Episode 263

29th June – 2nd July 2026

Sanctions

US Government Imposes Multi-Agency Sanctions Targeting Military Procurement and Recruitment in Sudan Conflict

The United States government has enacted a series of coordinated measures targeting networks fuelling the civil war in Sudan. The Treasury’s Office of Foreign Assets Control (OFAC) designated eight individuals and entities involved in weapon procurement and foreign fighter recruitment for both the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF). These actions specifically targeted firms supplying explosives and military equipment to the SAF, as well as individuals associated with a Colombian network recruiting fighters for the RSF. Concurrently, a press statement from spokesperson Thomas "Tommy" Pigott outlined a second round of sanctions under the Chemical and Biological Weapons Control and Warfare Elimination Act (CBW Act). These additional measures oppose international financial assistance to Sudan and bar Sudanese state-owned air carriers from operating within the United States. Both statements urged the warring parties immediately to implement a humanitarian truce and called on external actors to halt all military and financial support to the belligerents. The State Department press release is here.

US Treasury Launches Online Portal to Streamline Sanctions Delisting Petitions

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has launched a new online Reconsideration Portal to streamline requests for removal from its sanctions lists. The digital platform is designed to reduce procedural delays by guiding petitioners to provide necessary information upfront, minimising the back-and-forth questionnaire exchanges which have historically slowed down determinations. Through the new portal, designated individuals and entities can also request "courtesy documents," which contain certain unclassified, non-privileged information which served as the basis for their sanctions listing. To support the transition, OFAC updated its frequently asked questions and published two quick-reference guides outlining best practices and specific content requirements for submissions. Although the agency is currently accepting multiple submission formats, it strongly encourages immediate adoption of the portal as it plans to transition away from email-based delisting petitions in the future.

US Treasury Targets Fuel Smuggling Networks Funding Jalisco New Generation Cartel

The US Department of the Treasury initiated a coordinated regulatory sweep to disrupt cross-border fuel smuggling and tax evasion networks which generate substantial revenue for the Cartel de Jalisco Nueva Generación (CJNG). The Office of Foreign Assets Control (OFAC) sanctioned two Mexican nationals, Oscar Guillermo Juraidini Silva and J. Refugio Ruiz Villagomez, along with nine companies operating in fuel transportation, real estate, and logistics, freezing their US-based assets and barring them from the US financial system. Concurrently, the Financial Crimes Enforcement Network (FinCEN) issued a supplemental alert advising financial institutions to detect and report transactions linked to "fiscal fuel theft" (known as huachicol fiscal), where gasoline, diesel, and other fuel products purchased in the United States are smuggled across the border to evade Mexico’s fuel import taxes. Jointly coordinated with Mexican financial intelligence and domestic US law enforcement, these measures seek to fracture the cartel's primary non-drug revenue streams, which are used to fund local corruption, political influence, and regional violence. The State Department press release is here, OFAC’s here, and FinCEN’s Alert here.

US Treasury Announces Counter-Narcotics Additions and Russia Sanctions Removals

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has updated its Specially Designated Nationals List, executing a series of counter-narcotics additions alongside Russia-related removals. Under its counter-narcotics authorities, OFAC designated Mexican nationals Oscar Guillermo Juraidini Silva and J. Refugio Ruiz Villagomez, as well as multiple logistics, transportation, and real estate entities in Mexico and the United Kingdom, for their alleged involvement in cross-border fuel smuggling schemes supporting the Cartel de Jalisco Nueva Generación (CJNG). Concurrently, the agency removed four India-based engineering and technology firms from its Russia-related sanctions framework under Executive Order 14024. Alongside these list modifications, the Treasury published its quarterly report detailing licensing decisions made between January and March 2026 under the Trade Sanctions Reform and Export Enhancement Act (TSRA) for the export of agricultural products, medicine, and medical devices to Iran.

