Episode 285

28th September – 1st October 2026

Sanctions

Two Arms Dealers Sentenced to 32 Years in Jail for Unlicensed Global Weapons Brokering

British national, David Greenhalgh, and Greek national, Christos Farmakis, have each been sentenced to 16 years in prison at Southwark Crown Court following their convictions under the UK Export Control Order 2008. An investigation by HM Revenue and Customs (HMRC) revealed that between 2009 and 2016, the two men illegally brokered unlicensed arms deals worth tens of millions of dollars to supply former Soviet military equipment, including combat aircraft, surface-to-air missile systems, and thousands of assault rifles, to conflict zones such as Sudan, South Sudan, and Libya. Authorities established that the defendants deliberately bypassed UK trade control licensing by forging end-user certificates and routing transactions through overseas subsidiary entities to obscure the final destinations of the weapons. Farmakis was tried and sentenced in absentia, with HMRC collaborating with international law enforcement partners to locate and extradite him to the UK.

UN Security Council and UK OFSI Update Sanctions Entries for Terrorist Group KTJ and Iran General Licence

The UN Security Council ISIL (Da'esh) and Al-Qaida Sanctions Committee enacted an official entry amendment on 28th September for terrorist group Khatiba Jama'at al-Tawhid wal-Jihad (KTJ), prompting the UK Foreign, Commonwealth and Development Office (FCDO) to align the UK Sanctions List on 29th September under its asset freeze and arms embargo provisions. Concurrently, the UK Office of Financial Sanctions Implementation (OFSI) updated General Licence INT/2025/7363752, which permits activities related to the Shah Deniz Project, to incorporate new prohibitions under regulations 17A and 17C of the Iran Nuclear Regulations concerning investments as well as insurance and reinsurance services. OFSI has also amended FAQ 204 on how it will assess licence applications involving the designated Iranian banks covered by HM Treasury's licensing guidance.

Money Laundering

MONEYVAL Releases 2025 Annual Report Highlighting First 6th-Round Evaluations and Emerging Typology Risks

MONEYVAL published its Annual Report for 2025, detailing progress under its 2023–2027 Strategy and marking its position as the first assessment body in the Financial Action Task Force (FATF) Global Network to launch 6th-round mutual evaluations with reports adopted for Latvia and Serbia. The report highlights new typology studies addressing illicit finance risks linked to virtual assets and conflict-related proceeds, alongside ongoing monitoring of anti-money laundering and counter-terrorist financing reforms across member jurisdictions and enhanced cooperation with the FATF, European Union, United Nations, and Council of Europe bodies. The Council of Europe's Committee of Ministers formally took note of the annual assessment during its meeting on 23rd September 2026.

MONEYVAL Launches 6th-Round Mutual Evaluation Process of Gibraltar

MONEYVAL has launched the sixth round of its mutual evaluation process for the British Overseas Territory of Gibraltar to assess its compliance with international anti-money laundering and counter-terrorist financing standards. The launch commenced with a high-level exchange between Gibraltar’s Minister for Justice, Trade and Industry, Nigel Feetham, and MONEYVAL Deputy Chair Alfred Zammit, highlighting national commitment to the assessment. Following the exchange, MONEYVAL conducted a training seminar in Gibraltar for approximately 130 public and private sector representatives, including officials from the Gibraltar Financial Services Commission, the Financial Intelligence Unit, the Royal Police's Economic Crime Unit, and the Gaming Commission, focused on Financial Action Task Force (FATF) evaluation standards and methodology.

FATF Releases 2026 Mutual Evaluation Reports for Canada and Türkiye Highlighting Anti-Money Laundering Progress and Governance Gaps

The Financial Action Task Force (FATF) has published mutual evaluation reports assessing the anti-money laundering, counter-terrorist financing, and counter-proliferation financing frameworks of Canada and Türkiye. The evaluation for Canada, conducted jointly with the Asia-Pacific Group on Money Laundering (APG), commended advancements in beneficial ownership transparency, but called for improved risk-based supervision over non-financial businesses, particularly real estate and precious metals dealers, and prioritised prosecution of complex professional money laundering schemes, placing Canada in regular follow-up. Meanwhile, the report for Türkiye recognised strengthened financial intelligence capabilities and international cooperation, while advising authorities to accelerate money laundering prosecutions involving high-risk predicate offences, reduce court case backlogs, and bolster cross-border asset recovery, placing Türkiye in enhanced follow-up. The Canadian government press release is here.

