Episode 261

22nd June – 25th June 2026

Sanctions

UK Government Extends Business Continuity Licence for Lukoil International Entities

HM Treasury has issued an amended general licence permitting the continued business operations of Lukoil International GmbH and its subsidiaries under the Russia (Sanctions) (EU Exit) Regulations 2019. The authorisation, granted by the Office of Financial Sanctions Implementation, allows individuals and entities to fulfil existing or new contractual obligations and exchange economic resources with these specific Lukoil entities. While relevant UK financial institutions are permitted to process these payments, the licence mandates that funds must be paid into frozen accounts until such time as Lukoil International is no longer owned or controlled by PJSC Lukoil. This regulatory exemption is currently set to remain in effect until 25th August 2026, though HM Treasury retains the authority to vary, revoke, or suspend the permissions at any time.

US Treasury Sanctions ISIS Financial Facilitators Across Europe, the Middle East, and West Africa

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and six entities on 22nd June 2026, for facilitating financial transactions to support the Islamic State of Iraq and Syria (ISIS). This enforcement action targets facilitators in France, Syria, Türkiye, and Nigeria who reportedly enable the group to transfer funds across its decentralised network of global affiliates. Among those designated are Miloud Abderrahmane, a French national alleged to have provided instructional material on explosives, and several money service businesses, which include Syria-based Bitcoin Xchange and Nigeria-based Nine to Nine Exchange, linked to the movement of terrorist financing. Treasury Secretary Scott Bessent stated that the measures aim to disrupt ISIS’s ability to operate and protect religious minorities from further violence. Consequently, all US-based property belonging to these designated parties is blocked, and foreign financial institutions risk secondary sanctions for engaging in significant transactions with the listed individuals and firms.

US Expands Sanctions Targeting Transnational Crime Networks and Cuban State Entities

In a series of coordinated enforcement actions, the United States government has announced new sanctions aimed at dismantling global criminal organisations and restricting the financial capabilities of the Cuban regime. On 23rd June 2026, the Department of the Treasury's Office of Foreign Assets Control designated 35 individuals and entities linked to the Prince Group Transnational Criminal Organisation, a Southeast Asia-based network allegedly responsible for large-scale cyber-enabled fraud and digital asset investment frauds targeting American citizens. This action was accompanied by a Financial Crimes Enforcement Network proposal to further isolate the Huione Group's money laundering infrastructure, specifically H-Pay Service plc, from the US financial system. Simultaneously, the Department of State designated five entities and one individual associated with Cuba’s military-led conglomerate, GAESA, and the nation's metals and mining sectors, citing their roles in supporting the regime's malign activities and internal repression. These combined measures, authorised under various Executive Orders, mandate the freezing of all US-based assets belonging to the named parties and prohibit US persons from engaging in transactions with them as part of a broader strategy to disrupt illicit financial flows and address threats to national security.

Bridging the Atlantic: US and UK Tighten Sanctions Alignment Amid Global Threats

The relationship between the United States and the United Kingdom on financial enforcement has reached a new milestone. Officials from the US Office of Foreign Assets Control (OFAC) and the UK’s Office of Financial Sanctions Implementation (OFSI) recently convened in London for a week-long dialogue aimed at refining how they target global adversaries. This collaboration, now entering its fifth year, appears to signal a shift toward a more unified "financial front" in an increasingly volatile geopolitical climate. As part of this effort, the agencies have released a new comparative guide designed to help compliance officers navigate the often-confusing technical differences between Washington’s and London’s rulebooks.

While both nations share high-level goals, the granular reality on the ground remains complex. For instance, the US employs a strict "50 Percent Rule" which aggregates the ownership of multiple sanctioned individuals to determine if a company is blocked, whereas the UK generally looks at individual holdings unless there is an obvious attempt to hide control through joint arrangements. This discrepancy may suggest that legal teams in global financial institutions still face a delicate balancing act when determining which entities are truly off-limits. The agencies are currently looking to apply lessons from the Ukraine conflict to other challenges, specifically the effort to disrupt the "shadow fleet" of aging tankers used to bypass international oil caps.

