated action earlier this month led to simultaneous searches, the arrest of high‑value targets, and the seizure of €4 million in assets, demonstrating how digital forensics and international cooperation can expose and dismantle globally embedded organised crime.

DRC Moves to Tighten Oversight of Infrastructure Financing Amid Corruption and Illicit Flow Risks

The Democratic Republic of Congo has signed a cooperation agreement between its oversight agency APCSC and financial intelligence unit CENAREF to strengthen monitoring of financial flows tied to major infrastructure projects, aiming to improve transparency, traceability, and safeguards against corruption, embezzlement, money laundering, and other illicit financial activity. The move comes as the IMF warns that persistent illicit flows, especially in the mining sector, continue to undermine the country’s fiscal stability, while the DRC remains on the FATF grey list and scores just 20/100 on Transparency International’s 2025 Corruption Perceptions Index. Authorities hope the enhanced controls will bolster economic governance and credibility in a challenging security and governance environment.

US Treasury Releases 2026 National Risk Assessments on Illicit Finance Threats

The US Department of the Treasury has published its 2026 national risk assessments detailing the primary vulnerabilities and threats associated with money laundering, terrorist financing, and proliferation financing within the US financial system. The reports indicate that while the core threats remain largely consistent, illicit actors, which include transnational criminal organisations, state actors such as the Democratic People's Republic of Korea and Iran, and various global terrorist networks, are increasingly employing sophisticated methods such as professional money laundering networks, digital assets, and artificial intelligence to bypass regulatory controls. Key findings across the three reports highlight the generation of hundreds of billions of dollars from domestic and international fraud and drug trafficking, the exploitation of the global technology ecosystem to evade sanctions and fund weapons of mass destruction programmes, and the recent unprecedented designation of several international drug cartels as Foreign Terrorist Organisations. The assessments emphasise the necessity for the US government and financial institutions continuously to adapt regulatory frameworks and strengthen public-private cooperation to mitigate these evolving vulnerabilities.

BIS Publishes Caroline Abel’s Strategic Roadmap for Strengthening Seychelles’ AML/CFT Defences

The Bank for International Settlements (‘BIS’) has released the opening and closing remarks delivered by Caroline Abel, Governor of the Central Bank of Seychelles, at a workshop focused on navigating risk and resilience within the jurisdiction's financial system. Throughout her addresses, Governor Abel emphasised that addressing bribery, corruption, and illicit financial flows is essential to maintaining the governance and economic stability of Seychelles. She highlighted the mounting pressure from expanding global sanctions regimes and the necessity for the country to align with FATF standards to protect its vital correspondent banking relationships. To address specific national challenges, the Governor confirmed that discussions are underway to establish a centralised PEP list and sanctions repository, while also advocating for the use of artificial intelligence and risk intelligence tools to enhance transaction monitoring. Ultimately, Abel stressed that technical tools must be matched by a practical shift in culture, translating regulatory guidance into consistent customer due diligence and risk-based judgment, to ensure Seychelles is prepared for its next Mutual Evaluation in 2027.

Fraud

US Authorities Escalate Multi-Agency Crackdown on Rising Financial Fraud and Cyber-Enabled Scams

The United States government has launched a coordinated effort to combat the rapidly evolving landscape of financial fraud, using executive action, record-breaking regulatory penalties, and legislative oversight to address a crisis which costs consumers billions of dollars last year. These initiatives target a wide range of illicit activities, from sophisticated international "scam centres" to internal compliance failures within the domestic financial sector.

First, a new Executive Order was signed specifically to dismantle transnational criminal organisations engaged in cyber-enabled fraud, including ransomware, phishing, and impersonation scams. The order directs the Attorney-General to prioritise prosecutions of these offences and establishes a Victims Restoration Programme to return seized or forfeited funds directly to those defrauded. This directive also focuses on protecting vulnerable populations, such as seniors, who reported significant losses in 2024, and children targeted by online extortion and deepfake abuse.

Reinforcing these federal priorities, the Financial Crimes Enforcement Network (‘FinCEN’) recently assessed a historic $80 million civil penalty against the broker-dealer Canaccord Genuity LLC for wilful violations of the Bank Secrecy Act. The agency found that the firm’s under-resourced anti-money laundering programme failed to detect and report numerous securities fraud schemes, including penny stock scams which caused significant economic harm to investors. By failing to file at least 160 suspicious activity reports, the firm reportedly allowed high-risk customers, including those with ties to illicit actors, to access the US financial system without proper oversight.

These enforcement actions coincide with a House Financial Institutions Subcommittee hearing held on 5th March 2026, where lawmakers and industry experts analysed the "rising occurrence" of financial fraud. During the session, it was noted that reported fraud losses reached $12.5 billion in 2024, a figure many believe represents only a fraction of the actual total. Testimony from banking representatives emphasised that while financial institutions serve as the "front lines" of defence, the increasing complexity of overseas criminal networks necessitates an all-of-government approach. Proposed solutions discussed by the committee include expanded information-sharing authority, the integration of artificial intelligence for early warning detection, and a national strategy focused on consumer education to prevent funds from being lost to irreversible wire transfers and peer-to-peer scams.

