Episode 282

18th September – 20th September 2026

Money Laundering

FinCEN Convenes Global Financial Institutions to Target Iranian Illicit Finance Networks Under Operation Economic Outcast

The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury has hosted a FinCEN Exchange with global financial institutions to advance Operation Economic Outcast. The voluntary public-private session provided financial sector representatives with actionable insights on nodes, facilitators, and procurement networks which enable the Iranian regime and its regional proxies to access US correspondent banking relationships, launder funds, and acquire weapons. Treasury officials and industry representatives shared operational findings and best practices to protect the US financial system from abuse and terrorism. Building on the April 2025 Iran Maximum Pressure and Counter Terrorism (IMPACT) event, the exchange forms part of sustained federal efforts to sever Tehran's economic lifelines and disrupt illicit financial activity.

RUSI Commentary Highlights Operational Gaps in Global Financial Integrity Framework Amid Geopolitical Fragmentation

Kinga Redlowska, Head of CFS Europe at the Royal United Services Institute (RUSI), published a commentary introducing a special issue of the RUSI Journal entitled Illicit Finance in a Fragmenting World: Can the Global System Keep Pace? The publication assesses whether the global financial integrity architecture, centred on the Financial Action Task Force (FATF) established in 1989, remains effective amidst intensifying geopolitical rivalries, sanctions proliferation, and emerging threats such as war financing, hybrid activities, and sanctions evasion. Redlowska highlights a growing gap between technical regulatory compliance and real-world operational effectiveness, arguing that traditional anti-money laundering mechanisms designed for criminal proceeds struggle to address complex state-directed threats and technological shifts. The commentary further notes that developing nations in the Global South bear a disproportionate share of international compliance costs, concluding that global standard-setters must adopt genuine risk-based priorities, strengthen regional bodies, and integrate financial intelligence across national security and law enforcement domains to maintain relevance in a fragmenting international system. The commentary piece is here.

Bribery and Corruption

Former French Minister Rachida Dati Stands Trial in Paris Over Alleged Renault-Nissan Lobbying Payments

The former French Justice and Culture Minister, Rachida Dati, has gone on trial in Paris facing corruption charges over €900,000 in payments received from car manufacturer, Renault-Nissan, between 2009 and 2013. French investigating magistrates allege that a contract signed for legal services while Dati served as a Member of the European Parliament was used to conceal illicit political lobbying and influence-peddling arranged by former Renault-Nissan CEO, Carlos Ghosn, who is being tried in absentia as a fugitive in Lebanon. Both Dati and Ghosn deny all allegations.

Fraud

UK Government Unveils £550 Million Anti-Money Laundering and Asset Recovery Strategy 2026–2029

Minister of State for Security, Dan Jarvis, presented the UK Government's Anti-Money Laundering and Asset Recovery Strategy 2026–2029 (CP 1677) to Parliament this week. Backed by over £550 million in investment across three years, comprising at least £520 million from the Economic Crime Levy and £30 million from a dedicated high streets package, the strategy establishes a national framework to disrupt serious financial crime and take the profit out of criminality. Structured around three core pillars, the plan sets out three main objectives: enhancing national financial defences, dismantling high-harm criminal networks, and increasing asset recovery for law enforcement, victims, and the public. To execute these goals, the government will fund 500 new law enforcement officers and specialists by end-2029, including financial investigators, forensic accountants, and cryptoasset experts. Key operational initiatives detailed in the strategy include establishing a High Street Organised Crime Unit, consolidating national financial intelligence functions, streamlining anti-money laundering supervision by reducing supervisor bodies from 25 to three, and deploying artificial intelligence tools to detect and trace complex illicit financial flows.

Now, it is worth remembering that in March this year, the UK government published its Fraud Strategy 2026–2029 (CP 1523). The focus of the March fraud strategy was the protection of individuals and businesses with the investment of over £250 million, while the report published this week targets systemic illicit finance. Operationally, the March report prioritises public resilience, victim reporting, and digital infrastructure protection. It does this by initiatives such as the £31 million public-private Online Crime Centre, the Report Fraud service, and a planned Fraud Victims Charter. By contrast, the September report focuses on strengthening law enforcement and asset recovery, reducing the AML supervisory bodies from 25 bodies down to three. It is also planned to expand cryptoasset tracing and asset recovery capabilities. Together, the two papers aim to establish a coordinated national response spanning public fraud prevention, digital platform defence, and systemic illicit finance disruption. RUSI has issued a press release in response to the latest Strategy Report.

