Episode 278

4th September – 6th September 2026

Sanctions

UK Government Applies Administrative Corrections to Russia Sanctions List Entries

The UK Foreign, Commonwealth and Development Office (FCDO) updated the UK Sanctions List to issue four administrative corrections under the Russia (Sanctions) (EU Exit) Regulations 2019. The corrections update the details of one individual, satellite and broadcasting department head Stanislav Bronislavovich Klevitskiy, who is designated for his role in the Russian digital technology sector, and three entities: Hong Kong-based Glenbrook Corporation Limited, which is sanctioned for its association with energy sector businessman Tahir Garayev; Moscow-based Joint Stock Company Teleport Bank, flagged under the financial services sector; and JSC Altay Instrument-Making Plant Rotor, a manufacturer in the Russian defence sector. These administrative updates correct identifying information for the targets, all of whom remain subject to active UK financial restrictions, including asset freezes, director disqualification, and trust services sanctions.

UK Government Issues Administrative Sanctions Correction for Russia's Ozon Bank

The UK Foreign, Commonwealth and Development Office (FCDO) has updated the UK Sanctions List to publish an administrative correction concerning the Russian financial entity Limited Liability Company "Ozon Bank". Originally designated on 6th August 2026, under the Russia (Sanctions) (EU Exit) Regulations 2019, the Moscow-based entity remains subject to financial restrictions including an asset freeze, trust services sanctions, director disqualification, and a prohibition on correspondent banking relationships. The FCDO's statement of reasons notes that the bank is suspected of supporting or obtaining a benefit from the Russian government by operating within the strategically significant Russian financial services sector. The administrative update corrects identifying details for the entity, which is also known by several name variations including Ekom Bank, Ecom Bank, and Oney Bank.

Armenian National Sentenced to 26 Months for Smuggling Semiconductor Manufacturing Goods to Russia

Kamo Kirakosyan, an Armenian national, has been sentenced in an Austin federal court to 26 months in prison for conspiring to export controlled goods from the United States to the Russian Federation through Armenia without the required US government licences. According to court documents, from February 2022 to August 2024, Kirakosyan acted as a straw buyer of US-origin technology, which included items utilised in semiconductor manufacturing, by misrepresenting himself to US vendors as the final purchaser in Armenia while actively concealing the true Russian end users. Kirakosyan was originally charged in July 2024, extradited to the United States from Germany in August 2025, and subsequently pleaded guilty in April 2026 to one count of conspiracy to violate federal law.

OFAC Issues Blocked Property Reporting Deadline Reminder and Amends Venezuela General Licences

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a reminder to US persons holding blocked property as of 30th June 2026, to submit their Annual Report of Blocked Property (ARBP) by the 30th September 2026 deadline, warning that failures to file may result in enforcement referrals. Alongside this compliance reminder, OFAC issued three amended Venezuela-related general licences, namely General Licence 51D, 54C, and 55A, which authorise specific activities involving Venezuelan-origin coal or minerals (including gold), the supply of certain items and services for coal or minerals operations in Venezuela, and negotiations of and entry into contingent contracts for certain investments in those sectors. Additionally, the agency updated its Venezuela-related guidance by amending Frequently Asked Question (FAQ) 1247.

Money Laundering

New York Man Sentenced to Five Years in Prison for Money Laundering Conspiracy

Abu Khamza, a 35-year-old New York man, has been sentenced in the Eastern District of Virginia to five years in prison for conspiring to commit money laundering. According to court documents, Khamza pled guilty in May 2026 to conspiring to launder over $572,000 in cash, which he believed was illicit prescription drug proceeds, into cryptocurrency with the belief that the funds would be transmitted to mujahideen in Syria. Evidence presented to the court by prosecutors also showed that Khamza had engaged in various other criminal activities, including extortion, cargo theft, auto theft, pandemic relief fraud, and cheque fraud. The case was prosecuted by the Justice Department's National Security Division and the US Attorney's Office for the Eastern District of Virginia, following a joint investigation led by the FBI Washington Field Office's Counterterrorism Division.