Fraud

Federal and State Authorities Target Multi-million Dollar Fraud Operations Across Investment, Cyber, and Public Sectors

Recent federal and state court actions across the United States have targeted complex fraud schemes involving investment deception, real estate misrepresentation, staged insurance claims, and retail fraud. In California, a federal jury has found wearable technology CEO Michelle Bisnoff guilty of securities and wire fraud for operating a $2 million Ponzi scheme involving falsified patents and fraudulently securing $150,000 in COVID-19 relief funds. In a separate California case, Gilberto Barron received a sentence of seven years and ten months in federal prison for participating in a $10 million real estate fraud which used fake agent identities to sell non-existent properties and laundered proceeds through Las Vegas casinos. At the state level, New Jersey car rental business co-owner Bozena Kolc was sentenced to four years in prison and ordered to pay $314,000 in restitution after pleading guilty to submitting a $273,864 fraudulent insurance claim on a pre-damaged Bentley. Additionally, federal judges in Louisiana sentenced Michigan residents Malik Strodder and Dondrell Smith to 21 and 35 months in prison, respectively, for executing a $340,000 nationwide retail scheme using fraudulent cash cards and fake employee overrides across more than 101 Walmart stores.

In parallel enforcement actions, prosecutors have unsealed indictments and forfeiture filings addressing public sector misconduct, banking insider threats, and cryptocurrency laundering. A federal grand jury in Utah has indicted USDA Assistant Special Agent in Charge Michelle Bouziden for wire fraud and theft after she allegedly collected $51,571 in disability benefits while traveling and hiking abroad. In Georgia, former bank teller Mercedes Henry was arrested on bank fraud and bribery charges for allegedly misusing customer identifiers to transfer $931,500 into conspirator-controlled cryptocurrency accounts. Internationally, federal authorities in Missouri unsealed a complaint charging Vietnamese national Trung Nguyen Van with money laundering, alleging his digital wallets processed $53 million in fraud proceeds, including $569,000 directly linked to a $16 million "pig butchering" investment scheme. Furthermore, federal prosecutors in Massachusetts have initiated civil forfeiture proceedings to recover 110,270 Tether tokens, valued at approximately $47,000, derived from a phishing-based account takeover scheme.

Alongside individual prosecutions, institutional oversight assessments indicate ongoing fraud vulnerabilities within federal IT operations. A Government Accountability Office report evaluating 18 major Department of Defense business programmes, representing $10.3 billion in planned spending, found that seven programmes lacked staff training to recognise signs of cyber fraud or tampering. The assessment also highlighted that eight software development programmes failed to track required performance metrics and three operational systems lacked approved cybersecurity strategies. To mitigate these systemic risks, the GAO recommended establishing formal, role-specific anti-fraud training across all major defence IT programme offices.

Serial Fraudster Jailed for Four Years Over £200,000 Corporate Fraud Scheme and Alias Impersonations

Darren Anderson has been sentenced at Nottingham Crown Court to four years in prison and handed a 15-year company director disqualification following joint investigations by the Insolvency Service and Derbyshire Police. Operating under multiple aliases and false titles, including "Lord Timothy Ahlbeck" and a fabricated medical doctorate, Anderson caused over £200,000 in financial losses across 13 entities during 2022 and 2023 by executing unauthorised direct debit transfers, defaulting on commercial property leases, stealing rented furnishings, and fabricating corporate financial declarations. Investigators established that Anderson breached two prior 15-year director bans issued under previous aliases since 2011, serving as a director for five companies while disqualified to deceive creditors, employees, and industry regulators.

Convicted Fraudster Pays £265,000 Following CPS High Court Civil Recovery Action on Mortgaged Property

The Crown Prosecution Service (CPS) has announced that convicted fraudster Parmjit Dhami has paid £265,000 following High Court civil recovery proceedings targeting a residential property in Ilford. Dhami originally purchased the property in 2010 using a mortgage secured through false income details and fabricated payslips, subsequently collecting rental income from tenants. Although Dhami had previously received a nine-month suspended prison sentence and paid a £146,150 criminal confiscation order in connection with a second fraudulent mortgage scheme from 2014, the CPS Proceeds of Crime Division initiated separate Part 5 civil recovery proceedings seeking an 85% equity share in the Ilford residence. The High Court claim was settled by agreement requiring Dhami and his wife to pay £265,000 within three months, which was settled in full and brought total assets recovered from Dhami across both enforcement actions to over £411,000.

