Episode 232

13th March – 15th March 2026

Sanctions

UN 1988 Sanctions Committee Removes 22 Individuals from Afghanistan Sanctions List

The Security Council’s 1988 Sanctions Committee has approved the removal of 22 individuals from its Afghanistan sanctions list, reflecting an adjustment to measures targeting Taliban‑associated actors; the update signals a recalibration of international pressure tools while maintaining the broader framework of travel bans, asset freezes, and arms embargoes. The UK has updated its sanctions list to reflect the change.

UK Government Varies Russia Sanctions Designation for Associate of Alisher Usmanov

The Foreign, Commonwealth & Development Office has updated the UK Sanctions List to include a variation for Gulbakhor Ismailova, the sister of previously designated billionaire Alisher Usmanov. Ismailova remains subject to an asset freeze, travel ban, trust services sanctions, and a director disqualification, based on findings that she is associated with an "involved person" and obtains material benefit from him. The notice reinforces that failure to comply with these financial sanctions or attempting to circumvent them constitutes a criminal offence.

DBT updates countering Russian sanctions evasion guidance

The Department for Business and Trade and the Office of Trade Sanctions Implementation have updated guidance on preventing Russian sanctions evasion. Changes include revised lists of UK goods at higher risk and third‑country exporters. First issued on 7th January 2025, the guidance helps UK businesses identify and mitigate risks related to circumvention of Russian trade sanctions.

OFSI Updates Its Approach to Assessing “Reasonableness” in Sanctions Licensing Applications

The Office of Financial Sanctions Implementation (‘OFSI’) has updated its guidance on how it evaluates the “reasonableness” of costs in licence applications across all UK financial sanctions regimes, introducing new requirements for independent Costs Draftsperson’s Reports when legal fees exceed set thresholds and encouraging expert reports for high‑value or complex maintenance‑of‑assets requests. The update clarifies when these reports are needed, how thresholds apply, what evidence applicants should provide, and how OFSI may still adjust or decline costs even when supported by independent assessments. The changes aim to improve transparency, ensure consistent evaluation of fees, and help applicants prepare more complete submissions. The story is expanded upon in this blog post, and the earlier one is here.

US Treasury Sanctions Four Overseas Nonprofits Accused of Funding Hamas’ Military Wing

The US Department of the Treasury has designated four non-profit organisations in Türkiye and Indonesia for allegedly providing material support to Hamas’ military wing, stating that the groups operated as part of a covert fundraising network disguised as charitable activity. The action, taken under Executive Order 13224, blocks the entities’ US-linked assets and prohibits US persons from engaging in related transactions. Treasury officials said the designations build on previous actions targeting similar networks and form part of broader efforts to disrupt financial channels which support Hamas’ operations.

US Treasury Sanctions Individuals and Firms Accused of Facilitating DPRK IT Worker Fraud

The US Department of the Treasury has sanctioned six individuals and two entities for allegedly supporting North Korea’s overseas IT worker schemes, which the US government says generate significant revenue for the DPRK’s weapons programmes by using false identities to obtain work with foreign companies. The designations target facilitators in North Korea, Vietnam, Laos, and Spain who are described as enabling currency conversion, procurement activities, and financial transactions linked to these operations. The action blocks any US-linked property of the designated parties and restricts US persons from engaging in related transactions, forming part of a broader effort to disrupt revenue streams associated with DPRK sanctions evasion.

Money Laundering

FATF warns that offshore crypto service providers are creating major blind spots for global AML/CFT enforcement

A new FATF report highlights how weak or inconsistent oversight of offshore Virtual Asset Service Providers (oVASPs) is enabling large‑scale fraud, money laundering, and terrorist financing, with criminals exploiting regulatory gaps to obscure funds through layered wallets, multiple blockchains, and cross‑border structures. Fewer than half of jurisdictions apply activity‑based supervision which captures offshore providers serving their residents, creating vulnerabilities which illicit actors use to cash out proceeds, support terrorist groups, and hide beneficial ownership. The report outlines good practices, such as stricter licensing, sanctions for non‑compliance, stronger inter‑agency coordination, and enhanced international cooperation, and includes case studies from Nigeria, Indonesia, the UK, and others showing how oVASPs have facilitated scams, terrorism financing, and regulatory evasion.

Jersey probe may classify Abramovich’s Chelsea sale proceeds as potential ‘proceeds of crime’

Jersey authorities are examining whether the £2.4bn raised from Roman Abramovich’s 2022 sale of Chelsea FC could constitute proceeds of crime, according to newly filed Fordstam Ltd accounts, adding fresh complexity to his ongoing dispute with the UK government over the frozen funds. The documents reveal that a long‑running corruption and money‑laundering investigation in Jersey may affect a £1.4bn interest‑free loan routed through Abramovich’s offshore company, potentially influencing how much of the sale money can legally be released. The funds remain frozen under UK and EU sanctions imposed after Russia’s invasion of Ukraine, while Chelsea FC’s current owners also retain a £150m buffer against possible penalties for alleged financial rule breaches during Abramovich’s tenure.