The authorities are also betting on emerging technology to manage the mounting administrative weight of global sanctions. They are exploring how artificial intelligence might handle routine tasks, such as analysing licence applications or identifying specific patterns of evasion. However, a subtle critique remains: as these agencies modernise, the "strict liability" standard remains a significant hurdle for the private sector. Under this rule, a person or firm can be held liable for a breach even if they had no knowledge that a transaction was prohibited. While both authorities offer a "discount" on fines for firms that voluntarily disclose errors, the burden of staying compliant in a rapidly changing environment continues to grow.

This London exchange is part of an ongoing cycle, with a follow-up meeting already scheduled for Washington D.C. this autumn. By synchronising terminology, moving between the American "blocked persons" and the British "designated persons", the agencies hope to reduce the friction that often slows down cross-border enforcement. This effort to align operations is likely to be tested as they move to manage the structured dismantling of older regimes in regions like Syria. For now, the focus remains on ensuring that these powerful economic tools are as clear to the public as they are impactful against their targets. An OFSI blog post marking the agreement is here.

Fraud

Banned Director Jailed After Spending Covid Loans on Holidays, Luxury Purchases and School Fees

A Cornwall man who treated pandemic support funds as a personal spending pot has been jailed for a £300,000 fraud, following a case which appears to highlight ongoing vulnerabilities in emergency loan schemes. Steven Brookes, a previously disqualified director, admitted obtaining six Bounce Back Loans by applying in his wife’s name and inflating turnover figures, despite several of the companies never having traded. Court documents show the money was channelled into a mix of family holidays, private school fees, an Audi with personalised plates, and day‑to‑day personal purchases. Only a small fraction of the funds, less than £7,500, has been repaid. Investigators say Brookes’ actions were “calculated and greedy,” noting that he had already been banned from running companies for a decade at the time of the offences. The Insolvency Service, which is now seeking recovery under the Proceeds of Crime Act, argues the case is another reminder of how quickly Covid support could be exploited and how long the clean‑up is likely to continue.

Money Laundering

FATF Plenary Sets New Direction on Illicit Finance as UK Prepares to Take the Helm

The Financial Action Task Force closed its June Plenary in Paris with decisions which may signal a more assertive phase in global efforts to curb illicit finance, though some measures appear to hinge on how effectively countries implement them. Delegates endorsed updated standards to ensure counter‑terrorism sanctions do not impede humanitarian assistance, a shift which reflects long‑running concerns from aid groups about unintended consequences of financial restrictions. The meeting also saw Algeria and Namibia removed from the FATF’s “grey list” after on‑site assessments confirmed progress, while Bosnia and Herzegovina and Iraq were newly added. Alongside these compliance moves, members approved several forthcoming publications on emerging risks, ranging from terrorist financing via social media to the misuse of underground banking networks, suggesting the task force is trying to keep pace with rapidly evolving criminal methods. The incoming UK Presidency outlined priorities centred on tackling the global fraud surge, strengthening risk‑based supervision, and improving information‑sharing partnerships, an agenda which observers say is likely to test both political will and operational capacity across the FATF’s 200‑plus jurisdictions. The Jurisdictions Under Increased Monitoring can be found here.

FATF Updates Global Standards to Safeguard Humanitarian Financial Flows

The Financial Action Task Force (FATF) has announced updates to its Recommendation 6 to ensure which targeted financial sanctions do not inadvertently obstruct the delivery of humanitarian assistance and basic human needs. Formally adopted on 23rd June 2026, these revisions align the FATF’s international standards with United Nations Security Council resolutions 2615, 2664, and 2761, which establish clear exemptions for life-saving resources. FATF President Elisa de Anda Madrazo stated that while counter-terrorism measures remain essential for collective security, they must be balanced to allow for the flow of goods and services to vulnerable populations. This reform is part of a wider strategy to mitigate the "unintended consequences" which can arise from the misapplication of anti-money laundering and terrorist financing regulations. By promoting a risk-based approach, the organisation seeks to maintain the integrity of the global financial system without compromising international humanitarian efforts.

