Episode 279

7th September – 10th September 2026

Sanctions

US Government Expands Sanctions on Cuban Regime Elites and Iranian Financial Networks in Türkiye

The US Department of State has announced new sanctions targeting five entities and one individual linked to the Cuban government under Executive Order 14404. The designations, announced by Secretary of State Marco Rubio, target actors accused of propping up the Cuban government's financial services, metals and mining, and energy sectors. Among those designated are Fidel Ernesto Castro Calis, a grandson of Raúl Castro; the financial institution Banco Exterior de Cuba; and four entities involved in exploiting Cuba’s natural resources or energy reserves. According to the State Department, the measures aim to disrupt financial networks and power structures which support the regime's security apparatus.

In addition to this action, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) has announced sanctions against a Türkiye-based financial network as part of its wider "Operation Economic Outcast" campaign. OFAC designated Golden Global Yatirim Bankasi Anonim Sirketi (Golden Global Bank) and its two subsidiaries, Golden Global Varlik Kiralama Anonim Sirketi and Golden Global Portfoy Yonetimi Anonim Sirketi. Treasury officials stated that Golden Global Bank knowingly operated in the financial sector of the Iranian economy, facilitating tens of millions of dollars in transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its proxies, while providing correspondent banking access to move funds internationally. In conjunction with the listings, OFAC issued Iran General Licence CC to authorise a wind-down period for transactions involving the blocked entities.

US Treasury Imposes Sweeping Sanctions on Iranian Aviation Sector Under Operation Economic Outcast

The US Department of the Treasury has announced enforcement actions under Operation Economic Outcast targeting Iran's commercial aviation sector, designating 36 entities and individuals across multiple jurisdictions. As part of the action, the Office of Foreign Assets Control (OFAC) designated 27 active Iranian airlines under Executive Order 13902, alongside third-country front companies, general sales agents, and cargo service providers in the United Arab Emirates, Türkiye, Malaysia, Kazakhstan, and the United Kingdom which facilitated aircraft acquisitions, cargo shipments, and sales support for Mahan Air. Concurrently, OFAC suspended three Iran-related aviation authorisations, including overflight permissions, while the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on red flag indicators to detect and report illicit procurement networks supporting the Iranian aviation industry. The OFAC press release is here, FinCEN here, and the State Department here.

UK Designates Five Individuals and Beirut-Based Financial Entity under Human Rights and Counter-Terrorism Sanctions

The UK Foreign, Commonwealth & Development Office (FCDO) has expanded its consolidated sanctions list by adding five individuals under the Global Human Rights regime and one Lebanese entity under the Counter-Terrorism (International) regime. According to the published sanctions notices, the newly designated individuals, namely Ben-Zion Gopstein, Meir Mordechai Ettinger, Eliav Libi, Baruch Marzel, and Avichai Suissa, are now subject to asset freezes, travel bans, and director disqualifications across British jurisdictions. The FCDO's statement of reasons notes that these actions were taken due to the individuals' involvement in facilitating, inciting, promoting, or supporting violence and aggression against Palestinian individuals in Israel and the Occupied Palestinian Territories. Under the counter-terrorism framework, the UK designated Beirut-based financial services and charitable organisation Al-Qard Al-Hasan, imposing an asset freeze and director disqualification based on reasonable grounds that the entity is associated with Hizballah and facilitates financial services for the purposes of terrorism.

UK Updates Terrorist Sanctions List Following UN Sanctions Committee Amendments

The UK Foreign, Commonwealth & Development Office (FCDO) updated the UK Sanctions List to apply a variation under its ISIL (Da'esh) and Al-Qaeda sanctions regime. This domestic administrative action was taken in direct response to a 4th September 2026, decision by the United Nations Security Council Sanctions Committee, which enacted amendments to two entries on its consolidated sanctions list under Chapter VII of the UN Charter. The UN updates modified identifying details for Sanaullah Ghafari, the leader of the Islamic State of Iraq and the Levant-Khorasan (ISIL-K), and Abubakar Swalleh, a Uganda-based ISIL facilitator accused of providing financial and logistical support in East and Southern Africa. Because the UK's domestic framework provides for the automatic alignment and designation of individuals sanctioned by the UN under this regime, the UK modified its own records to ensure that asset freezes, travel bans, and arms embargoes remain accurately enforced against both individuals across British jurisdictions.

