Episode 236

27th March – 29th March 2026

Sanctions

UK Blacklists "Broken Tooth" and Nine Others in Major Crackdown on Southeast Asian Scam Centres

The UK government has significantly expanded its Global Human Rights sanctions list, targeting 10 individuals and entities allegedly central to the operation of scam centres in Southeast Asia. In a notice issued on 26th March 2026, the Foreign, Commonwealth and Development Office (FCDO) announced that these new designations are a response to systemic human rights abuses, including forced labour, servitude, and "cruel, inhuman or degrading treatment" documented within these "scam farms".

At the forefront of the new sanctions is Kuok-Koi WAN, a Chinese national widely known by the alias "Broken Tooth" and "Dragon Head". The UK identifies Wan as being responsible for the operation of scam centres where victims are held against their will to conduct fraudulent schemes. Joining him on the list are several high-profile associates of the Prince Group, including directors Weizhi PANG and Thet LI, as well as entities like Tian Xu International Technology PLC and BSquare Technology Co Ltd, all cited for providing the financial services and infrastructure necessary to sustain these criminal hubs in Cambodia.

The sanctions also target the logistical side of the "industrialised" fraud ecosystem. Soklim EANG and the entity Legend Innovation Co Ltd were designated for their roles in developing scam centre facilities through Cambodian Heng Xin Real Estate. Additionally, the UK has blacklisted Xinbi Company Limited, an entity linked to specific Tron cryptocurrency addresses, for enabling and profiting from these human rights abuses. All those named are now subject to immediate asset freezes and travel bans, and the government warned that failure to comply with these financial restrictions constitutes a criminal offence.

Supreme Court Confirms Russia Sanctions Suspended UniCredit’s Payment Obligations Under Aircraft Leasing Letters of Credit

The UK Supreme Court has unanimously held that amended Russia sanctions, specifically regulation 28(3)(c) of the 2019 Regulations, prohibited UniCredit’s London branch from making payments under letters of credit connected with aircraft leased to Russian airlines until licences were granted, thereby suspending its payment obligations during that period. The Court rejected the appellants’ argument that the regulation required a causal connection between the payment and the prohibited supply of aircraft, confirming instead that the broad statutory purpose justified a wide interpretation of “in connection with.” It further held that section 44 of the Sanctions and Anti‑Money Laundering Act (SAMLA) 2018 would have provided UniCredit with a defence against liability for debt recovery, interest, and costs where the bank reasonably believed it was complying with sanctions. The appeal by the aircraft lessors was dismissed, and UniCredit’s cross‑appeal on the SAMLA defence was allowed.

OFAC Issues New Belarus General Licence and Removes Multiple Entities from Sanctions List

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued Belarus General Licence 14 authorising certain transactions involving Belinvestbank and other entities, while rescinding Belarus Directive 1 after determining that its prohibitions are no longer warranted. OFAC also removed multiple Belarus‑related entities, including various designations of Belaruskali and the Belarusian Potash Company, from the Specially Designated Nationals and Blocked Persons List and archived General Licence 13 accordingly. Additionally, the SDN list has been updated to reflect these removals.

Bribery and Corruption

European Parliament Approves EU-Wide Anti‑Corruption Directive

The European Parliament has approved a new EU anti‑corruption directive which harmonises definitions and criminal penalties for offences such as bribery, embezzlement, and trading in influence across member states. Developed in response to the 2023 Qatargate scandal, the directive passed with strong parliamentary support and is described by EU officials as an important step toward strengthening integrity rules, though it leaves significant discretion to national governments for enforcement. The vote comes amid ongoing scrutiny of the Parliament’s own anti‑corruption reforms, stalled efforts to establish an independent EU ethics body, and wider concerns about gaps between formal rules and practical enforcement highlighted in recent OECD findings.

Market Abuse

BaFin Fines Schaeffler AG for Delay in Disclosing Inside Information

The German financial regulator BaFin has imposed an administrative fine of €180,000 on Schaeffler AG for failing promptly to publish inside information, after the company’s first‑quarter 2024 financial results diverged significantly from market expectations. Under the EU Market Abuse Regulation, companies listed on organised markets in Germany must immediately disclose precise, non‑public information which could influence financial instrument prices. BaFin determined that Schaeffler breached these ad hoc disclosure obligations, which are designed to prevent insider trading and ensure investors have equal access to market‑relevant information.

Other Financial Crime

CPS Freezes £81m London Property Portfolio with Unexplained Wealth Order

The Crown Prosecution Service has secured an Unexplained Wealth Order and Freezing Order against a Chinese national and associated UK companies, freezing a London property portfolio worth over £81 million pending a civil recovery investigation. The High Court’s decision requires the individuals and companies to demonstrate within three months that the funds used to acquire 85 properties across central and south London were lawfully obtained. If they cannot, the CPS may pursue full civil recovery without the need for a criminal conviction, using powers under the Proceeds of Crime Act 2002. The case forms part of the CPS Proceeds of Crime Division’s broader effort to target illicit international funds entering the UK property market.

Cybercrime

Google Warns Quantum Computers Could Break Current Encryption by 2029

Google has warned that large‑scale quantum computers could be capable of breaking widely used encryption systems by 2029, urging governments, financial institutions, and technology providers to begin transitioning to post‑quantum cryptography. The company stated that current encryption may become vulnerable as quantum technologies advance, even though fully capable quantum computers remain difficult to build and experts estimate broader timelines stretching into the 2030s or later. Nonetheless, intelligence agencies and cybersecurity bodies are already preparing for risks such as “store now, decrypt later” attacks, in which encrypted data harvested today could be decrypted once quantum capabilities mature.