The Watchdog’s New Teeth: FCA to Overhaul Supervision for Lawyers and Accountants

The UK’s financial landscape is bracing for a significant shift as the Financial Conduct Authority (FCA) prepares to take over anti-money laundering (AML) and counter-terrorist financing oversight for the legal and accountancy sectors. This transition may suggest a move toward a more centralised, interventionist approach to policing professional services. By shifting responsibility away from various professional bodies, the government is likely to seek a more consistent application of standards across high-stakes industries.

A central pillar of this reform is the creation of a public register maintained by the FCA, which appears to be designed as a single source of truth for identifying firms legally permitted to operate in these sectors. While the government frames this as a win for transparency and law enforcement, some industry voices remain sceptical, suggesting that a new layer of bureaucracy is likely to clash with existing statutory registers. The regulator is also gaining the power to appoint a "skilled person" to inspect firms, which is a tool traditionally reserved for the banking world, which may introduce significant administrative costs for smaller boutique practices.

The decision to extend "fit and proper" tests to legal and accountancy providers is likely to stir further debate regarding regulatory overlap. Critics from the legal sector have already pointed out that solicitors and barristers are already subject to intense scrutiny, making a parallel FCA-led test feel like a redundant and expensive exercise to some. This friction appears to highlight a fundamental challenge in the reform: how to centralise power without ignoring the distinct operational realities of different professions.

Funding for this expanded remit will come directly from the firms themselves through a cost-recovery fee model. This move is likely to put pressure on the financial resilience of sole practitioners who already pay for professional body memberships. While the government promises a "smooth and low-burden" transition, the eventual disappearance of the Office for Professional Body AML Supervision (OPBAS) marks the end of the current fragmented model. For now, the professional services world is left to wonder if these new "supervisory teeth" will effectively deter criminal cash or simply increase the paperwork for legitimate business owners. The Consultation Response is here.

Texas Resident Pleads Guilty to Laundering $1.2 Million from International Elder Fraud Network

Chase Harris, a 36-year-old from Keller, Texas, pleaded guilty on 22nd June 2026, to conspiracy to commit money laundering for his role in an international technology-support scheme which defrauded elderly victims of more than $1.2 million. According to court documents, the operation targeted at least 25 individuals across the United States between November 2023 and July 2024 by using deceptive computer pop-up ads and impersonating federal agents to extract payments for fictitious services. Harris admitted to receiving victim cheques through several entities he controlled, laundering the proceeds, and transferring the majority of the funds to a co-conspirator’s business in India in exchange for a fee. As part of the resolution, Harris agreed to pay approximately $1.24 million in restitution and currently faces a maximum potential sentence of 20 years’ imprisonment when he is sentenced on 29th October 2026.

OCC Proposes New AML and Sanctions Compliance Standards for Payment Stablecoin Issuers

The Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking on 22nd June 2026, aimed at implementing Bank Secrecy Act (BSA) and sanctions compliance standards for permitted payment stablecoin issuers (PPSIs). This regulatory step, mandated by the Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), requires OCC-supervised PPSIs to maintain anti-money laundering and countering the financing of terrorism (AML/CFT) programmes in alignment with regulations from the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control. The proposal seeks to establish a formal supervision and enforcement framework for these entities while creating a consultation process between the OCC and FinCEN for significant regulatory actions. Furthermore, the rule would allow PPSIs to share specific non-public information with the FinCEN Director relating to potential enforcement matters. The OCC is currently seeking public comment on all aspects of the proposed framework for a period of 30 days following its publication in the Federal Register.

Justice Department Seizes Digital Infrastructure Linked to Huione Group’s Global Money Laundering Network

The US Department of Justice has announced the seizure of a cloud computing account which reportedly served as the backend infrastructure for subsidiaries of the Cambodia-based Huione Group. Federal authorities allege that this conglomerate, specifically through its Huione Guarantee platform, provided a technological backbone which allowed billions of dollars in fraud proceeds from Southeast Asian fraud centres and cryptocurrency investment schemes to be laundered into the legitimate banking sector. The investigation revealed that the seized account supported digital marketplaces used for facilitating human trafficking, malware distribution, and the sale of stolen identity data. This enforcement action, conducted as part of the FBI's "Operation Riptide," was accompanied by a proposal from the Financial Crimes Enforcement Network (FinCEN) to extend existing sanctions to include H-Pay Service plc, an entity identified as a key component of the Huione Group's money laundering apparatus. By targeting the service-level infrastructure used by these networks, law enforcement seeks to disrupt the fundamental mechanisms which enable large-scale cybercrime and victimise individuals globally.

