Episode 283

21st September – 24th September 2026

Sanctions

US Treasury Sanctions Iranian Digital Asset Exchange BitBank Under Operation Economic Outcast

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated digital asset exchange, BitBank, and its software developer, Pishtaz Simorgh Electronic Trade Company, alongside three individual associates, as part of Operation Economic Outcast. Designated pursuant to Executive Order 13902, BitBank was cited as a key component of Iran's digital asset sanctions-evasion infrastructure, controlled by Iranian financier Babak Zanjani to launder proceeds and transfer hundreds of millions of dollars in Bitcoin to the Islamic Revolutionary Guard Corps (IRGC). As a result of the action, all US-located property and interests of the designated parties are blocked, while foreign financial institutions and individuals engaging with them risk secondary sanctions, including potential exclusion from the US financial system.

US OFAC Terminates Ethiopia Emergency Sanctions and Updates Russia-Related Lukoil Licences

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the expiration of the national emergency declared under Executive Order 14046 regarding Ethiopia, resulting in the removal of previously designated individuals from the Specially Designated Nationals (SDN) List. Concurrently, OFAC updated Russia-related General Licences 128C and 131J, extending authorisations through October 2026 for routine maintenance, retail operations, and wind-down activities of Lukoil International GmbH (LIG) entities outside the Russian Federation. The updated Russia authorisations permit ordinary course business transactions and divestment negotiations provided that no funds are transferred to accounts or entities within Russia and that any potential asset sale completely severs operational ties with parent company Lukoil.

UK Government Revokes Russia Sanctions on Vietnamese-Flagged Oil Tanker ASTRA

The UK Foreign, Commonwealth and Development Office (FCDO) has updated the UK Sanctions List under The Russia (Sanctions) (EU Exit) Regulations 2019 by revoking shipping sanctions previously imposed on the oil tanker ASTRA (IMO 9273387). Operated by Stravax Shipping Co Ltd and currently flagged in Vietnam, the vessel was originally designated on 12th September 2025, for transporting Russian-origin oil or oil products to a third country. Following the official revocation, the vessel is no longer subject to UK port entry prohibitions, detention directions, or maritime access restrictions.

Money Laundering

FCA Opens Enforcement Investigation into Euro Exchange Securities UK Ltd Over Financial Crime Controls

The UK Financial Conduct Authority (FCA) has opened a formal investigation into payments firm Euro Exchange Securities UK Ltd (EES) to examine potential compliance failures across its anti-money laundering and risk management framework. The regulatory inquiry is evaluating EES's customer due diligence procedures, ongoing transaction monitoring, internal governance, record-keeping mechanisms, and resource allocation, though the FCA emphasised that it has not yet reached conclusions regarding whether formal statutory breaches occurred. The investigation follows supervisory actions taken in June 2026, when the regulator ordered EES to cease all regulated electronic money and payment services over financial crime risks, leading to the High Court appointment of special administrators from Teneo Financial Advisory Limited to secure assets and ringfence funds in designated safeguarding accounts.

FCA to Assume Anti-Money Laundering Supervision of UK Legal and Accountancy Sectors in Late 2028

Steve Smart, Executive Director of Enforcement and Market Oversight at the Financial Conduct Authority (FCA), has announced at the Law Society Economic Crime Conference 2026 that the regulator will assume anti-money laundering (AML) supervision over approximately 60,000 entities across the UK's legal and accounting sectors beginning in late 2028. Smart outlined an intelligence-led, technology-enabled supervisory strategy aimed at targeting professional enablers and high-harm criminal networks while minimising operational burdens on compliant firms. Highlighting that the FCA currently processes over 56 million data records daily, Smart detailed how the regulator plans to integrate artificial intelligence, explore agentic supervision tools, and expand public-private data partnerships, such as the National Crime Agency's data fusion initiative, to identify systemic risks earlier across the professional services sector.

