Episode 258

12th June – 14th June 2026

Sanctions

US Sanctions Target Foreign Networks Backing Iran’s Military Procurement

The US Department of the Treasury announced new sanctions against nine individuals and entities accused of supporting weapons procurement for Iran’s Islamic Revolutionary Guard Corps and Ministry of Defence, citing activities spanning China, Hong Kong, Iran, and Belarus . The designations, issued under multiple executive orders as part of the administration’s “Economic Fury” campaign, target companies and facilitators alleged to have enabled financial transactions, clandestine banking operations, and the acquisition of military components for Iranian defence bodies. Officials said the measures aim to disrupt overseas procurement and financial networks linked to Iran’s weapons production, while reinforcing broader efforts to restrict the regime’s access to revenue streams, including through actions against shadow banking, illicit oil trade, and digital assets.

US Sanctions Cuba’s State‑Owned Oil Company Over Energy‑Sector Activities

The United States has imposed sanctions on Unión Cuba‑Petróleo (CUPET), Cuba’s state‑owned oil and gas company, designating it under Executive Order 14404 for operating in the Cuban energy sector, according to a statement from the US Department of State. The measure blocks CUPET’s property and interests in the United States and prohibits US persons from engaging in transactions involving the company unless authorised by the Treasury Department. Officials said the action forms part of broader efforts to counter what Washington describes as the Cuban government’s misuse of energy resources and to address national‑security concerns outlined in related executive orders. The Department of State also warned that foreign entities engaging in transactions with sanctioned parties or operating in specified sectors of the Cuban economy may face sanctions exposure.

High Court Rules Lender Entitled to Possession in Sanctions‑Linked Mortgage Dispute

A High Court judge has ruled that West One Loan Ltd is entitled to take possession of a Surrey property owned by Anna Okroyan, after finding that UK sanctions did not suspend her contractual obligation to repay a multimillion‑pound bridging loan. The judgment, handed down by Mr Justice Edwin Johnson, traces a complex dispute shaped by the defendant’s designation under the Russia (Sanctions) (EU Exit) Regulations 2019, which froze her assets and prevented both parties from making or receiving mortgage payments. Although the situation may appear, at first glance, to place the borrower in an impossible position, the court concluded that the repayment duty under the loan agreement still fell due on the extended maturity date in July 2024. The judge rejected arguments that sanctions effectively paused the contract or shielded the defendant from civil liability, noting that the lender had obtained an OFSI licence permitting it to take possession and sell the property if a court order were granted. While both sides indicated they ultimately wished to see the property sold to clear the debt, the ruling clarifies that sanctions restrictions, however disruptive, do not automatically prevent a lender from enforcing security where repayment has not occurred. The judgment, West One Loan Ltd v Okroyan [2026] EWHC 1428 (Ch), is here.

Bribery and Corruption

Haiti Launches Specialised Judicial Poles to Tackle Corruption and Mass Crime

Haiti has inaugurated two specialised judicial poles designed to strengthen the country’s response to corruption, money laundering, arms trafficking, and other complex crimes, marking a significant institutional reform amid ongoing political, security, and humanitarian crises. The new chambers, one of which is focused on financial crimes and the other on mass crimes, aim to address longstanding gaps in Haiti’s justice system, where ordinary courts have struggled with cases involving hidden financial flows, links between officials and armed groups, and high risks to investigators and witnesses. Supported by the UN Office on Drugs and Crime and the Office of the High Commissioner for Human Rights, the initiative includes training for prosecutors, judges, and anti‑corruption bodies, as well as the provision of equipment and technical guidance intended to improve investigative capacity and case management.

Money Laundering

TD Bank Employee Sentenced for Role in Laundering Millions to Colombia

A former TD Bank retail employee has been sentenced to two years in prison and three years of supervised release after admitting he accepted bribes and helped launder more than $5.5 million in narcotics proceeds to Colombia, according to the US Department of Justice. Court documents state that Leonardo Ayala opened fraudulent accounts, issued over 150 debit cards to shell companies, and repeatedly unblocked cards flagged for suspicious activity, enabling more than 12,000 ATM withdrawals abroad. Prosecutors said Ayala received over $6,000 in bribes for his role, and he pleaded guilty to conspiring to launder monetary instruments and accepting bribes as a bank employee. Officials noted that the case reflects ongoing efforts to target financial facilitators whose actions threaten the integrity of the US financial system.