Market Abuse

Four Individuals Plead Guilty in Million-Dollar Insider Trading Scheme Involving Secondary Offerings

On 22nd June 2026, John Lowe and Richard Ringel pleaded guilty to securities fraud in federal court, joining co-conspirators David Cooper and Randy Grewal in admitting to a multi-year insider trading scheme which generated over $1 million in illicit profits. Between 2018 and 2024, the group illegally obtained material non-public information (MNPI) regarding the timing and pricing of secondary stock offerings from investment banks, often through Cooper’s position as a registered broker. This confidential data allowed the defendants to execute short sales in advance of public announcements for companies such as Chicken Soup for the Soul Entertainment and Tivic Health Systems. The investigation, which utilised judicially authorised wiretaps, revealed that broker-dealer employees breached their confidentiality duties to induce customers to buy shares in the offerings, thereby generating compensation for the firm. Each defendant now faces a maximum sentence of 20 years’ imprisonment as federal authorities emphasise their commitment to rooting out actors who compromise the integrity of the financial markets.

SEC Charges New Jersey Man in $2.7 Million Insider Trading Scheme Involving Misappropriated Information

The Securities and Exchange Commission (SEC) announced charges on 23rd June 2026, against Justin Jennings and his entity, Vortex Strategies LLC, for an alleged insider trading scheme which yielded approximately $2.7 million in illicit profits. According to the SEC's complaint filed in the US District Court for the District of New Jersey, Jennings misappropriated material non-public information from his romantic partner, who served as an account executive at a strategic communications and investor relations firm. The regulator alleges that Jennings accessed the partner’s work laptop without authorisation to obtain confidential details regarding mergers, acquisitions, and earnings announcements for several of the firm’s public clients, subsequently trading in the securities of eight companies ahead of significant corporate disclosures. While the SEC seeks permanent injunctions and civil penalties for violations of federal antifraud provisions, the US Attorney’s Office for the District of New Jersey has concurrently announced parallel criminal charges against Jennings in relation to the matter.

Other Financial Crime

Global Forum Reports Steady Gains in Tax Transparency Compliance

Jurisdictions are continuing to strengthen tax transparency and the effective exchange of information, according to a new Global Forum report which consolidates monitoring outcomes for 39 jurisdictions. The update notes that nearly one third of the 217 recommendations issued during peer reviews have already been addressed, with progress underway on most remaining items. Improvements include stronger legal frameworks for beneficial ownership information and wider use of centralised registers, though the report highlights that only 25 of 99 recommendations in this area have been fully met. Authorities also continue to prioritise better access to accounting records, and some jurisdictions have been asked to submit action plans due to delays. The report records more than 18,000 information‑exchange requests across 2023–2024, with 84% answered within six months, reflecting sustained operational effectiveness.

SFO Tracks Down Hidden Assets Linked to Fraudster

The Serious Fraud Office has secured a further £491,967 from convicted fraudster Alan Edwin Gardner after investigators uncovered new assets linked to his long‑running fraud targeting British immigrants in Jakarta. The discovery appears to show that Gardner, now 57, continued to accumulate property equity, luxury vehicles, and bank holdings well after his 2009 conviction for persuading overseas investors to hand over their savings on the false promise of high‑return investments supposedly placed with UBS. While victims believed their money was being carefully managed, the funds were instead spent on personal expenses and even used to offset gambling losses. Officials say the latest recovery effort reflects the agency’s view that confiscation orders are not a one‑off exercise but an ongoing obligation, particularly when offenders attempt to shield assets over time. The SFO has already reclaimed more than £186,000 under the original order, and the new uplift will return additional funds to the public purse as the agency continues to pursue the principle that “crime never pays.”

