Episode 267

13th July – 16th July 2026

Sanctions

US Blacklists Supreme Leader Financier and Iranian Shadow Exchange Networks Following Gulf Shipping Tensions

Following a resumption of attacks on international shipping in the Strait of Hormuz, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) has targeted a sprawling financial network tied to Iranian elites. The sanctions, issued on 10th July 2026, freeze the assets of Dubai-based facilitator Ali Ansari and his Saint Kitts and Nevis-registered holding company, Smart Global Limited, which has allegedly acquired extensive real estate holdings across Europe and the Middle East to benefit Mojtaba Khamenei. Concurrently, the action blacklists several family-run partnership exchange houses in Tehran and Shiraz, along with front companies in Hong Kong and Dubai, for allegedly moving billions of dollars on behalf of blacklisted banks. While the Treasury claims these measures will isolate the regime from the global financial system, some compliance analysts suggest that the highly adaptable nature of family-run "general partnership" exchange networks may limit the long-term efficacy of these sanctions, as illicit operators are likely to rapidly establish alternative front companies to bypass Western controls. To manage the immediate impact on international partners, OFAC concurrently issued General Licence Y, which establishes a temporary wind-down period for transactions involving Smart Global Limited. The OFAC press release is here, and the Treasury press release is here.

US Sanctions Virtual Private Network and Cryptor Developers Aiding Ransomware Operations

The US Department of the Treasury's Office of Foreign Assets Control  (OFAC) has designated First VPN Service, its administrator Dmytro Rashevskyi, and Belarusian "cryptor" seller Yevgeniy Vladimirovich Silayev for supporting malicious cyber activities targeting American infrastructure. Operating in coordination with the United Kingdom, this Treasury action follows a May 2026 international law enforcement campaign which successfully seized the VPN provider’s primary website. The designated individuals allegedly offered specialised obfuscation services, such as hiding server locations and disguising malicious code as harmless programmes, which have collectively facilitated billions of dollars in losses. Although federal authorities aim to dismantle these cybercrime enablers, the persistent global availability of unmonitored digital infrastructure is likely to suggest that malicious actors can relatively quickly adapt by shifting to alternative illicit vendors.

US Imposes Sanctions on Ten Cuban Entities Tied to State Revenues and Security Apparatus

The US Department of State has designated 10 Cuban entities pursuant to Executive Order 14404, targeting state-owned enterprises and paramilitary organisations linked to the regime's funding and security operations. The sanctions target security and surveillance groups, including the Milicias de Tropas Territoriales, the Association of Combatants of the Cuban Revolution, and the Rapid Response Brigades, as well as commercial entities in the tourism, energy, maritime, and financial services sectors, including the Ministry of Tourism (MINTUR) and foreign trade group GECOMEX. As a result of these actions, all US-based assets of the designated entities are blocked, and the State Department warned that non-US persons and foreign financial institutions face potential sanctions risk for engaging in transactions with the targeted parties.

Massachusetts Man Convicted of Illegally Exporting Sensitive Microelectronics to Iran

An individual has been convicted in Boston of sanctions-related offences. Mahdi Mohammad Sadeghi, a 43-year-old dual US-Iranian national, has been found guilty of conspiring to violate and violating the International Emergency Economic Powers Act and the Iranian Transactions and Sanctions Regulations. Following a 14-day trial, court evidence showed that Sadeghi, while employed by a Massachusetts-based microelectronics manufacturer, conspired to illicitly export sophisticated, sensitive US-origin electronic components, including accelerometers, gyroscopes, and inertial measurement units, to Iran through a Swiss front company. These components ultimately benefited San'at Danesh Rahpooyan Aflak Co., an Iranian firm which manufactures navigation systems for the Islamic Revolutionary Guard Corps' military drone programme. Sadeghi is scheduled to be sentenced on 13th October 2026, while his co-defendant, Mohammad Abedininajafabadi, remains a fugitive.

UK Imposes New Sanctions on Russian GRU Officers, Lumma Stealer Cybercriminals, and Rybar Media Staff

The UK Foreign, Commonwealth and Development Office has updated its sanctions list to add 24 new designations targeting state-backed cyber actors, cybercriminals, and media operations under its cyber and Russia regimes. Under the Cyber sanctions regime, the UK designated 14 individuals and entities, including several officers of the Russian GRU Unit 29155, such as Colonel Roman Aleksandrovich Puntus and Guards General-Major Vyacheslav Stanislavovich Stafeyev, alongside OOO Impuls and multiple operators of the "Lumma Stealer" malware. Concurrently, under the Russia sanctions regime, the regulator added 10 individuals associated with Rybar LLC, which is a media company involved in destabilising Ukraine, including its Director Denis Valeryevich Vulf, Creative Director Valeriia Vladimirovna Zvinchuk, and multiple regional and video department heads. While all targeted individuals are subject to standard asset freezes and travel bans, the Rybar-linked personnel also face specialised "Internet Services Sanctions," which require UK social media services, internet access providers, and application stores to prevent users from accessing their content. The Cyber sanctions notice is here, and the Russia sanctions notice is here. The FCDO press release is here. The European Union also imposed sanctions in tandem with the UK, and its press release is here.