Illumina Cambridge Pays £7.4 Million HMRC Compound Settlement Over Russia Sanctions Breaches

Illumina Cambridge Limited has paid a £7,438,840.13 compound settlement to HM Revenue and Customs (HMRC) as an alternative to criminal prosecution following violations of The Russia (Sanctions) (EU Exit) Regulations 2019. According to published HMRC records, between July 2022 and January 2023, the company breached Regulation 25(1) through its involvement in supplying sanctioned goods between overseas entities within its corporate group for export to Russia and other destinations. The case was brought to HMRC's attention via a voluntary disclosure by Illumina, meeting HMRC's criteria for compound settlements offered when breaches are inadvertent or stem from internal control weaknesses rather than intentional evasion. Following the investigation, Illumina fully cooperated with authorities, implemented remedial measures, and ceased all business involving Russia.

Australia Commences Public Consultation on Major Sanctions Law Reforms

The Australian Government has launched a four-week public consultation period on the Australian Sanctions Legislation Amendment (ASLA) Reforms, marking the most significant overhaul of the nation's sanctions framework since the commencement of the Autonomous Sanctions Act 2011. Designed to modernise, streamline, and harmonise existing laws, the reforms will be implemented through three proposed bills, including the cornerstone Autonomous Sanctions Bill 2026 which will replace the 2011 Act, and two pieces of subordinate legislation. The Department of Foreign Affairs and Trade (DFAT) is seeking feedback on an exposure draft of the primary bill until 2nd October 2026, and plans to host two open virtual town hall information sessions in mid-to-late September to assist stakeholders in understanding the proposed structural changes.

Money Laundering

Georgian Citizen Indicted in Massachusetts for Laundering Proceeds of $1.3 Billion Healthcare Fraud Scheme

A federal grand jury in the District of Massachusetts has returned an indictment charging Erekle Gugava, a 33-year-old citizen of Georgia residing in the United States, with one count of money laundering conspiracy. According to court documents, Gugava allegedly served as a money launderer for a transnational criminal organisation based in Russia and elsewhere which orchestrated a multi-billion-dollar healthcare fraud and money laundering scheme targeting Medicare and other health insurers. Prosecutors allege that between February and July 2025, Gugava purportedly owned Pennsylvania-based durable medical equipment (DME) provider ND Medical Solutions LLC, which submitted at least $1.3 billion in fraudulent claims using the stolen identities of elderly and disabled American citizens. The insurers paid ND Medical approximately $6.5 million, which Gugava allegedly deposited into company bank accounts under his control before transferring the funds to overseas accounts for the benefit of the criminal organisation. If convicted, Gugava faces a maximum penalty of 20 years in prison.

Italian and German Authorities Disrupt €4.5 Million Sports Association Money Laundering Scheme

Italian and German law enforcement authorities, in coordination with Eurojust, have executed a joint operation to dismantle a money laundering network which allegedly diverted and misused €4.5 million in grants intended for a sports association. Investigations led by Italian authorities revealed that a former legal representative of the sports association systematically diverted funding received from universities, national sports bodies, and public organisations between 2018 and 2024 by channelling the funds through a second, fictitious sports association to family members. The majority of the illicit funds were subsequently transferred to bank accounts in Germany, where €2.5 million was reinvested in financial portfolios, businesses, and real estate. As a preventive measure during the coordinated action, authorities seized approximately €7 million in assets, including 83 bank accounts, 21 real estate properties, four businesses, and two luxury vehicles located in Germany. The operations were conducted by the Public Prosecution Office and Guardia di Finanza of Naples alongside the Public Prosecution Office of Cologne.

AUSTRAC Removes 45 Remittance and Virtual Asset Businesses Amid Heightened Payments Scrutiny

The Australian Transaction Reports and Analysis Centre (AUSTRAC) has announced that it had cancelled, suspended, or refused the registration renewals of 45 remittance and virtual asset service providers (VASPs) over the preceding twelve months. According to AUSTRAC CEO Brendan Thomas, the enforcement actions targeted dormant, inactive, or insolvent operations, as well as businesses lacking operational capacity, failing to declare material changes, or presenting significant money laundering and terrorism financing risks. Among the deregistered entities was BA Digital Ventures Pty Ltd (trading as GetCoins), a virtual asset service provider removed from the registry following collaboration with the National Anti-Scam Centre due to its alleged exploitation by organised cryptocurrency investment frauds. The regulator noted that these registry removals are part of an ongoing, proactive campaign to intensify oversight of high-risk payment sectors, which also includes an active investigation into Western Union and the recent suspension of Cryptolink's crypto ATM network.