Europol and INTERPOL Formalise Expanded Cooperation Strategy Against Transnational Crime

Europol and INTERPOL have solidified their collaborative efforts against global criminal networks by establishing a new framework of Joint Key Operational Priorities (JKOP), designed to harmonise cross-border responses to organised crime and counter-terrorism. This strategic alignment, formally signed in Toledo, Spain, appears to signal a more integrated phase of intelligence sharing and operational coordination between the two major law enforcement bodies. By merging Europol’s regional support for EU member states with INTERPOL’s extensive international reach, the agreement aims to disrupt sophisticated syndicates involved in diverse sectors such as cybercrime or financial fraud. The effectiveness of such cooperation was recently demonstrated in targeted initiatives like Operation Global Chain, which reportedly resulted in the arrest of 158 human traffickers. While these formalised priorities may suggest a more proactive stance toward global security, the long-term impact is likely to depend on the continued technical and analytical synergy of both organisations in an increasingly complex digital landscape.

Paper Shields: The Global Gap in Whistleblower Protection

On World Whistleblowers Day, which is 23rd June, the global community is facing a sobering reality: while nearly 150 nations now have laws on the books to protect those who expose wrongdoing, the lived experience for many remains one of isolation and punishment, according to new research from Transparency International. This proliferation of legislation may suggest a global consensus on the value of corporate and governmental transparency, yet the bridge between statutory language and actual security appears to be crumbling under the weight of poor enforcement. In roughly 60 countries, these protections are relatively comprehensive, but elsewhere, they are often little more than fine print buried in broader labour codes. Laws matter, certainly. However, without active enforcement, they provide a false sense of security which can lead an unsuspecting employee directly into a professional trap.

The consequences of speaking up are rarely as clean as a legal textbook would imply. Consider the experience of a teacher in Rwanda who reported unauthorised school fees; despite his disclosure leading to official action, he was quickly transferred to a post far from his family in what was eventually recognised as a retaliatory move. Similarly, an Italian municipal police officer found that reporting misconduct resulted in a hostile work environment and a demotion to lesser duties. These specific instances is likely to highlight a broader trend where retaliation takes the form of "soft" punishments, such as exclusion from meetings, reputational attacks, or reassignment, which are difficult to prove in court.

A subtle critique of the current landscape is the shifting burden of proof, which often rests too heavily on the individual. A whistleblower frequently spends years in litigation and significant financial resources just to demonstrate that their career setback was a direct result of their honesty. This "chilling effect" is likely to mean that for every person like Sophie Zhang, who helped expose social media manipulation, there are many others who choose silence over the risk of professional exile. The risk is not distributed equally. Those on the fringes of an organisation, such as contractors or volunteers, often find themselves entirely outside existing legal frameworks.

This enforcement gap appears to be the primary hurdle in 2026. While the EU Whistleblowing Directive has pushed member states toward meaningful reform, many reporting systems still fail to guarantee the anonymity which often dictates whether a person comes forward in the first place. Until organisations stop viewing those who speak up as troublemakers and start recognising them as guardians of the public interest, the "protection" promised by global governments will remain a theoretical comfort rather than a practical reality. When no one feels safe enough to speak, the public eventually pays the price for the corruption which remains hidden.

Cybercrime

Europol Expands Cyber Intelligence Efforts Through New Public‑Private Partnership Pilot

Europol has launched a pilot Cyber Intelligence Extension Programme which aims to deepen cooperation between law enforcement and private‑sector specialists, a move which appears to reflect growing concern about the speed and scale of cybercrime across Europe. The initiative brings industry experts into Europol’s headquarters in The Hague to work directly with analysts from the European Cybercrime Centre, creating what officials describe as a more agile way to track fast‑moving threats. Early results may suggest the model’s potential: Microsoft, one of the first partners, identified nearly 400,000 Windows devices infected with the Lumma Stealer malware, enabling authorities to disrupt more than 2,300 command‑and‑control domains linked to large‑scale data theft. While the programme is framed as a natural extension of Europol’s strategy to “deliver security in partnership,” some observers note that its success will likely depend on how consistently intelligence can be shared across borders and how quickly operational conflicts can be resolved. Even so, the agency argues that the approach offers clear advantages, from European‑level disruption to faster dissemination of emerging threat information, as it tries to build a more resilient digital environment for citizens and critical infrastructure.