FATF Issues Warning and Red-Flag Guidance on Emerging Illicit Finance Risks in Gaming and Gambling Sectors

The Financial Action Task Force (FATF) has issued a global alert and published comprehensive red-flag risk indicators detailing emerging money laundering, terrorist financing, and proliferation financing threats across the evolving gaming and gambling sectors. Based on a year-long project drawing from over 80 jurisdictions, the FATF identified illegal offshore operators and the rapid growth of online platforms using digital payment systems, such as e-wallets, mobile money, and virtual assets, as major drivers of cross-border financial crime. The report highlighted how organised criminal networks, fraudsters, and professional money launderers exploit complex beneficial ownership structures, smurfing, and non-genuine betting patterns to infiltrate platforms and obscure illicit funds. FATF President Giles Thomson urged governments to adopt risk-based controls, tighten operator licensing, boost international cooperation, and deploy the new behavioural and transactional warning signs to strengthen oversight across public and private sectors. The press release is here, which includes a link to the report.

Bribery and Corruption

Ex-Vitol Energy Trader Javier Aguilar Sentenced to Four Years in Prison for $500 Million International Bribery Scheme

Former Vitol oil trader, Javier Aguilar, has been sentenced by a federal court in Brooklyn to 48 months in prison for his role in two international bribery and money laundering schemes targeting public officials in Ecuador and Mexico. Following a February 2024 trial conviction for Foreign Corrupt Practices Act (FCPA) violations and money laundering related to Ecuadorian fuel oil contracts, along with a guilty plea for bribing officials at Mexican state oil affiliate PEMEX Procurement International, US District Judge Eric N. Vitaliano also ordered Aguilar to forfeit approximately $7.13 million and pay a $100,000 fine. Federal prosecutors detailed that Aguilar and co-conspirators funnelled more than $1 million in bribes to secure over $500 million in oil and gas contracts for Vitol, using offshore shell entities, fake contracts, and alias email accounts to conceal the illicit transactions. Aguilar will be deported to Mexico upon completion of his custodial sentence.

GRECO President Highlights Anti-Corruption Role and Urges Closer EU Institutional Ties at IACA Conference

David Meyer, President of the Council of Europe's Group of States against Corruption (GRECO), addressed the European Conference on Measuring the Effectiveness of Anti-Corruption Agencies organised by the International Anti-Corruption Academy (IACA) in Rome, Italy. Speaking on a panel focused on the first European anti-corruption strategy alongside representatives from the European Commission, academia, and civil society, Meyer presented GRECO's contribution and key monitoring findings to outline priority areas for strengthening anti-corruption efforts across Europe. Meyer emphasised the need to deepen the institutional relationship between the European Union and GRECO in accordance with its statute, arguing that closer EU participation would enhance independent scrutiny, policy coherence, and mutual accountability across the region.

Fraud

Former Puerto Rican Bank CEO Sentenced to Over Nine Years in Prison for $24.9 Million Wire Fraud and Venezuela Sanctions Evasion

Tomás Niembro Concha, 64, former chief executive officer of Puerto Rico-based Nodus International Bank, was sentenced in federal court to 112 months in prison and ordered to forfeit over $16.9 million for his role in a wire fraud conspiracy and Venezuela sanctions evasion scheme. According to the US Department of Justice, Niembro conspired with the bank's board chairman between 2017 and 2023 fraudulently to siphon at least $24.9 million from Nodus Bank through self-dealing loans, sham investments, and promissory notes, ultimately causing the financial institution's 2023 liquidation. Additionally, between 2021 and 2023, Niembro conspired to violate the International Emergency Economic Powers Act (IEEPA) by executing an unauthorised private agreement to sell a foreclosed Southampton, New York, residential property back to an OFAC-designated Specially Designated National linked to Venezuela's state oil company, Petróleos de Venezuela, S.A. (PDVSA), through a front company.

Cybercrime

NCSC Releases Scheme Documents for New Cyber Adversary Simulation Assurance Framework

The UK National Cyber Security Centre (NCSC) has published the initial scheme documents and buyer guidance for its upcoming Cyber Adversary Simulation (CyAS) assurance scheme. Authored by Catherine H, Head of Assured Professional Services Schemes at the NCSC, the publications set out standard criteria for companies seeking NCSC assurance as adversary simulation providers while offering buyer guidance to help organisations evaluate service quality. Developed in partnership with sector regulators and government policy bodies, the capability-led framework moves away from fixed-script security testing, requiring assured providers to apply an adversarial mindset, conduct continuous tailored reconnaissance, and execute customised attack simulations aligned with specific client resilience objectives.