UK Finance Responds to FATF’s Draft Payment Transparency Guidance, Highlighting Need for Cross-Border Payments Transformation

UK Finance, the industry trade body, has published its formal response to the Financial Action Task Force (FATF) public consultation on draft guidance for its strengthened Recommendation 16 payment transparency standards, which were originally agreed in June 2025. Developed alongside members of UK Finance's Payments and Financial Crime teams, as well as the wider Economic Crime stream, the response supports FATF's goal of enhancing the transparency and traceability of international value transfers to preserve financial integrity. However, the representative body emphasised that the implementation of Recommendation 16 must be approached not merely as an isolated anti-financial crime initiative, but as a major cross-border payments transformation programme requiring coordinated alignment among global regulators, payment service providers (PSPs), scheme operators, and infrastructure systems. UK Finance urged that the final guidelines remain risk-based and operationally achievable across diverse legal and technological frameworks while still delivering effective economic crime outcomes.

Bribery and Corruption

Ukrainian Prosecutor General Resigns Following Anti-Corruption Raid on Office

The Ukrainian Prosecutor General, Ruslan Kravchenko, has resigned from his post following a meeting with President Volodymyr Zelenskyy and an anti-corruption raid on his office by investigators from the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialised Anti-Corruption Prosecutor's Office (SAPO). The resignation followed allegations that senior officials within the prosecutor general's office accepted monthly protection payments, reported at $7,000 per facility, from illegal fraudulent call centres conducting money laundering and phone scams targeting citizens across Ukraine and Europe. Anti-corruption agents executed a raid on Kravchenko's office and searched his residence, arresting a chief suspect accused of collecting millions of dollars in bribes while managing repairs at Kravchenko's home. Kravchenko has denied all allegations of wrongdoing, stating that he stepped down to prevent the prosecutor general's office from being used as a tool in political confrontation.

Fraud

US and UK Launch First-of-Its-Kind Joint Alliance to Disable Global Scam Centres

The US Attorney's Office for the District of Columbia, alongside the Crown Prosecution Service of England & Wales and the UK National Crime Agency, have announced the signing of a first-of-its-kind Memorandum of Understanding (MOU) to dismantle international fraud centres. The agreement coordinates efforts between the US Scam Centre Strike Force, which was launched in November 2025 to target Southeast Asian scam compounds operated by Chinese organised crime networks using human-trafficked labour, and its United Kingdom counterparts to combat cryptocurrency and cyber-enabled investment fraud. Under the terms of the MOU, the participating agencies will conduct parallel investigations into common targets, share intelligence on syndicates, coordinate prosecution jurisdictions, and join forces for an in-person disruption event with private industry partners in London in early October.

UK Ministry of Justice Launches Five-Year Counter Fraud Strategy Targeting Technological and Insider Risks

The Ministry of Justice (MOJ) has published its Counter Fraud Strategy for 2026 to 2030, establishing a comprehensive five-year framework to protect England and Wales's justice system from the harms of fraud, bribery, and corruption. Grounded in the department's Enterprise Fraud Risk Assessment, the strategy prioritises four key areas of strategic vulnerability: insider threats, commercial risks, digital and technological exploitation, and third-party threat actors. The initiative is structured around four core strategic pillars which are Governance and Assurance, Risk Identification, Control Implementation, and Response, and these are set alongside two supporting pillars focused on Culture and Capability and Data Analytics. The aim is to transition the ministry from fragmented reporting to a data-rich, evidence-based operation. Under the new guidelines, the MOJ plans systematically to embed digital, data, and artificial intelligence detection tools directly into its services and controls by design, while committing to the creation of a centralised control library by 2028.

City of London Police Report Fraud Assessment Reveals £3.2 Billion Loss and 395% Spike in AI-Enabled Fraud

The City of London Police has published its inaugural Report Fraud Annual Assessment FY2025–26, revealing that reported financial losses from cybercrime and fraud across England, Wales, and Northern Ireland reached £3.2 billion across 503,288 crime submissions. The assessment highlighted a rapid evolution in criminal methodologies, headlined by a 395% surge in reports involving artificial intelligence, rising from 193 to 956 reports, with AI-enabled losses climbing from £1.2 million to £9.6 million, predominantly through generative AI investment frauds. High-harm threats such as romance, payment diversion, and courier fraud remained prominent, while cryptocurrency served as a commodity or enabler in 32,493 reports. Officials noted that the deployment of the new national Report Fraud service in December 2025 enhanced intelligence gathering and reduced average case review times from 37 days to five days. The press release is here, and the report is here.

