Episode 245

27th April – 30th April 2026

Sanctions

UK Government Updates Assessment and Licensing Procedures for Trade Sanctions

The UK government has issued updated guidance via the Office for Trade Sanctions Implementation (OTSI) regarding the authorisation and assessment of trade sanctions licences for individuals and businesses with a "UK nexus". This framework permits specific trade activities which are otherwise prohibited under various regulations, such as those involving Russia, Iran, and Myanmar, including professional services like accounting and engineering, as well as the export of goods and technology not subject to strategic export controls. OTSI’s assessment follows a four-stage process to verify if sanctions apply to the licensee and recipient, determine if the specific activity is sanctioned, and ensure the activity's purpose is consistent with the underlying objectives of the sanctions regime. To facilitate this, applicants must provide exhaustive documentation, such as group ownership organograms, technical product specifications, and commodity codes. While standard licences are generally valid for a maximum of 24 months, the government recommends allowing at least six months for assessment, noting that the average processing time currently stands at approximately 82 working days.

Upcoming changes to UK sanctions regulations

The UK Government has announced that the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 will come into effect on 12th May, introducing several key updates to sanctions procedures. Notably, reporting thresholds for high value dealers and art market participants will now be denominated in pounds sterling (£10,000), replacing the previous euro (€10,000) benchmarks to align with forthcoming UK money laundering regulations. The changes also clarify that notices for licences can be sent electronically by OFSI and other authorities without the need for recipient consent, streamlining communications. Additionally, the Treasury debt exception will now apply to all transfers of funds throughout the payment chain, including intermediaries, and the prior obligations licensing ground has been broadened to allow OFSI greater flexibility in licensing legitimate pre-designation obligations, while safeguarding against sanctions circumvention.

OFSI General Licences for Legal Services

OFSI has issued General Licence INT/2026/9512597, allowing UK legal firms to receive payments from designated persons under most UK sanctions regimes without specific authorisation, replacing INT/2025/7323088 (which expired on 28th April 2026). The new licence expires 28th October 2026. OFSI has also updated its Financial Sanctions FAQs, amending FAQs 50 and 57, withdrawing FAQ 170, and adding FAQ 184.

US Sanctions targeting Iran and its Allies

The US Treasury’s Office of Foreign Assets Control (OFAC) has taken a series of actions aimed at curbing Iran’s ability to generate revenue through oil exports and access the international financial system, with a particular focus on networks involving China and global shipping. This week, OFAC announced sanctions against Hengli Petrochemical, a China-based refinery, and approximately 40 shipping firms and vessels alleged to facilitate Iran’s petroleum trade. These measures, enacted under Executive Order 13902, add multiple tankers and associated companies to the Specially Designated Nationals list, blocking their property under US jurisdiction and restricting transactions involving US persons. Alongside this, OFAC issued an alert highlighting sanctions-compliance risks associated with independent “teapot” oil refineries in Shandong Province, China, which are believed to import and process significant volumes of Iranian crude oil. The alert warns financial institutions about the use of the US financial system for dollar-denominated transactions and procurement, urging the application of risk-based controls and enhanced due diligence, while also outlining common evasion tactics such as front companies, intermediary brokers, and deceptive shipping practices. Furthermore, the Treasury has designated 35 individuals and entities accused of facilitating Iran’s shadow banking system, which allegedly moved tens of billions of dollars linked to sanctions evasion, oil sales, military procurement, and support for sanctioned groups. This action, part of the “Economic Fury” campaign, targets foreign front companies, exchange houses, and “rahbar” firms said to enable Iranian state-linked entities to access the global financial network. Through these coordinated efforts, US authorities seek to disrupt revenue streams supporting the Iranian government and affiliated organisations, while reminding financial institutions of increased compliance risks in relation to these activities.

Money Laundering

French national sentenced to eight years for laundering over $470 million through shell companies and cryptocurrency network

A French national, Maximilien de Hoop Cartier, has been sentenced to eight years in US federal prison for operating an unlicensed cryptocurrency exchange which laundered more than $470 million in criminal proceeds, including drug‑trafficking funds, through a network of US shell companies and bank accounts. Prosecutors said Cartier misrepresented his businesses to banks, used forged documents, and moved funds through multiple layers to conceal their origin before transferring them abroad. He previously admitted to misstatements about his operations during a separate investigation, where some seized funds were returned based on false records. In addition to the prison term, he was ordered to forfeit more than $2.3 million and several bank accounts.

