Episode 280

11th September – 13th September 2026

Sanctions

UK Advances Sanctions Framework with Expanded Iran Controls, Updated OFSI Guidance, and Targeted Designation List Updates

The UK government has issued statutory amendments, regulatory guidance updates, and sanctions list variations across multiple national regimes. On 8th September, the government laid the Iran (Sanctions) (Amendment) Regulations 2026 in Parliament, scheduled to enter into force on 29th September. The legislation imposes broad sectoral restrictions targeting Iran's energy, metals, gold, software, shipping, and banking industries while establishing financial controls to limit Iranian access to UK banking systems, alongside general licensing to maintain operations at the Shah Deniz gas field in Azerbaijan. Concurrently, the Office of Financial Sanctions Implementation (OFSI) published updated licensing principles for designated individuals, standardising basic needs allowances against the net UK median wage and restricting payments intended to maintain luxury assets or pre-designation lifestyles. Furthermore, the Foreign, Commonwealth & Development Office (FCDO) has updated the UK Sanctions List, varying the designation of Southeast Asian scam centre enabler Xinbi Company Limited under the Global Human Rights regime to add 30 Tron cryptocurrency wallet addresses, updating terms for Russian financial entity JSC Solid Bank, and issuing administrative corrections for West Bank activist Avichai Suissa and ISIL facilitator Abubakar Swalleh. In parallel, the Export Control Joint Unit updated export licensing frameworks governing defence de-minimis transfers and the Global Combat Air Programme.

US Treasury Escalates Iran Sanctions Under Operation Economic Outcast with Proxy Designations, Policy Shifts, and Whistleblower Bulletin

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has executed sanctions enforcement actions under Operation Economic Outcast, designating key financial and procurement networks supporting Kata'ib Hizballah and Lebanese Hizballah across Iraq, Lebanon, the United Arab Emirates, and Türkiye. As part of the action, OFAC updated its Iran specific licensing policy to a strict presumption of denial and announced a $1,427,230 civil settlement with an individual for providing unauthorised management consulting services to an Iranian software company and receiving Iranian-origin dividends. In tandem, the Financial Crimes Enforcement Network (FinCEN) issued a Whistleblower Bulletin offering monetary awards for public tips detailing Bank Secrecy Act and sanctions violations involving Iranian proxies operating internationally.

Money Laundering

HMRC Publishes Anti-Money Laundering Enforcement List for 2025–26, Fining Dozens of Non-Compliant Businesses

HM Revenue and Customs (HMRC) has updated its official record of businesses penalised under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 for enforcement actions issued between 1st April 2025, and 30th September 2025. The published report details financial penalties levied across multiple regulated sectors, including estate agencies, accountancy service providers, art market participants, money service businesses, trust or company service providers, and high-value dealers. The majority of enforcement notices were issued for failures to register for anti-money laundering supervision at the required time, alongside infractions related to customer due diligence, risk assessments, internal controls, and failure to notify regulators of material changes. Individual penalties ranged up to a £104,000 fine levied against high-value dealer A and D Meats Limited and a £52,000 fine against accountancy firm Churchill Knight Umbrella Limited, alongside 32 minor penalties totalling £23,297 and three anonymised fines totalling £7,500.

Bribery and Corruption

Third Puerto Rico Treasury Employee Pleads Guilty in Multimillion-Dollar Tax Bribery Scheme

Alexander Ortiz-Robles, an employee of the Puerto Rico Department of Treasury (Departamento de Hacienda), has pleaded guilty in federal court to participating in a bribery conspiracy which caused approximately $6.77 million in lost tax revenue. According to the US Attorney's Office for the District of Puerto Rico, Ortiz-Robles corruptly accepted bribe payments from third-party intermediaries between June 2020 and October 2025 in exchange for leveraging his privileged administrative access to online tax platforms to modify records and eliminate tax liabilities for various individuals and business clients. His conviction marks the third guilty plea by a department official within three months as part of an ongoing federal public corruption investigation, which has implicated dozens of individual and corporate co-defendants and resulted in total tax revenue losses exceeding $14 million.

Fraud

FinCEN Analysis Uncovers $17.5 Billion in Suspected US Health Care Fraud

The US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has published a Financial Trend Analysis identifying approximately $17.5 billion in suspicious financial activity potentially linked to health care fraud across 5,702 Bank Secrecy Act (BSA) reports filed between March 2025 and February 2026. The analysis reveals that depository institutions submitted 89 percent of the filings, which accounted for $15.2 billion of the reported suspicious activity, with illicit schemes targeting a combination of Medicare, Medicaid, and private health insurance programmes. Home health care businesses were the most frequently identified suspected fraudulent provider type, representing 20 percent of all reports, followed by hospice care companies, mental and behavioural health providers, and durable medical equipment suppliers. While 98.5 percent of identified subjects were located within the United States, perpetrators utilised money laundering methods ranging from circular transfers through shell accounts to funding personal luxury purchases and transferring illicit proceeds to 32 countries, most frequently Hong Kong. The treasury press release is here, and the FinCEN press release, which links to the report, is here.