Isle of Man keeps medium‑high national money‑laundering risk as criminals adopt more sophisticated methods

The Isle of Man’s latest National Risk Assessment concludes that the island’s overall exposure to money laundering remains medium‑high, with authorities warning that increasingly sophisticated criminal techniques, such as cyber‑enabled fraud, virtual assets, and AI‑driven methods, are reshaping how illicit funds move through and around the traditional financial system. The report highlights banking, online gambling, and trust and corporate service providers as the highest‑risk sectors, while noting that threats stem from both foreign scams and domestic issues like drug importation and labour exploitation. Despite rising complexity, officials say the island’s investigative capacity and asset‑freezing capabilities have strengthened ahead of this year’s Moneyval evaluation.

Bribery and Corruption

Clean and Green Manifesto Calls for Stronger UK Anti‑Corruption Measures to Tackle Environmental Harm

A new “clean and green” manifesto, launched by Spotlight on Corruption on 12th March 2026, and endorsed by 30 civil society organisations, outlines how stronger UK anti‑corruption efforts could help address escalating environmental harms amid a global crisis of climate change, biodiversity loss and pollution. Developed with input from groups focused on corruption, environmental protection and social justice, the manifesto identifies five consensus areas where targeted reforms would expose corrupt actors responsible for environmental damage, ensure transparency and accountability in climate‑related public spending, and safeguard environmental policy from undue influence.

Other Financial Crime

Man jailed for exploiting vulnerable homeowners through illegal sale‑and‑rent‑back scheme

Rajinder Gill has been sentenced to two and a half years in prison for running an unauthorised sale‑and‑rent‑back scheme which targeted financially distressed homeowners, pressuring them to sell their properties below market value while charging excessive and often hidden fees totalling £925,233. Working through Secure Property Consultants Ltd, Gill falsely promised quick sales, cash advances, and the ability for victims to remain as tenants, with some ultimately evicted. Two accomplices, Amandeep Heer and Jetinder Sandhu, received community‑based sentences for supporting the operation. The judge described Gill’s conduct as systematic exploitation, and the FCA has begun confiscation proceedings to compensate victims. The misconduct occurred between 2014 and 2018, despite Gill previously signing undertakings not to engage in regulated activity.

AI‑driven “evidence chains” emerge as Europe’s next tool for rebuilding digital trust and fighting financial crime

The World Economic Forum argues that Europe’s fight against money laundering and fraud increasingly depends on AI systems which can build evidence chains which link contracts, invoices, deliveries, payments, and counterparties into coherent, machine‑readable proof of legitimate activity, making risk visible when those links break. With only about 2% of criminal proceeds confiscated in the EU and organisations losing 5% of revenue to fraud, the article warns that fragmented records and labour‑intensive reviews leave major integrity gaps. AI‑based verification, deployed through banks, insurers, auditors, and regulated service providers rather than broad state surveillance, could enable continuous integrity testing aligned with the EU’s digital identity framework and new AML authority. Policymakers are encouraged to set interoperability standards and safeguards so that AI becomes a core layer of Europe’s financial‑trust infrastructure.

NACC Finds Serious Corrupt Conduct in Robodebt Scandal but Declines Criminal Referrals for Officials

In Australia, the National Anti-Corruption Commission (‘NACC’) has concluded its investigation into the unlawful Robodebt income averaging scheme, determining that two former senior public servants, Mark Withnell and Serena Wilson, engaged in "serious corrupt conduct" by intentionally misleading government officials and the Commonwealth Ombudsman. Despite these findings, the NACC will not refer the individuals for criminal prosecution, stating there is insufficient admissible evidence to prove charges beyond a reasonable doubt. The report cleared former Prime Minister Scott Morrison and three other high-level officials of corrupt conduct, attributing the failure to detect the scheme's illegality to departmental failures to provide accurate legal advice. This outcome has been labelled "devastating" by the Australian Council of Social Service (ACOSS), which criticised the lack of ministerial accountability for a programme which caused widespread financial and personal ruin for hundreds of thousands of vulnerable Australians.

Cybercrime

International taskforce dismantles ‘SocksEscort’ proxy network which hijacked 369,000 devices worldwide

Europol and partners from Austria, France, the Netherlands, the US and Eurojust have taken down SocksEscort, a criminal proxy service which covertly exploited more than 369,000 residential routers and IoT devices across 163 countries to provide anonymised infrastructure for ransomware, DDoS attacks and CSAM distribution. Operation Lightning seized 34 domains, 23 servers, and froze (US) $3.5 million in cryptocurrency, disconnecting infected modems and exposing a botnet built through a vulnerability in a specific brand of residential routers. Europol coordinated intelligence sharing, crypto tracing and malware analysis, highlighting how international cooperation can dismantle cybercrime infrastructure at scale.