UK Government Amends Sanctions Listing for Cypriot Director Christodoulos Vassiliades

The UK Foreign, Commonwealth and Development Office has updated the UK Sanctions List under the Russia regulations to vary the designation of Cypriot national Christodoulos Georgiou Vassiliades. While Vassiliades remains subject to an asset freeze, travel ban, trust services sanctions, and a director disqualification sanction, the amended statement of reasons removes previous allegations concerning his professional services and association with designated oligarch Alisher Usmanov. Instead, the revised justification focuses on his role as a director of Sberbank Investments Limited, a Cyprus-based subsidiary 100% owned by Russia's state-owned PJSC Sberbank, concluding that he has been involved in obtaining a benefit from or supporting the Government of Russia.

UK Imposes Asset Freeze on Iranian-Linked "Islamic Movement of Companions of the Right"

The UK Foreign, Commonwealth and Development Office has updated the UK Sanctions List to add the Islamic Movement of Companions of the Right (IMCR) under the Iran (Sanctions) Regulations 2023. The designation subjects the entity, which also operates under several alias variations including Ashab al-Yamin, HAYI, and the Islamic Movement of the Companions of the Right Hand, to an immediate asset freeze. According to the UK government's official statement of reasons, there are reasonable grounds to suspect that the group has been involved in hostile activity directed by the Government of Iran, specifically actions which undermine the security of the United Kingdom or other countries, including attacks against persons and the sabotage of assets.

UK OFSI Amends General Licence for Sanctioned Brokerages, Extending Expiry to July 2027

The UK's Office of Financial Sanctions Implementation (OFSI) has formally amended General Licence INT/2025/6641960, extending its expiration date to 16th July 2027. Originally issued on 18th July 2025, under both the Russia and Belarus sanctions regulations, the licence exempts activities which would otherwise breach financial prohibitions to permit the transfer of investment assets held on behalf of non-designated third-party account holders from designated brokerage firms. Under the terms of the licence, asset holding institutions are permitted to transfer CSD funds and client money to non-designated brokers, provided the transactions have the consent of all involved parties, are reported to HM Treasury, and accurate transaction records are retained for a minimum of six years.

Friction and Flexibility: How Russian Fossil Fuels Navigated Sanctions and Drone Strikes in June

As Western regulators and military forces tighten their grip on Russian maritime shipping, Moscow’s fossil fuel export machine is showing signs of both strain and adaptability. Data from the Centre for Research on Energy and Clean Air (CREA) reveals a curious divergence in June 2026: Russia’s total daily fossil fuel export revenues fell by 1% to €734 million, even though export volumes actually grew by 7%. This suggests that price drops and steep discounts are eroding the Kremlin's earnings despite its efforts to pump more volume into global markets.

The physical logistics of moving Russian crude have become increasingly volatile. Drone strikes by Ukraine have hobbled domestic refining capacity, driving Russian seaborne oil product loadings to a record low in June. To compensate, Russia has pushed raw crude out of its ports. Black Sea shipments from Novorossiysk, for example, increased by 68%, even as Baltic ports like Primorsk saw declines. This shift appears to reflect a scramble to re-route exports away from vulnerable regions or adapt to localised disruptions, though whether this represents a sustainable logistical shift remains highly uncertain.

Meanwhile, the battle on the high seas is intensifying. European navies are increasingly stepping in to police the "shadow fleet" of unaligned tankers. In June alone, naval forces boarded and detained multiple shadow tankers. Among them was the Tagor, boarded by the French Navy in the Atlantic, and the Smyrtos, intercepted by UK Royal Marine Commandos in the English Channel. Under mounting international pressure, Cameroon has begun purging its registry, stripping its flag from dozens of sanctioned tankers. Rather than stopping the trade, however, these actions are likely simply to push the tankers toward alternative, less cooperative registries like Equatorial Guinea, which saw its sanctioned fleet swell in recent months.