UK National Economic Crime Centre Releases 2025–26 Annual Report Highlighting System-Wide Disruptions and Major Operations

The UK's National Economic Crime Centre (NECC) has published its 2025–26 annual report detailing multi-agency operations against fraud and illicit finance across England, Scotland, Wales, and Northern Ireland. Working in partnership with law enforcement, government departments, regulators, and private-sector institutions, the UK-wide system delivered 5,500 fraud disruptions and 3,158 illicit-finance disruptions over the past year. Key operational milestones included Operation Henhouse 5, which resulted in a record 557 arrests and £18.1 million in cash and assets seized or denied, and Operation Machinize 2, which yielded 924 arrests and over £10.7 million in seized or restrained criminal proceeds across 2,734 high-street premises. Additionally, targeting Russian-speaking money laundering networks under Operation Destabilise generated 46 arrests and £5.1 million in cash seizures over the year, bringing total campaign outcomes to 129 arrests and more than £25 million in seized assets. The report highlights an ongoing strategic transition toward proactive prevention driven by data-sharing platforms, including the expansion of Data Fusion and the launch of the Online Crime Centre. The report is here.

London Hotelier Receives Suspended Sentence for £450,000 Covid Loan Fraud

A London hotelier, Richard Courtenay, has been sentenced at Southwark Crown Court to a three-year prison sentence, suspended for three years, after pleading guilty to nine counts of fraud and one count of money laundering. An investigation by the UK Insolvency Service revealed that between May and June 2020, Courtenay submitted nine fraudulent applications under the government's Bounce Back Loan scheme to secure £450,000 across five interlinked businesses. The defendant obtained the funds by systematically inflating company turnovers and dishonestly applying for multiple loans despite restrictions permitting only one loan per business, before moving the capital into personal accounts, other companies, and cryptoassets. Alongside his suspended sentence, Courtenay was ordered to complete 150 hours of unpaid work and attend 10 days of rehabilitation activity. While the £450,000 has been repaid in full, the Insolvency Service noted that the repayment was only made after its investigation into his conduct had already commenced.

Devon Taxi Driver Ordered to Repay Over £63,000 Following Fraudulent Covid Loan Conviction

A taxi driver from Exeter has been made the subject of a £63,790 confiscation order following an investigation by the UK Insolvency Service. Murat Dogantekin was previously sentenced to two years and seven months in prison in February 2025 after fraudulently securing £100,000 through two Covid Bounce Back Loan applications in 2020 by overstating his annual business turnover by more than £350,000. Financial investigators revealed that he used the government-backed funds to purchase personal assets, including a flat in Turkey, a vehicle, and a pizza oven, without making any loan repayments prior to his November 2021 bankruptcy. Dogantekin has been granted three months to satisfy the order, after which he faces an additional five-year prison sentence while remaining obliged to pay the full amount.

Market Abuse

German Regulator BaFin Fines Two Individuals for Market Manipulation Tied to TUI AG Shares

The German Federal Financial Supervisory Authority (BaFin) has imposed administrative fines of €1,900 and €1,650 on two natural persons for failing to implement the necessary supervisory and organisational measures to prevent market manipulation. According to the regulator, these organisational deficiencies led to the submission of an incomplete voting rights notification at the start of 2022 following a change in the ownership structure initiated by the previous majority shareholder of tourism group TUI AG. The notification negligently failed to disclose the individual who could exercise a dominant influence over the owner of the voting rights, creating a misleading signalling effect on TUI AG's share price due to the involvement of a new major shareholder. The administrative fine orders, issued under the Market Abuse Regulation (MAR), remain subject to appeal.

SEC Files Settlements in Elanco Executive Insider Trading Case Involving Kindred Biosciences Acquisition

In the US, he Securities and Exchange Commission (SEC) has filed consents and proposed final judgments to resolve insider trading charges against Trijya Vakil, a former Senior Director at Elanco Animal Health, Inc., and her friend Neeraj Visen. According to the SEC’s complaint, Vakil obtained material non-public information in April 2021 while participating in Elanco's due diligence for its acquisition of Kindred Biosciences, Inc. Vakil purchased 500 shares of Kindred, yielding $2,447.50 in illicit profits, and tipped Visen, who purchased 38,000 shares and generated $109,437 in gains after the acquisition was publicly announced. Under the proposed settlements, which require court approval, both defendants have agreed to pay a civil penalty of $54,718 each. These civil settlements follow August 2025 court orders permanently barring both individuals from serving as officers or directors of public companies, as well as guilty pleas entered by both defendants in parallel criminal cases prosecuted by the US Attorney’s Office for the Southern District of New York.