HMRC Names Petrofac in First Public Russia Sanctions Compound Settlement

HM Revenue and Customs (HMRC) has named energy services firm Petrofac Facilities Management Limited (PFML) after the company agreed to a £569,157 compound settlement for breaching UK-Russia sanctions regulations. The violations took place during 2022 and 2023 as PFML was winding down its Russian operations, during which time it supplied sanctioned industrial goods and related technical assistance to individuals connected to Russia. Because the company self-reported the breaches and cooperated fully with the investigation, HMRC settled the matter out of court, marking the first time the agency has named a corporate offender under this settlement process. Moving forward, HMRC intends to include public disclosure as a condition for strategic export and sanctions settlements where appropriate, aiming to increase regulatory transparency and align its enforcement practices with peer bodies like the Office of Financial Sanctions Implementation.

Money Laundering

Fintech in the Chat: How Terrorists Are Quietly Hijacking Social App Payments

The Financial Action Task Force (FATF) has issued a warning that terrorist groups are systematically exploiting the commercial features of digital communication and streaming platforms (SMSPs) to raise and move illicit funds. Once simple tools for messaging, these services have quietly grown into complex financial hubs. The underlying technology has shifted. It is fast, global, and highly integrated. Users can now send peer-to-peer transfers, purchase virtual goods, buy ad-free subscriptions, or access cross-border payment tools within a single interface. These transactional capabilities have made it easier for illicit networks to disguise their activities. Typically, campaigns begin on public social feeds to build emotional engagement. Once trust is established, organisers migrate supporters to private chat groups to share rotating virtual asset wallets and QR codes. Other schemes exploit the creator economy directly. Extremist sympathisers can use live-stream tipping or digital subscriptions to funnel micro-donations directly to illicit actors. This tactic effectively blends extremist funding with legitimate transactional noise.

Regulating this space is likely to be a massive headache. Currently, SMSPs are not officially subject to anti-money laundering or counter-terrorist financing obligations under global FATF standards. This structural exclusion appears to leave national frameworks flat-footed. In fact, FATF found that less than 30% of surveyed jurisdictions include SMSPs in their national risk assessments. When tech platforms do try to intervene, their compliance efforts often prioritise content moderation rather than transaction tracking. Removing violent propaganda is one thing; auditing complex payment trails is another. Critics might argue that forcing tech platforms to police financial transactions would blur the line between a communication utility and a bank. The FATF suggests that if an SMSP directly controls or facilitates custody, transfer, exchange, or facilitation of funds, it may technically cross the line into becoming a regulated financial institution. However, distinguishing between a neutral technical host and an active financial intermediary remains an unresolved challenge.

Addressing these threats is likely to require deep cooperation across national authorities, financial entities, tech platforms, and international bodies. Law enforcement relies heavily on platforms preserving transaction data and sharing early telemetry. Conversely, tech companies need specific contextual indicators from intelligence agencies to design effective detection algorithms. Without a highly structured framework for public-private data exchange, these collaborative efforts may suggest more of a theoretical ideal than an operational reality. Meanwhile, digital finance is evolving faster than global policy, leaving governments to chase moving targets. The Report is here.

Council of Europe Coordinates Financial Crime and Cryptocurrency Investigation Training in Malta and Moldova

In late June 2026, the Council of Europe spearheaded two separate training initiatives designed to bolster international and domestic capacities against complex financial crimes. First, from 22nd to 26th June, the Council of Europe’s MONEYVAL committee and the Financial Action Task Force (FATF) co-hosted an intermediate-level Standards Training Course in Valletta, Malta, where 41 practitioners from various jurisdictions completed training on combating money laundering and terrorist financing. Simultaneously, from 23rd to 25th June, the Council of Europe conducted a specialised three-day workshop in Chisinau, Moldova, designed to help Moldovan law enforcement, prosecutors, and judges investigate economic crimes involving crypto-assets. This initiative in Moldova focused on practical training, including blockchain analytics and simulated cryptocurrency money laundering investigations, better to equip local judicial and investigative authorities to manage the rapid expansion of digital crime.