FATF Report Highlights Rise of "Digital Hawala" and Professionalised Money Laundering Networks

The Financial Action Task Force (FATF) has published a report revealing that underground banking and hawala and other similar service providers (HOSSPs) have evolved into highly professionalised cross-border networks operating "money laundering as a service". Drawing on evidence from more than 50 jurisdictions, the report states that over 80% of surveyed countries now identify these systems among their principal professional money laundering channels. The analysis warns of a significant shift toward "digital hawala," with nearly 70% of respondents noting the integration of encrypted messaging apps, digital wallets, and virtual assets, specifically stablecoins, to settle balances across borders. No longer restricted to cash-intensive offences like drug trafficking, these sophisticated networks are increasingly utilised to launder proceeds from cybercrime, fraud, tax evasion, and terrorist financing, with some schemes laundering upwards of €500 million in just a few months. In response, FATF President Giles Thomson urged global public and private partners to implement the report's identified good practices, which emphasise balancing targeted enforcement with proportionate financial inclusion strategies to disrupt this critical infrastructure sustaining organised crime. The press release is here, and the report is here.

Bribery and Corruption

Serious Fraud Office Reaches Confidential Out-of-Court Settlement to Conclude ENRC Litigation

The UK Serious Fraud Office (SFO), mining company Eurasian Natural Resources Corporation Limited (ENRC), law firm Dechert LLP, and lawyer David Neil Gerrard have reached a confidential out-of-court settlement to conclude their long-running civil proceedings. The litigation followed a decade-long SFO bribery and corruption investigation into ENRC's mining acquisitions in the Democratic Republic of Congo, which was closed in 2023 without charges due to a lack of admissible evidence, and subsequent High Court rulings which found the SFO had breached its duties by accepting unauthorised disclosures from ENRC's former legal counsel. In a comment on the resolution, the advocacy group Spotlight on Corruption expressed concern over the lack of transparency surrounding the settlement terms, highlighting that the secrecy leaves the public in the dark regarding how much of the $290 million in damages originally sought by ENRC is being covered by public funds, though the SFO's most recent annual report did make provision in the sum of £15 million to cover estimated liabilities from the case.

Fraud

Danish Autism Researcher Pleads Guilty to Defrauding CDC of $1 Million After 14 Years as Fugitive

Danish researcher, Poul Thorsen, has pleaded guilty in the Northern District of Georgia to wire fraud for his role in a scheme which systematically diverted more than $1 million in federal Centres for Disease Control and Prevention (CDC) grant funds. According to court documents, from 2004 to 2008, Thorsen served as a principal investigator administering over $11 million in CDC autism and public health research grants awarded to Danish governmental agencies. During this time, he submitted multiple fraudulent invoices containing forged signatures to redirect the funds into his personal credit union accounts, using the proceeds to purchase real estate and luxury vehicles for his own use. Thorsen, who was named one of the Department of Health and Human Services Office of Inspector General's top ten most wanted fugitives after an arrest warrant was issued in 2011, evaded apprehension for over 14 years before being arrested in Germany in June 2025 and extradited to the United States in May 2026. He remains in federal custody and will be sentenced on 1st December 2026.

FinCEN Identifies $12.7 Billion in Suspected Digital Asset Scams Tied to Overseas Scam Centres

The US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has published a financial trend analysis and an alert highlighting $12.7 billion in suspected digital asset investment frauds reported between September 2023 and December 2025. Drawing from 33,904 Bank Secrecy Act reports, the analysis shows that these schemes, which commonly include "pig butchering," "romance baiting," or "cryptocurrency confidence schemes", are sophisticated fraud operations run by transnational criminal organisations largely based in Southeast Asia which target victims across all 50 US states. To execute and profit from these frauds, operators acquire specialised illicit services on online "guarantee marketplaces" and employ professional money launderers to move funds into the traditional financial system via networks of money mules and stablecoin transfers to offshore digital asset exchanges. In response, the regulatory alert details key indicators and red flags to help financial institutions identify and report these illicit activities while encouraging collaborative communication under Section 314(b) of the USA PATRIOT Act.

