Episode 276

28th August – 30th August 2026

Sanctions

US OFAC Enacts New Counter-Terrorism Designations and Updates Russia-Related Diamond Import Licences

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has announced several counter-terrorism designations and updated key general licences. Under Executive Order 13224, as amended, OFAC has added two individuals, Zaid Abdulnasser and Rawa Alsagheer, along with three entities, including the Italian data hosting provider Autistici Inventati, the transnational advocacy organisation Masar Badil, and the UK-based group Palestine Action, to the Specially Designated Nationals and Blocked Persons (SDN) List. Concurrently, OFAC issued Counter Terrorism General Licence 36, authorising the wind-down of transactions ordinarily incident and necessary to wind down activities involving Autistici Inventati through to 25th September 2026. Additionally, the agency issued Russia-related General Licence 104B, which replaces and supersedes General Licence 104A, authorising transactions ordinarily incident and necessary to the importation and entry into the United States of non-industrial diamonds weighing 0.5 carats or greater and 1.0 carat or greater through to 1st September 2027, provided the diamonds were physically located outside of the Russian Federation prior to their respective 2024 cut-off dates and have not been exported or re-exported from Russia since.

UK FCDO Amends Afghanistan Sanctions List with Administrative Corrections for Haqqani Network Leaders

The UK Foreign, Commonwealth and Development Office (FCDO) has updated the UK Sanctions List under the Afghanistan (Sanctions) (EU Exit) Regulations 2020 to apply administrative corrections to the entries of two designated individuals. The variations update the identifying information for Sirajuddin Jallaloudine Haqqani, who has headed the Haqqani Network since late 2012, and his father, the active Taliban leader Jalaluddin Haqqani. The amendments introduce a specific passport number (P05076602) for Sirajuddin Haqqani, while correcting the town of birth to "Neka District, Paktia Province" for Jalaluddin Haqqani. Both individuals remain subject to an asset freeze and travel ban under UK sanctions legislation.

UK’s Office of Trade Sanctions Implementation Publishes Inaugural Annual Review Detailing 178 Breach Investigations

In the UK, the Department for Business, Innovation, Science and Trade (BIST) has published the first annual review of the Office of Trade Sanctions Implementation (OTSI). The review, introduced by Minister of State for Trade Anas Sarwar, outlines the agency's performance during the 2025–26 financial year following its creation in October 2024 to oversee the civil enforcement of UK trade sanctions. During this foundational year, OTSI received 178 suspected breach reports, with the financial and legal services sectors accounting for 62% (111 cases) of the intake, and the majority of cases (156) involving the Russia sanctions regime. The agency closed 104 enforcement cases, resulting in 41 closures where no breach was identified and 40 referrals to HM Revenue & Customs (HMRC) for criminal enforcement or other jurisdictional matters. Although OTSI did not issue any civil monetary penalties during this period, the agency reported a substantial number of active investigations at an advanced stage. Additionally, OTSI processed 51 licensing applications (50 for Russia and one for Iran), granting 17 licences and refusing two, with an average completion time of 96 working days. Looking ahead, the report highlights the expansion of OTSI's remit in April 2026 to include the licensing of goods alongside services, as well as the implementation of Sanctions End-Use Controls (SEUC) proactively to prevent the diversion of sensitive exports to sanctioned destinations through third countries.

UN and UK Align Afghanistan Sanctions Lists with Updated Passport Data for Taliban Official

The United Nations Security Council Sanctions Committee established pursuant to resolution 1988 (2011) has amended the listing for Abdul Salam Hanafi Ali Mardan Qul, a Taliban member and former Deputy Minister of Education under the 1996–2001 regime. The amendment updated Hanafi's entry on the 1988 List of individuals and entities subject to assets freezes, travel bans, and arms embargoes by adding an Afghanistan diplomatic passport (P03078281) issued in Dubai on 9th February 2020. In alignment with this decision, the UK's Foreign, Commonwealth and Development Office has updated the UK Sanctions List, applying the corresponding variation under the Afghanistan (Sanctions) (EU Exit) Regulations 2020. The UK domestic update adds the newly identified passport number to his record to ensure effective screening under his existing asset freeze and travel ban sanctions.

Money Laundering

NCA Secures Over $5.2 Million Forfeiture from Firm Linked to Suspected Money Laundering and Sanctions Evasion

The National Crime Agency (NCA) in the UK has announced that agricultural logistics firm ENEX Premium Trading Limited has agreed to forfeit more than $5.2 million (£3.84 million) following a civil recovery investigation into suspected money laundering and sanctions evasion. Registered in St Kitts and Nevis and owned by Azerbaijani national Nadir Valiyev, ENEX had transferred significant funds into newly opened UK bank accounts between July and September 2024. The NCA originally secured an Account Freezing Order over the assets in November 2024 following public allegations that Valiyev's companies were involved in shipping stolen Ukrainian grain. The subsequent NCA investigation traced the frozen funds to ENEX's Chinese bank accounts, which had received millions of pounds from suspected front companies which have since been sanctioned by the United States for facilitating illicit Iranian oil sales and funding the Iranian Qods Force. While the NCA suspects the assets represent the proceeds of money laundering, Valiyev has denied any criminal activity, and the settlement agreement does not constitute an admission of unlawful conduct by either ENEX or its owner.