Bribery and Corruption

Former NBA Players and Agent Indicted in Alleged Sports Bribery and Game-Fixing Conspiracy

Federal prosecutors in Brooklyn have unsealed an indictment charging six individuals, including former National Basketball Association (NBA) players Malik Beasley and Edward Davis, and current player agent Paolo Zamorano, for their alleged roles in an illegal sports betting and bribery scheme. According to the US Attorney's Office for the Eastern District of New York, the co-conspirators allegedly bribed Beasley, who was playing for the Milwaukee Bucks in early 2024, intentionally to manipulate his on-court performance, including underperforming or overperforming relative to specific point and rebound statistics. The group then allegedly used this non-public information to place successful fraudulent wagers totalling hundreds of thousands of dollars across multiple betting operators, rewarding Beasley by paying down or reducing his personal gambling debts. The defendants face multiple federal charges, including wire fraud conspiracy, bribery in sporting contests, and money laundering conspiracy.

UK and Germany Join European Union Anti-Corruption Initiative in Ukraine

During the Ukraine Recovery Conference in Gdańsk, the governments of the United Kingdom, Germany, and Denmark signed an agreement confirming that the UK and Germany will officially join the European Union Anti-Corruption Initiative (EUACI) in Ukraine. Under this agreement, the UK has committed £2,400,000 and Germany has pledged €3,500,000 to the programme, which will continue to be co-funded by the European Commission and implemented by Denmark. The initiative provides critical assistance to Ukraine’s domestic anti-corruption institutions, parliamentary committees, ministries, civil society organisations, and independent investigative media to support governance reforms and advance the country's path toward European Union integration. Key signatories, including UK Deputy Prime Minister David Lammy and German State Secretary Niels Annen, emphasised that transparent, accountable governance serves as a necessary foundation for Ukraine's long-term sustainable recovery and eventual EU membership. With the additional funding and administrative support, the EUACI plans to expand its operational reach across all components, introducing a new priority focused on mainstreaming anti-corruption measures at the sector level.

Nigerian Anti-Corruption Commission Proposes Educational Framework for University Law Programmes

During a zonal workshop in Kano, Dr. Musa Adamu Aliyu, SAN, Chairman of Nigeria's Independent Corrupt Practices and Other Related Offences Commission (ICPC), advocated for integrating anti-corruption education directly into the curricula of Nigerian universities and the Nigerian Law School. Dr. Aliyu emphasised that while investigations and prosecutions remain vital, long-term prevention must focus on instilling ethical standards during formal legal training when professional values are first formed. Rather than prescribing a rigid curriculum, the ICPC plans to collaborate with legal educators to develop a flexible framework which strengthens integrity across the profession. This initiative, which follows a prior engagement in Abuja and precedes an upcoming session in Lagos, seeks to bolster public confidence in the justice system by addressing ethical decision-making before future lawyers begin their careers.

The Compliance Gap: Why Anti-Corruption Rules Still Struggle to Bind Europe's Top Leaders

European governments have made gradual progress in implementing anti-corruption standards, yet deep-seated compliance gaps persist at the highest levels of political power. The finding comes from the newly released annual report of the Council of Europe’s anti-corruption body, GRECO, published on 30th June 2026, which details how member states frequently struggle to police their own executive branches. While overall implementation of the watchdog's recommendations has ticked upward, top officials, such as ministers and their political advisers, regularly remain shielded from strict oversight. For instance, although states have fully or partially implemented 69.6% of recommendations targeting central governments, key safeguards on lobbying and post-employment "cooling-off" periods remain largely unfulfilled. This discrepancy suggests that while governments are willing to reform broader public services, they appear highly hesitant to impose the same level of accountability on their own political leadership.