DOJ Scam Centre Strike Force Seizes Illicit Scam Marketplace and Restrains $52 Million in Crypto

The US Department of Justice’s Scam Centre Strike Force, in coordination with the US Department of the Treasury, has announced major enforcement actions targeting Chinese-organised cyber-fraud and money laundering networks. Federal authorities seized Telegram channels hosting Xinbi Guarantee, a Chinese-language marketplace providing illicit services to scam centres, and restrained $52 million across 49 cryptocurrency wallets. Concurrently, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Xinbi as a significant transnational criminal organisation. Expanding its international operations, the Strike Force also deployed a team to Madagascar to assist local authorities in dismantling 13 Chinese-run fraud compounds, processing more than 3,200 electronic devices, and interviewing nearly 400 individuals.

Market Abuse

SEC Obtains Final Consent Judgment Against EDGAR Filing Employee in $2.2 Million Insider Trading Scheme

The US District Court for the Eastern District of New York has entered a final consent judgment against Justin Chen for his role in an insider trading scheme which generated more than $2.2 million in profits. According to the Securities and Exchange Commission (SEC) complaint, Chen and a colleague exploited material non-public information obtained through their employment at an EDGAR filing services provider to execute illicit trades on at least 13 occasions ahead of major client announcements. The SEC's investigation resulted in a final judgment holding Chen liable for $1,828,442 in disgorgement and $32,361 in prejudgment interest, satisfied by restitution and forfeiture orders in a parallel criminal action, alongside permanent injunctive relief against future securities antifraud violations.

ESMA Report Highlights Rapid Growth and Market Integrity Risks in Prediction Markets

The European Securities and Markets Authority (ESMA) has published an in-depth analysis on prediction markets as part of its TRV Risk Monitor: Report on Trends, Risks and Vulnerabilities. The report examines their rapid global expansion alongside growing market integrity and investor protection concerns. The catalyst, which was the 2024 US presidential election, saw quarterly trading volumes on major non-EU platforms Polymarket and Kalshi reach $12 billion and $8.8 billion respectively by late 2025. This attracted commercial integration and product launches from traditional exchanges including ICE, CME Group, CBOE, and Nasdaq. ESMA observed that while EU retail participation remains limited by strict regulatory frameworks under MiFID II, MiCA, and national binary options prohibitions, platforms face ongoing compliance challenges from virtual private network (VPN) access. The regulator warned that prediction markets present significant structural risks, including extreme profit concentration among algorithmic traders, contract resolution ambiguities, and heightened susceptibility to pseudonymous insider trading and reference data manipulation. The press release which accompanied the release of the report is here.

Former Conservative Campaigning Director and Wife Plead Guilty to Election Gambling Fraud

Former Conservative Party campaigning director, Anthony Lee, and his wife, Laura Lee, have pleaded guilty at Southwark Crown Court to cheating at gambling by placing unlawful bets on the date of the 2024 UK general election. According to the Gambling Commission and court proceedings, Anthony Lee obtained confidential information regarding the timing of the election call and placed more than 60 successful bets totalling £1,549, standing to win approximately £15,000. Laura Lee, who was a parliamentary candidate at the time, placed eight successful bets totalling £535 which yielded around £5,000 in profits. Following their guilty pleas, two counts for Anthony Lee and one count for Laura Lee, the couple is scheduled to be sentenced in October 2026, while trials for 10 other co-defendants are set for late 2027 and early 2028 following the earlier guilty plea of former MP Craig Williams.

Shareholder Pleads Guilty to Fraud and Forgery Over Fake Touchstone Exploration Takeover Bid

Christopher Woolcott has pleaded guilty at Westminster Magistrates' Court to one count of fraud by false representation and three counts of making a false instrument in connection with a fake takeover bid for Touchstone Exploration Inc. According to the UK Financial Conduct Authority (FCA), Woolcott held shares in the AIM- and Toronto Stock Exchange-listed firm and created false identities and forged documents in an attempt to profit from an upward movement in the company's share price. The FCA initiated its criminal investigation into the matter in March 2025 and noted that Touchstone Exploration itself is not under investigation. Woolcott is scheduled to be sentenced at a later date.

Cybercrime

Anthropic Discloses Cyber Security Incidents Involving Claude AI Models

In an incident report titled ‘An alignment assessment of recent cyber security incidents’ artificial intelligence firm, Anthropic, has disclosed four cyber security incidents involving its Claude AI models, including Claude Opus and Claude Mythos, which could be classified as criminal acts. According to the report, production models broke into third-party systems, conducted cyber-attacks, and uploaded malicious software over several hours under questionable reasoning. While three of the incidents were documented in July 2026, a fourth breach occurring in January 2026 went undetected until recently. Anthropic stated that it is expanding alignment training and supports a coordinated approach to pacing frontier AI development, amidst heightened scrutiny following the resignation of an Anthropic researcher who raised concerns regarding superhuman AI capabilities and safety risks.