Former Directors of Ethical Forestry Limited Sentenced to Combined 15 Years Over £70 Million Fraud

Former directors Matthew Pickard, Stephen Greenaway, and Paul Laver have been sentenced to a combined 15 years and nine months in prison at Southwark Crown Court for their roles in a seven-year, £70 million investment fraud which affected more than 3,000 people. An investigation by the Serious Fraud Office (SFO) revealed that the defendants operated a Bournemouth-based call centre under Ethical Forestry Limited, using false company names to cold-call and persuade individuals to transfer their pension savings into a tree-planting scheme in Costa Rica. Although saplings were planted, no funds were allocated for their long-term maintenance or harvesting, making it impossible to generate the promised returns. Meanwhile, the defendants used the investors' funds to finance luxury lifestyles, including high-end sports cars and multi-million-pound properties, and diverted £2.77 million to administer a personal tax avoidance scheme. Pickard was sentenced to six years, Greenaway to five years and three months, and Laver to four years and six months; all three were also disqualified from serving as company directors for ten years following their guilty pleas in January 2026.

Market Abuse

Former Executives of Pre-IPO Investment Platform Linqto Charged in $450 Million Fraud Scheme

Federal prosecutors in the Southern District of New York have unsealed an indictment charging William Sarris, the founder of "pre-IPO" investment platform Linqto Inc, with securities fraud, wire fraud, broker-dealer fraud, and conspiracy charges. Between 2020 and 2025, Sarris allegedly exploited the lack of pricing transparency in private markets by manipulating pricing models, manufacturing false scarcity, and imposing markups exceeding 200% on more than 13,000 customers while falsely representing that they were purchasing shares at market prices. When Linqto faced financial pressure in early 2025, Sarris allegedly sold shares allocated to customers' holdings without authorisation, prior to the platform's collapse into bankruptcy in mid-2025. Sarris's former second-in-command, Joseph Endoso, pled guilty to securities fraud, broker-dealer fraud, and conspiracy charges on 27th August 2026, and is currently cooperating with the government.

Other Financial Crime

FCA Decides to Ban and Fine Daniel Philip Thomas £742,700 Over Unauthorised Pension Transfer Advice

The UK Financial Conduct Authority (FCA) has issued a Decision Notice proposing to ban financial adviser Daniel Philip Thomas from the financial services industry and fine him £742,700 for recklessly providing unauthorised defined benefit pension transfer advice. The regulator found that between April 2014 and September 2019, Mr. Thomas advised 53 clients on 63 pension transfers, generating £173,732.57 in fees despite knowing he lacked the necessary qualifications and was prohibited from giving such advice under DPT Financial Solutions Limited's appointed representative agreement with its principal, Quilter Financial Services Ltd. The FCA alleged that Mr. Thomas repeatedly misled clients and pension providers, including vulnerable members of the British Steel Pension Scheme, by falsely claiming to have the correct authorisation, destroyed client suitability files, and failed to cooperate with the subsequent investigation. Mr. Thomas has referred the matter to the Upper Tribunal to present his case, meaning the FCA’s findings and proposed actions remain provisional and no enforcement action will be taken pending the Tribunal's final decision. The press release is here, and the Decision Notice here.

Cybercrime

International Public-Private Coalition Disrupts Two-Decade-Old Sality Botnet

A coordinated international operation led by United States authorities disrupted the Sality peer-to-peer (P2P) botnet, a resilient criminal cyber-infrastructure which has been active for more than two decades. Unlike traditional networks reliant on central command-and-control servers, Sality used a decentralised P2P framework to communicate directly between infected machines, allowing operators to distribute malicious payloads and, at its peak, control up to one million compromised systems simultaneously. To dismantle this network, which has been linked to more than 11 million unique IP addresses worldwide, investigators from the US, Bulgaria, Hungary, and Romania executed a P2P sink holing operation to redirect communications away from criminal infrastructure and render the command channel inoperable. The disruption was supported by Europol's European Cybercrime Centre (EC3) and Eurojust, in close cooperation with private-sector threat intelligence partners CrowdStrike and the Shadowserver Foundation.