Europol Dismantles €336m Crypto Laundering Service Used by Ransomware Gangs

Europol has announced the takedown of “AudiA6,” a large‑scale cryptocurrency laundering service alleged to have processed more than €336 million in illicit funds for ransomware groups and other cybercriminal networks between 2022 and 2025, according to the agency’s published findings. A coordinated international operation on 10 June led to arrests in Georgia, the seizure of over 30 servers and 25 domains, the freezing of cryptocurrency assets, and the removal of both the AudiA6 platform and its associated dark‑web forum, Dark2Web. Investigators say the service relied on thousands of fraudulent exchange accounts and money‑mule identities to “clean” stolen digital assets through rapid, multi‑layered transactions. Europol linked the operation to more than 15 global cybercrime investigations and described the case as evidence of the growing professionalisation of crypto‑laundering services which underpin the wider cybercrime economy.

UK Bill Proposes Major Overhaul of AML/CTF Supervision Framework

The UK government’s newly introduced Financial Services and Markets Bill sets out reforms which would reshape the country’s anti‑money laundering and counter‑terrorist financing supervisory landscape, aiming to simplify oversight and strengthen defences against illicit finance. The legislation would transfer AML/CTF supervision of legal, accountancy, and trust or company service providers from 22 professional body supervisors to the Financial Conduct Authority, while enabling greater information‑sharing between the FCA and professional bodies and allowing ministers to create criminal offences for non‑compliance in future regulations. The Bill would also move payment systems regulation to the FCA, granting it related investigative and enforcement powers, and preserve certain criminal offences under the Consumer Credit Act 1974 as other disclosure requirements shift into the FCA’s rules framework. The Bill is here, and the Explanatory Notes to the Bill can be found here.

UK Updates AML/CTF Rules with New Thresholds, Crypto Controls and Expanded Trust Registration

The UK has enacted the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (SI 2026/621), introducing phased changes to the country’s anti‑money laundering and counter‑terrorist financing framework between June 2026 and October 2027. The reforms update the Money Laundering Regulations 2017, the Terrorism Act 2000 and the Proceeds of Crime Act 2002, revising key definitions, converting multiple transactional and due‑diligence thresholds into sterling, and strengthening requirements for higher‑risk activities. The measures introduce detailed obligations for firms operating pooled accounts, expand trust registration and beneficial‑ownership rules, including for historic UK land‑holding trusts, and refine exclusions for certain professional bodies. The regulations also enhance customer due diligence for cryptoasset‑related activity and replace Schedule 6B to modernise the regime governing changes in control of registered cryptoasset businesses. Additional amendments support improved supervisory cooperation and disclosure across the AML/CTF system. The Regulations can be found here, and the Explanatory Notes are here.

Other Financial Crime

UK Updates Overseas Business Risk Guidance for the Palestinian Territories

The UK government has updated its Overseas Business Risk guidance for the Palestinian territories, outlining the political context, economic conditions, legal considerations, and security environment that companies should assess before operating in the West Bank or Gaza. The document highlights the impact of ongoing conflict, movement and access restrictions, and the broader effects of the Israeli occupation on trade, infrastructure, and investment, while noting areas where British firms have found opportunities, particularly in professional and security services. It also reiterates UK policy on Israeli settlements, warns of legal and reputational risks linked to activities in occupied territories, and provides information on corruption risks, human rights considerations, and the challenges facing Palestinian enterprises, especially in Gaza’s severely constrained economy.

Court Confirms Special Administrators for Euro Exchange Securities UK After Financial Crime Concerns

The High Court has formally appointed special administrators to Euro Exchange Securities UK Limited after the firm ceased trading last week and chose not to contest the court’s initial decision, according to the Financial Conduct Authority. The regulator said the move follows serious concerns about the company’s operations, including systemic weaknesses in its financial crime controls, safeguarding arrangements, and governance. Joint special administrators from Teneo Financial Advisory have taken control of the business, secured material, and frozen funds, and will now oversee customer claims and the return of client money. The FCA described the case as the first of this kind under the Payment and Electronic Money Institution Insolvency Regulations 2021 and emphasised that it acted alongside government partners as part of wider efforts to disrupt financial crime and protect market integrity.

FCA Moves to Fine BancTrust CEO £99,600 for Failing to Disclose Regulatory and Financial Issues

The Financial Conduct Authority has issued a Decision Notice proposing a £99,600 fine for Carlos Ricardo Fuenmayor, Chief Executive of BancTrust, after concluding he failed to disclose three significant matters the regulator says it would reasonably have expected to know. According to the FCA, Mr Fuenmayor did not inform the regulator, either in required notifications or in application forms, that he had been investigated and later sanctioned by the US Financial Industry Regulatory Authority, nor that Venezuelan authorities had frozen his personal and corporate bank accounts ahead of an FCA inspection. The watchdog said these omissions prevented it from fully assessing his fitness and propriety, describing the failures as negligent and in breach of conduct rules requiring timely and appropriate disclosure. Mr Fuenmayor has referred the matter to the Upper Tribunal, where both sides will present their cases.