Fraud

Massachusetts State Representative Indicted in $700,000 Pandemic Benefit Fraud and Money Laundering Scheme

Francisco Paulino, the Massachusetts State Representative for the 16th Essex District, has been arrested and charged in an 11-count federal indictment with eight counts of wire fraud and three counts of money laundering. Federal prosecutors allege that between 2020 and 2021, prior to his election to public office, Paulino fraudulently obtained over $700,000 in taxpayer-funded pandemic relief. The indictment claims that Paulino illicitly acquired over $44,000 in Pandemic Unemployment Assistance (PUA) by fabricating employment records under the name of an unknowing 77-year-old relative. He is also accused of submitting falsified revenue figures to secure multiple Economic Injury Disaster Loans (EIDLs) for Jackson Enterprise, Inc, which was a business with no prior revenue, and used those funds, along with EIDL proceeds from his tax business and a client, to purchase personal real estate and fund private mortgages through his mortgage company. Paulino is scheduled to make an initial appearance in federal court in Boston.

Three Defendants Sentenced to Combined 155 Months in Prison for Roles in $250 Million Federal Child Nutrition Fraud Scheme

Three defendants have been sentenced to a total of 155 months in prison for their roles in the $250 million Feeding Our Future fraud scheme, which exploited the Federal Child Nutrition Programme during the COVID-19 pandemic. Ahmed Abdullahi Ghedi, 35, was sentenced to 65 months in prison for wire fraud and money laundering; Abdihakim Ali Ahmed, 40, was sentenced to 54 months in prison for wire fraud and money laundering; and Ahmed Sharif Omar-Hashim, 43, was sentenced to 36 months in prison for wire fraud. The three men, who are the 24th, 25th, and 26th defendants to be sentenced in the investigation, previously pleaded guilty to charges connected to their generation of fraudulent, inflated meal counts at Safari Restaurant and associated distribution sites. The enforcement action represents a coordinated effort by the US Attorney’s Office for the District of Minnesota, the FBI, IRS Criminal Investigation, and the US Postal Inspection Service.

Five Indicted in Kentucky Over Alleged Deed Theft and Vehicle Title Fraud Schemes

A federal grand jury in Louisville, Kentucky, has returned an indictment charging five individuals, namely Donnie Russell, Lisa Cunningham, Jerry Wagers, Steven Jamesray Cates, and Claude Oscar Cunningham III, for their alleged roles in coordinated property and vehicle title fraud conspiracies. The indictment alleges that between April 2024 and June 2026, Russell, Cunningham, Wagers, and Cates executed a deed theft scheme by filing forged property deeds illegally to seize vacant homes in Louisville, frequently targeting properties whose owners had died without a will. Concurrently, Russell, Cunningham, Cates, and Claude Cunningham III allegedly operated a separate mail fraud conspiracy between January 2024 and July 2025 to secure fraudulent Indiana vehicle titles for stolen or abandoned cars using forged documentation to make them appear legitimately owned. All five defendants made their initial federal court appearances on 21st August 2026, and face up to 20 years in prison per count on the fraud and money laundering charges if convicted.

Other Financial Crime

UK FCA Fines and Bans Former Dolfin Executives Over £35.5 Million Investor Visa Circumvention Scheme

The UK Financial Conduct Authority (FCA) has announced enforcement action against former senior figures of Dolfin Financial (UK) Limited, a wealth management firm currently in special administration, for operating an artificial "visa loan business" designed to bypass immigration controls. Between 2016 and 2019, the scheme enabled at least 99 foreign nationals to obtain UK Tier 1 investor visas by paying a £400,000 fee rather than making the required £2 million personal investment in UK companies, generating at least £35.5 million in fees. The FCA fined former Chief Executive Denisz Nagy £324,800 and former Finance Director Sanjay Maraj £122,000, permanently prohibiting both from the financial services industry for failing to act with integrity and deliberately concealing the scheme from regulators. Furthermore, the FCA has decided to ban Dolfin co-founder Roman Joukovski for playing a lead role in designing the scheme and acting as an unapproved shadow director; however, Joukovski has referred his decision notice to the Upper Tribunal, leaving his findings and prohibition order provisional pending the tribunal's review.