The Great Digital Drift: How Asia’s Boom Became a Cybercriminal Frontier

The Asia-Pacific region is currently witnessing a digital transformation so rapid that local law enforcement is struggling to keep pace. According to a fresh assessment from INTERPOL, cybercrime now accounts for nearly a third of all recorded offences in over half the nations surveyed. This surge appears to be fuelled by an "industrial scale" of organised networks which have pivoted from manual hacks to automated, AI-driven schemes. It is a sobering shift.

Phishing remains the primary weapon of choice, and the numbers are telling. Residents in the region click on malicious links at roughly twice the global average, with about 5.5 out of every 1,000 people falling for these decoys every month. This vulnerability is likely to stem from the sudden explosion in mobile banking and cloud-based services, which has outstripped public awareness. While private sector partners like TrendAI helped mitigate over 6.5 billion threats last year, the sheer volume of attacks indicates that digital defences are under constant, heavy pressure.

The report highlights a particular anxiety surrounding the rise of deepfakes. Mentions of this technology on cybercriminal Telegram channels and forums popular in Southeast Asia jumped by 600 per cent in just a few months during 2024. This trend may suggest that criminal syndicates are moving beyond simple text-based fraud toward more convincing, synthetic identity theft. However, a subtle critique of the current regional response appears to emerge when looking at the resources available. While two-thirds of member countries are now using AI for predictive analysis or threat detection, smaller island states and developing jurisdictions are still operating with significant gaps in forensic tools and technical capacity.

Ransomware also remains a persistent thorn, with over 135,000 recorded incidents hitting sectors like manufacturing and real estate in 2024. The business model has evolved into "ransomware-as-a-service," effectively lowering the barrier to entry for launching high-impact attacks. Law enforcement is pushing for a "whole-of-society" approach, involving closer ties between governments and industry. For now, the data indicates that the criminals currently hold a technological advantage. Strengthening international cooperation is no longer just a policy goal; it has become a necessity for economic survival in a region where the internet is growing faster than the laws meant to govern it. The press release is here. The report is linked in the press release.

Five Eyes Intelligence Alliance Warns of Imminent Offensive Capabilities in Frontier AI Models

Intelligence agencies from Australia, the United States, the United Kingdom, New Zealand, and Canada have issued a rare joint statement warning that advanced AI models capable of launching sophisticated cyber-attacks against governments and private sectors are likely only months away. This public advisory follows recent actions by the United States government to restrict foreign national access to Anthropic’s "Fable" AI model due to national security concerns. The Five Eyes alliance noted that while AI may eventually bolster defensive measures, its current trajectory significantly accelerates the scale and complexity of cyber threats by automating the discovery of vulnerabilities and the creation of digital exploits. Emphasising that cyber risk must now be managed as a fundamental business and leadership responsibility, the agencies have called for a comprehensive, multi-sector response to ensure long-term resilience and market stability in the face of these rapidly evolving technological challenges.

Convictions Secured Following £29 Million Cyber Attack on Transport for London

Two individuals, Thalha Jubair and Owen Flowers, have entered guilty pleas at Woolwich Crown Court regarding a significant cyber-attack on Transport for London (TfL) which resulted in estimated losses and recovery costs of £29 million. A joint investigation by the National Crime Agency and City of London Police revealed that the pair, identified as members of the "Scattered Spider" criminal collective, infiltrated TfL's network in late 2024, compromising systems such as Oyster refunds and photocard applications while necessitating a mandatory password reset for all 28,000 employees. Evidence seized during the inquiry further linked the group to the unauthorised infiltration of healthcare providers in the United States. Sentencing is scheduled for 16th July, marking the conclusion of a complex investigation into an incident which authorities describe as a major disruption to a key component of the UK's critical national infrastructure.