United Kingdom and Cambodia Sign Bilateral Agreement to Combat Southeast Asian Online Scam Centres

The UK and Cambodian governments have signed a Memorandum of Understanding (MoU) to establish joint law enforcement operations aimed at dismantling illegal online scam centres across Southeast Asia. Signed by UK Minister for Fraud Lord Hanson and Cambodian Deputy Prime Minister Sar Sokha, the agreement enhances intelligence sharing, establishes coordinated operations against organised criminal networks, and provides support for human trafficking victims forced to carry out cyber fraud under threat of abuse. To strengthen operational capacity, the UK will deliver training to Cambodian authorities in digital forensics and cyber investigations while partnering through the UK-INTERPOL Global Fraud Taskforce to trace and disrupt the illicit financial flows funding scam compounds.

Bribery and Corruption

GRECO Publishes Anti-Corruption Compliance Summaries for Denmark, Hungary, Türkiye, and Ukraine Under New Transparency Policy

The Council of Europe’s anti-corruption body, GRECO, has published summaries of compliance reports evaluating anti-corruption measures among parliamentarians, judges, prosecutors, and central government officials across Denmark, Hungary, Türkiye, and Ukraine. Issued pursuant to a March 2026 decision requiring summary reports to be published within six months of adoption to strengthen public trust and monitoring transparency, the evaluations reflect varying implementation rates across member states. Denmark and Ukraine formally concluded their Fourth-Round compliance procedures after fully implementing two of six and 19 of 31 recommendations, respectively. In contrast, Hungary and Türkiye remain under active compliance monitoring into 2027, with Hungary fully implementing 10 of 18 recommendations, and Türkiye fully addressing six of 22 Fourth-Round recommendations alongside four of 32 Fifth-Round recommendations targeting central government and law enforcement integrity.

OSCE-Supported Analysis Examines Trends and Benchmarks in Ukraine's Anti-Corruption Case Law

The OSCE Secretariat Extra-Budgetary Support Programme for Ukraine has released a joint analytical report with Ukraine's National Agency on Corruption Prevention (NACP) and the Centre for Political and Legal Reforms reviewing anti-corruption court case law from 2024 and 2025. Presented during an online event on 24th September the study revealed that while registered corruption investigations increased by 6% to 11,467 in 2025 compared to 2023, the proportion of cases referred to court with proposed convictions dropped from 39% to 34%. Among court rulings which entered into legal force in 2025, 80% resulted in guilty verdicts amounting to 2,479 convictions, with fines serving as the main penalty in 72% of cases and custodial sentences imposed on 140 individuals (5%). The analysis also noted a lack of unified structure in general court decisions, contrasted with the High Anti-Corruption Court's consistent practice, providing empirical data for judicial reforms and policy decisions.

Market Abuse

Boise Man Pleads Guilty to Federal Securities Fraud in $49,000 Insider Trading Scheme

A Boise resident, Michael Christensen, has pleaded guilty in federal court to one count of securities fraud in connection with an insider trading scheme. According to the US Attorney’s Office for the District of Idaho, Christensen received a text message on 4th August 2024, from an executive at an Idaho-headquartered public company alerting him to watch for news headlines, which he understood to be material, non-public information. Without informing the executive, Christensen purchased 4,900 shares of the company for approximately $99,350.27. Following a 7th August 2024 public announcement that the company was being acquired, the stock price increased significantly, enabling Christensen to sell his holdings for an illegal profit of $49,609.73. Christensen faces a maximum penalty of up to 20 years in prison, with sentencing scheduled for 15th December 2026.

SEC Charges Former Cummins Accountant, Husband, and Four Associates in $500,000 Insider Trading Scheme

The US Securities and Exchange Commission (SEC) charged former Cummins Inc corporate development accountant Fan “Jocelyn” Yang, her husband Jing Tian, and four associates, namely Zijun Zhang, Shuchen Zhu, Chong Zhang, and Hanxiong Bo, with insider trading in connection with Cummins' February 2022 acquisition of Meritor Inc. According to the SEC complaint filed in federal court in the District of Columbia, Yang tipped non-public acquisition details to Tian, who passed the information down a chain of acquaintances who traded Meritor securities to generate over $500,000 in collective illegal profits. Uncovered by data analysis tools from the SEC Market Abuse Unit's Analysis and Detection Centre, all six defendants consented to final judgments enjoining them from future securities violations, with the four trading defendants agreeing to pay individual disgorgement and civil penalties, while Yang and Tian, who also face criminal charges from the US Attorney’s Office, agreed to court-determined civil penalties.