Interestingly, policing the police has proven somewhat easier than policing politicians. Recommendations aimed at law enforcement agencies saw their implementation rate climb to 77.2%. This difference may stem from the rigid, hierarchical nature of police departments, where internal codes of conduct are more straightforward to enforce than the fluid, discretionary world of high-level political appointments. But even when rules are officially adopted, the timeline for reform is often incredibly drawn out. In the evaluation round covering parliamentarians and judges, nearly half of the compliance procedures reviewed in 2025 were deemed "globally unsatisfactory". Many of these reforms have been dragging on for nine to thirteen years, a timeline which critics argue dilutes the urgency of the initial anti-corruption findings.

Some defenders of the current pace argue that constitutional differences make sweeping, standardised integrity checks difficult to implement. Discretionary political appointments are a deeply rooted tradition in many democracies, and designing post-employment bans which do not unfairly restrict an individual’s career is a complex legal balancing act. Nevertheless, GRECO is already moving its focus to local and regional governments under its newly launched sixth evaluation round, with Estonia and the Slovak Republic undergoing the initial assessments. As public trust in central institutions wavers amid geopolitical tensions, local administrations are likely to face much sharper scrutiny. The Report is here.

Other Financial Crime

UK Government Implements Major Reforms to Criminal Confiscation and Proceeds of Crime Regime

The UK Home Office has published six guidance documents detailing significant statutory updates to the criminal confiscation regime under Part 2 of the Proceeds of Crime Act 2002, as amended by the Crime and Policing Act 2026. Designed to make confiscation orders more realistic and proportionate, the reforms reduce the threshold for triggering "criminal lifestyle" assumptions from three offences to two, while simultaneously introducing prosecutorial discretion over whether the court should make a criminal lifestyle determination. Additionally, the legislation places hidden asset determinations on a statutory footing, establishes a new core legal objective to deprive defendants of their criminal benefits so far as it is within their means, and grants judges discretion to reduce benefit calculations when applying the full statutory amount would result in injustice. To reduce procedural delays, the courts are now required at the sentencing hearing to set out a strict timetable for confiscation proceedings, which may include newly established "early resolution of confiscation" meetings where prosecutors, defendants, and third parties can resolve asset and benefit disputes out of court.

Cybercrime

UNSW Cyber Security Summit Highlights AI-Driven Threats and the Vital Role of Human Skills

The University of New South Wales (UNSW) has published the keynote address from its Cyber Security Summit, where Professor Attila Brungs outlined the expanding intersection of artificial intelligence, cybersecurity, and higher education. Addressing an audience of government, industry, and academic partners, Brungs emphasised that cybersecurity has transitioned from a niche technical discipline into a core pillar of national security and economic resilience. The address highlighted escalating challenges in the digital landscape, citing a ransomware attack on the educational platform Canvas which resulted in a ransom payment, as well as the restricted release of Anthropic's advanced "Claude Mythos" model due to its significant cyber vulnerability discovery capabilities. Brungs argued that while AI is increasingly deployed as both a defensive and offensive cyber tool, the rapid evolution of technology demands that universities focus on cultivating uniquely human capabilities to prepare the future workforce for an AI-augmented society.

UK Law Enforcement Launches Anti-Ransomware Campaign as Reported SME Attacks Rise

UK businesses are being warned, especially small and medium-sized enterprises (SMEs), to strengthen their cyber defences in response to a persistent ransomware threat. Newly released data reveals that 323 organisations reported ransomware attacks between April 2025 and March 2026, with SMEs accounting for more than 50 percent of the incidents. While reported financial losses rose by 50 percent to approximately £270,000, authorities note that actual losses are likely much higher due to widespread underreporting by firms seeking to avoid compliance penalties or the perception of supporting criminal activity. The manufacturing, scientific and technical, and education sectors were identified as the most heavily targeted industries. To counter these attacks, Report Fraud and the National Cyber Security Centre are advising businesses to implement proactive security measures, such as regular data backups and strong access controls, while emphasising that law enforcement does not endorse or condone paying ransom demands. The City of London press release linking the various toolkits available can be accessed here.