SFO Recovers Additional £96,000 Linked to Long‑Running “Green Energy” Investment Fraud

The Serious Fraud Office has secured a further £96,000 from Steven John Murphy after investigators uncovered additional assets tied to his role in an £8.2 million boiler‑room fraud involving the sham biofuel company Worldwide Bio Refineries, according to the agency’s announcement. The confiscation order, approved by Ipswich Crown Court, follows the discovery that Murphy held equity in a UK property purchased with criminal proceeds. Murphy, convicted in 2011 and previously ordered to repay more than £117,000, was one of seven men who deceived thousands of investors through high‑pressure sales tactics while diverting funds to personal accounts overseas. The SFO said total recoveries from the defendants now exceed £436,000, adding that its proceeds of crime team will continue efforts to reclaim illicit gains.

UK Launches £75m PoliceAI Centre to Accelerate Investigations and Modernise Policing

The UK government has launched PoliceAI, a new national centre designed to develop and scale artificial intelligence tools across police forces in England and Wales, aiming to reduce administrative burdens and speed up complex investigations, according to the Home Office. Backed by £75 million over three years, the initiative will pilot AI systems capable of rapidly reviewing digital evidence, translating large volumes of material, and supporting tasks such as call transcription and crime‑pattern analysis. Ministers said early trials have already demonstrated significant time savings, including reviewing hundreds of hours of video in a fraction of the usual time. The centre will also lead national efforts to counter AI‑enabled crime, including deepfake imagery, and will publish a public registry of AI tools used in policing. Officials emphasised that all deployments will be subject to independent testing and oversight to ensure accuracy, fairness and public trust.

UK Introduces New Powers to Target Hostile Foreign State Organisations

The UK government has introduced legislation granting counter‑terrorism‑style powers to tackle individuals, organisations and proxy groups acting on behalf of hostile foreign states, following a rise in state‑linked aggression and recent antisemitic attacks, according to the Home Office. The National Security (State Threats) Bill would allow the Home Secretary to designate foreign state‑linked groups, criminalise support or assistance to them, and give police and intelligence agencies enhanced tools to disrupt hostile activity, including acts carried out through organised crime networks. Ministers said the measures respond to increasing threats on UK soil, including MI5’s reported 35% rise in state‑threat investigations and multiple Iranian‑backed plots, and aim to deter those carrying out covert or violent acts on behalf of foreign governments. The bill is expected to be fast‑tracked through Parliament, with the government stating it will act immediately once the powers come into force. The press release is here, and the Bill is here. The Report of the Independent Reviewer of Terrorism Legislation is here.

Cybercrime

Two UK Education Institutions Hit by Separate Cyber-Attacks Disrupting Operations and Exposing Data

A secondary school in Buckinghamshire and the University of Nottingham have been affected by separate cyber‑attacks this week, disrupting teaching and compromising personal data, according to statements from both institutions. Great Marlow School partially closed after a malware incident disabled key IT systems, preventing staff from contacting parents and forcing the postponement of internal exams, while external assessments continued as planned. In Nottingham, the university reported that a well‑known cybercriminal group accessed a significant volume of student and alumni information including contact details, financial data and personal identifiers, prompting the institution to take systems offline, notify affected individuals and work with law‑enforcement and regulators as investigations continue. Both organisations said they are working with cybersecurity specialists to restore services and assess the full impact of the breaches.

ICO Issues Final Guidance Setting Clear Data Protection Expectations for Smart Device Industry

The UK Information Commissioner’s Office has published its final guidance for manufacturers and developers of consumer smart devices, outlining legal requirements on privacy‑by‑design, informed consent, transparency and data‑minimisation, according to the regulator’s announcement. The guidance, updated following a 12‑week consultation, emphasises that connected products often process highly sensitive information and must therefore include protective settings by default, limit data collection to what is necessary, and provide clear, accessible explanations of how personal information is used. The ICO said it will now focus on connected TVs to assess whether manufacturers are complying with data protection law, particularly around targeted advertising and user consent. Consumer group Which? welcomed the move, noting that many connected products collect more data than required and that clearer expectations should help strengthen accountability across the sector.

EU Tests Coordinated Cyber Response in Simulated Attacks on Transport Networks

This week, over the 10th and 11th June, an EU‑wide cyber exercise involving around 5,000 experts tested Europe’s readiness to respond to large‑scale attacks on rail and maritime infrastructure. The simulation, organised by the EU Agency for Cybersecurity (ENISA), was the first major test of the 2025 EU Cyber Blueprint and modelled severe operational disruption escalating into a broader cybersecurity crisis. Participants from EU institutions, national authorities, industry and partner countries examined cross‑border coordination, crisis roles and the deployment of the Cybersecurity Reserve established under the Cyber Solidarity Act. The Commission said lessons from Cyber Europe 2026 will inform future crisis‑management planning and strengthen the EU’s wider emergency preparedness frameworks.