Council of Europe project supports Albania in strengthening AML/CFT judicial capacity

A Council of Europe initiative supporting Albania’s efforts to counter money laundering and terrorist financing has delivered targeted training in Tirana for prosecutors and judges from specialised anti‑corruption and organised‑crime institutions, aiming to improve understanding and application of Financial Action Task Force standards. The sessions covered national risk assessment, risk‑based policy, international cooperation, and procedures for freezing, seizing, and confiscating illicit assets, while also promoting consistent practice and inter‑institutional coordination ahead of Albania’s upcoming MONEYVAL mutual evaluation.

Andorra Begins MONEYVAL’s Sixth-Round AML/CFT Evaluation with High‑Level Talks and National Training

MONEYVAL has launched its sixth mutual evaluation of Andorra, beginning with a high‑level meeting in La Vella between Chair Nicola Muccioli and Finance Minister Ramon Lladós, who emphasised the country’s commitment to the process. The visit included extensive training for more than 110 participants from Andorra’s public institutions, law‑enforcement bodies, financial authorities, and private‑sector representatives, aimed at strengthening understanding of FATF standards and MONEYVAL’s evaluation methodology.

Market Abuse

US soldier charged with using classified information to influence prediction‑market bets

The US Department of Justice has charged an active‑duty soldier with allegedly accessing and using classified military information to place and adjust bets on a public prediction market, according to the announcement from the Justice Department. Prosecutors state that the soldier is accused of exploiting restricted operational details to gain a financial advantage, and the case forms part of the department’s broader efforts to address misuse of sensitive government information.

FCA leads international effort to curb illegal finfluencer activity

The UK Financial Conduct Authority coordinated a global “week of action” with 17 regulators to address illegal finfluencer activity, combining enforcement measures, consumer‑awareness campaigns, and education for content creators who promote financial products. According to the FCA, UK actions included securing a guilty plea for unauthorised promotions, initiating further criminal proceedings, issuing targeted warning letters, publishing multiple alerts, and requesting takedowns of accounts hosting illegal adverts, which collectively reached more than two million UK users. The regulator urged social media platforms to take stronger steps to prevent unauthorised financial promotions and encouraged consumers to verify firms using its online tools.

Other Financial Crime

Court lifts anonymity order in unexplained wealth case

The Administrative Court has removed an anonymity and reporting‑restriction order in proceedings concerning an unexplained wealth order and interim freezing order obtained by the National Crime Agency, ruling that the principle of open justice, and not a presumption of privacy, should guide such decisions. The judge found that the respondent had not shown that continued restrictions were necessary, distinguishing the Supreme Court’s ZXC decision and noting earlier case law confirming that POCA applications engage open‑justice considerations even at early investigative stages. Permission to appeal was granted, and the interim order remains in place pending that appeal.

BIS paper on multifunctional cryptoasset intermediaries

The Bank for International Settlements (BIS) has published one of its occasional papers (No 27) which examines the risks and policy approaches surrounding multifunctional cryptoasset intermediaries (MCIs), emphasising that while many jurisdictions initially prioritised anti-Money Laundering and Countering the Financing of Terrorism requirements, this focus has often left significant gaps in prudential oversight. The report warns that the vertical integration of services within these "crypto conglomerates", which combine functions such as trading, custody, and lending, creates inherent conflicts of interest and threats to market integrity, such as the potential for platforms to exploit customer order flows for proprietary gain. Additionally, the paper highlights critical challenges for authorities, including the risk of regulatory arbitrage, where MCIs relocate to permissive jurisdictions to evade stricter rules, and a "striking lack of data" which continues to keep the illicit finance risks associated with the sector largely hidden from regulators.

Cybercrime

UK Biobank data listed for sale on Chinese website prompts investigation

UK Biobank reported that confidential data from roughly 500,000 volunteers was illicitly advertised for sale on Chinese e‑commerce platform Alibaba, leading the charity to suspend data access, notify regulators, and work with UK and Chinese authorities to remove the listings, while it implements additional security measures to prevent further breaches.