This regulatory cat-and-mouse game extends to third-country refiners, who continue to serve as a critical bridge to Western markets. Despite the European Union’s ban on refined Russian oil products, refineries in countries such as India and Türkiye processed Russian crude and exported €814 million worth of oil products to sanctioning countries in June. The United Kingdom, for instance, received its first shipment of jet fuel from India's Jamnagar refinery, taking advantage of a specific third-country processed oil exemption. Energy policy groups like CREA argue that these loopholes effectively dilute the impact of Western measures, advocating for tighter, refinery-level restrictions. However, some economists suggest that these complex trade routes are a deliberate compromise by G7+ allies, designed to keep global oil markets supplied and prevent a politically damaging spike in domestic pump prices.

Money Laundering

Former Epoch Times CFO Pleads Guilty to $67 Million Transnational Money Laundering Conspiracy

Weidong Guan, the former Chief Financial Officer of The Epoch Times Association, Inc., has pleaded guilty in federal court to participating in a conspiracy to launder approximately $67 million in criminally obtained funds. According to the Department of Justice, Guan conspired from at least 2019 through May 2024 to purchase illegally acquired proceeds loaded onto gift cards and prepaid debit cards at discounted rates, subsequently laundering those funds back to the media organisation under the guise of fake "donations". When financial institutions flagged these transactions as suspicious, Guan knowingly provided false explanations to mislead the banks regarding the legitimacy of the funds. Guan, who now faces a maximum potential penalty of 10 years in prison, has agreed to forfeit at least $67 million, and may be ordered to pay restitution up to $67 million. Federal prosecutors noted that the criminal conduct was entirely separate from the media company’s newsgathering activities.

Other Financial Crime

UK Covid-19 Inquiry Identifies Large-Scale Waste and Bias in Pandemic PPE Procurement

The UK Covid-19 Public Inquiry has published its Module 5 report on pandemic PPE procurement, prompting responses from civil society organisations regarding the scale of waste and structural bias in emergency spending. The Inquiry's findings show that of the approximately £14.9 billion to £15 billion spent on PPE, nearly £10 billion was wasted due to failed or unusable equipment. Furthermore, the report concluded that the fast-track "VIP lane" was "inherently biased" toward suppliers with political connections to the UK government and "heightened the risk of abuse". While representatives from Transparency International UK and the UK Anti-Corruption Coalition noted that the findings mirror their prior research on systemic procurement failures, they emphasised that the resulting loss of transparency has damaged public trust and challenged the government to implement stronger emergency spend controls to prevent a repeat of these outcomes in future crises. Transparency International UK’s press release is here, and the UK Anti-Corruption Coalition is here.

Cybercrime

UK Regulators to Begin Joint Oversight of Designated Critical Technology Providers to Safeguard Financial Stability

In the UK, the Bank of England, the Prudential Regulation Authority, and the Financial Conduct Authority announced they will commence joint supervision of the first designated Critical Third Parties (CTPs) on Monday, 13th July 2026. This regulatory transition follows HM Treasury’s formal designation of four major technology and cloud infrastructure providers: Amazon Web Services EMEA SARL, Google Cloud EMEA Limited, Microsoft Ireland Operations Ltd, and Oracle Corporation UK Limited. Under the newly operationalised regime, the three regulators will jointly oversee these critical suppliers to monitor the resilience of their services and mitigate systemic risk across the UK financial sector. While this framework introduces direct regulatory oversight for designated global technology giants, authorities emphasised that the regime complements rather than replaces existing rules, meaning individual financial institutions remain fully responsible for their own outsourcing due diligence, risk management, and operational resilience planning.

Three Russian Nationals Indicted in US for Allegedly Operating $62 Million "Bulletproof Hosting" Network

Federal prosecutors in the Northern District of Ohio have unsealed a December 2024 indictment charging Russian nationals Alexander Alexandrovich Volosovik, Kirill Andreevich Zatolokin, and Yulia Vladimirovna Pankova with conspiracy to commit computer fraud, wire fraud, and money laundering. The indictment alleges that the defendants operated St. Petersburg-based "bulletproof hosting" services through Media Land, LLC and ML.Cloud, LLC, which knowingly leased resilient internet infrastructure to cybercriminals to distribute malware, run illicit marketplaces, and evade law enforcement detection. This network allegedly enabled cyberattacks targeting schools, hospitals, financial institutions, and government entities across 21 US states and multiple countries, causing over $62 million in losses. Following previous US and allied sanctions against the defendants, the US Department of State has offered a reward of up to $10 million for information leading to foreign government-linked associates of the cybercrime ring.