Texas DME Owner Gets 90 Months for $59M Medicare Fraud Scheme

A Texas DME company owner, Patrick Cassells, has been sentenced to 90 months in prison for running a scheme which paid kickbacks for fraudulent doctors’ orders and billed Medicare nearly $60 million for unnecessary orthotic braces, ultimately receiving more than $27 million before being caught.

UK Government Unveils £250 Million Fraud Strategy and New Online Crime Centre to Combat £14.4 Billion Scam Epidemic

In response to an escalating epidemic which cost the UK economy an estimated £14.4 billion in the 2023-2024 financial year, the UK Government has launched a sweeping new Fraud Strategy for 2026 to 2029, backed by a £250 million investment over the next three years. At the heart of this initiative is the creation of a new, £30 million Online Crime Centre launching in April, which will unite law enforcement, intelligence agencies, banks, telecoms, and major tech firms instantly to share data and dismantle the increasingly tech-enabled and international scam networks targeting the British public. Grounded in three core pillars, namely disrupting criminal infrastructure, safeguarding the public and businesses, and responding with enhanced victim support and swifter justice, the strategy aims to transform the national response. By deploying cutting-edge artificial intelligence, shutting down scam operations at scale, and strengthening international intelligence-sharing partnerships, the government and the National Crime Agency intend to stop fraudsters at their source and make the UK a significantly harder environment for criminals to operate. The National Assessment Centre Fraud assessment 2025 which was used to inform the 2026 Fraud Strategy is here. The National Crime Agency response to the announcement is here.

Bribery and Corruption

Ukraine’s Anti‑Corruption Agencies Complete Final Training Module to Strengthen Pre‑Trial Investigation Standards

Ukraine’s National Anti‑Corruption Bureau, the Special Anti‑Corruption Prosecution, and the Specialised Anti‑Corruption Prosecutor’s Office have completed the final module of a UNDP‑supported programme aimed at unifying and improving pre‑trial investigation standards. The training covered project‑management‑based planning, evidence assessment, including indirect evidence, risk‑based selection of preventive measures, and the principles of necessity and proportionality. Participants also developed soft skills such as ethical decision‑making and negotiation. The programme was implemented by JustLearn with support from UNDP and funding from the Government of Japan.

Other Financial Crime

Global ‘Custos Viridis’ Operation Disrupts Environmental Crime Networks Across Five Continents

An international law‑enforcement operation coordinated by Europol, code‑named Custos Viridis, brought together authorities from 71 countries throughout 2025 to target organised networks involved in waste trafficking, pollution crime, and related financial offences. The effort led to 1,048 inspections, 337 arrests, and the seizure of more than 127,000 tonnes of waste, significant quantities of hazardous chemicals including fluorinated greenhouse gases and mercury, and nearly €10 million in assets. Investigators identified multiple criminal groups operating within and beyond Europe, uncovered illicit waste flows and document fraud schemes, and highlighted growing trends such as increased illegal F‑gas trade from Asia. Europol supported the operation with intelligence coordination and cross‑border lead development, highlighting environmental crime as a rising threat linked to corruption, money laundering, and serious harm to communities and ecosystems.

Bank of England questions lenders over exposure to collapsed mortgage provider MFS

The Bank of England’s Prudential Regulation Authority is seeking information from lenders, including Barclays, about their funding exposure to Market Financial Solutions after the Mayfair-based bridging loan provider was placed into administration amid allegations of financial irregularities and mismanagement. Regulators are concerned banks may not have conducted adequate due diligence on MFS’s loan book, though no formal investigation has been launched. Barclays is reportedly owed £495 million, and the central bank emphasised that firms are responsible for managing their own risk while it continues broader stress‑testing and reviews of non‑bank lending vulnerabilities.

Home Office Seeks Views on Economic Crime Information Sharing

The Home Office has issued a call for evidence to gather feedback on the effectiveness of current information sharing practices in tackling economic crime in the UK. Stakeholders are invited to comment on legal, operational, and cultural barriers, as well as potential improvements, with submissions accepted until 18th May 2026. The statement on the Call for Evidence to the UK House of Commons from the Security Minister is here.

Justice Department Issues First Department‑Wide Corporate Enforcement Policy for Criminal Cases

The US Department of Justice has introduced its first department‑wide corporate enforcement policy for all criminal matters, aiming to create greater consistency, predictability, and fairness in how corporate misconduct is handled. The policy standardises incentives for companies which voluntarily disclose wrongdoing, cooperate with investigations, and remediate misconduct, with the possibility of declinations in the absence of aggravating factors. Senior DOJ officials emphasised that the framework builds on years of corporate enforcement experience and applies uniformly across all components except antitrust, replacing prior component‑specific policies. The Department states that the approach is intended to speed pursuit of individual accountability, support victims, deter white‑collar crime, and reduce unnecessary burdens on compliant businesses.