CCUK, Ofcom, and Home Office Issue Joint Guidance on Telecoms Data Sharing to Disrupt Fraud

The Comms Council UK (CCUK), in collaboration with Ofcom, the Home Office, and the Information Commissioner’s Office (ICO), has published joint guidance titled Sharing data to tackle fraud: Guidance for telecoms providers to establish clear mechanisms for intelligence sharing across the UK communications sector. Designed for providers of all sizes, the guidance addresses common regulatory misconceptions by emphasising that UK data protection laws, including the UK GDPR, the Data Protection Act 2018, and the Data Use and Access Act 2025, do not constitute a default barrier to sharing information, as crime prevention is explicitly recognised as a legitimate interest. The publication provides practical decision flowcharts, proportionality tests, and operational due-diligence expectations, encouraging providers proactively to share minimised fraud data with law enforcement, financial institutions, and Specified Anti-Fraud Organisations like Cifas and TUFF. The press release is here, the guidance is here, and the appendix is here.

Market Abuse

UK Regulators and Law Enforcement Target Unregistered Peer-to-Peer Crypto Trading Operations Across London

The UK Financial Conduct Authority (FCA), operating in coordination with HM Revenue and Customs (HMRC) and the Metropolitan Police Service, conducted targeted operations against three London locations suspected of operating illegal peer-to-peer cryptocurrency trading businesses. Enforcement officers issued cease-and-desist letters across all three premises, directing operators to immediately cease suspected illegal crypto trading activities. Under UK financial regulations, any entity conducting peer-to-peer crypto trading by way of business must be registered with the FCA to ensure compliance with anti-money laundering frameworks. The FCA emphasised that there are currently no registered peer-to-peer crypto businesses operating in the UK, warning that unregistered platforms create vulnerabilities for laundering illicit funds. The initiative builds upon a prior multi-agency enforcement action conducted in April 2026, with evidence gathered from both operations supporting active criminal investigations.

Other Financial Crime

10th Global Conference on Criminal Finances and Cryptoassets Highlights Advances in Tracing, Seizure, and Cross-Border Intelligence Sharing

The 10th Global Conference on Criminal Finances and Cryptoassets gathered 450 specialists from nearly 90 jurisdictions, with more than 2,000 online participants, at the European Convention Centre Luxembourg. Co-organised by Europol, the United Nations Office on Drugs and Crime (UNODC), and the Basel Institute on Governance, and hosted by Luxembourg’s Bureau de gestion des avoirs (BGA), the hybrid event examined how cryptoassets feature in cyberattacks, sanctions evasion, terrorist financing, trafficking, and violent forced transfers known as "wrench attacks". Participants showcased advancements in cross-border coordination, public-private intelligence sharing, and specialised legal and technological frameworks designed to trace, freeze, and manage illicit digital assets before they can be moved beyond reach.

Cybercrime

Ofcom Launches Industry Engagement on the Role of Artificial Intelligence in Telecoms Cyber Defence

The UK communications regulator, Ofcom, has launched an engagement initiative to examine how advances in artificial intelligence can strengthen cyber defence across critical telecommunications and digital infrastructure networks. The engagement addresses both the capabilities of AI-enabled tools, such as accelerated threat detection, vulnerability management, and incident response, and the risks posed by frontier AI models which can automate cyber-attacks at greater speed and scale. Throughout autumn 2026, Ofcom will hold discussions with industry stakeholders, technical experts, and vendors to evaluate how AI integrates with existing regulatory requirements and ensure standards do not inadvertently hinder security innovation. Ofcom expects to publish its findings in early 2027 to guide future regulatory policy while maintaining high standards of infrastructure resilience, trust, and accountability.