SEC Fines Zoe Financial $450,000 Over Undisclosed Referral Conflicts of Interest

The US Securities and Exchange Commission (SEC) has announced settled charges against New York-based registered investment adviser Zoe Financial Inc for failing fully and fairly to disclose material conflicts of interest to clients and prospective clients. According to the SEC, Zoe Financial operated an algorithmic referral service to match individuals with third-party investment advisers while simultaneously offering sub-advisory and back-office services through its "Zoe Wealth" platform. Although the initial matching algorithm did not prioritise advisers using Zoe Wealth, company salespeople frequently followed up with prospective clients to recommend non-algorithm-selected advisers who utilised the platform, creating an undisclosed financial incentive conflict which was not properly disclosed in Form ADV filings until December 2024. The SEC also determined that Zoe Financial failed accurately to describe how it mitigated conflicts of interest involving advisory firms which held indirect minority stakes in the company. Without admitting or denying the findings, Zoe Financial agreed to a cease-and-desist order, a censure, a $450,000 civil monetary penalty, and implemented remedial measures, including hiring an in-house chief compliance officer and revising its compliance manual.

Other Financial Crime

Twenty-Four CFD Firms Shut Down or Cancel Permissions Following FCA Regulatory Crackdown

The UK Financial Conduct Authority (FCA) has announced that 21 Contracts for Differences (CFD) firms have closed since 2025 and three others are currently cancelling their regulatory permissions following a targeted supervisory crackdown. The regulator intervened after discovering that firms were conducting minimal UK business while using their FCA-authorised status falsely to imply to retail investors that their linked overseas operations offered UK regulatory protections. Regulatory interventions against non-compliant entities included restricting trading activities, requiring independent business reviews, and opening formal enforcement investigations in two severe cases. Dominic Holland, Director of Sell-Side Supervision at the FCA, emphasised that the authority will continue to step in whenever firms blur the boundaries between UK-regulated activities and offshore businesses to safeguard consumers from complex, high-leverage trading risks.

FCA Secures Over £850,000 Confiscation Orders Against Crypto Fraudsters for Victim Restitution

The UK Financial Conduct Authority (FCA) secured confiscation orders totalling £851,402.27 against Raymondip Bedi (£603,404.28) and Patrick Mavanga (£247,997.99) at Southwark Crown Court following their convictions for operating a £1.5 million cryptoasset investment fraud. Between February 2017 and June 2019, Bedi and Mavanga cold-called consumers to solicit investments in fake cryptocurrency opportunities through entities including CCX Capital and Astaria Group LLP, defrauding at least 65 investors. Following their July 2025 custodial sentencing to terms of five years four months and six years six months, respectively, both defendants face up to an additional five years and two years in prison under the Proceeds of Crime Act 2002 if they fail to satisfy the confiscation orders within three months, with all recovered funds to be distributed directly to victims.

Countries Adopt Global Blueprint to Counter Fast-Evolving Crime in the Digital Age

The UNODC has announced that several nations have formally adopted a comprehensive global blueprint designed to strengthen international cooperation against increasingly sophisticated cyber threats and technology-driven crime. The joint framework establishes a standardised international strategy to align legal, technical, and operational resources across jurisdictions, enabling law enforcement agencies to bridge cross-border security gaps and share intelligence more effectively. By targeting complex online illicit activities which transcend traditional geographic boundaries, the multilateral agreement serves as a vital strategic roadmap to enhance joint enforcement capabilities and foster a safer, more resilient global digital environment.

Cybercrime

NCSC Urges UK Organisations to Patch Active Citrix NetScaler Vulnerabilities

The UK National Cyber Security Centre (NCSC) has issued a security alert urging organisations to promptly mitigate eight vulnerabilities affecting on-premises Citrix NetScaler ADC and NetScaler Gateway deployments. The advisory follows a Citrix security bulletin confirming that two flaws: (1) CVE-2026-88771, an improper input validation issue allowing unauthenticated remote command execution; and, (2) CVE-2026-88772, a memory buffer flaw leading to remote code execution or denial of service, are currently being actively exploited. The NCSC advises network defenders to investigate systems using published indicators of compromise, temporarily isolate vulnerable infrastructure where necessary, apply official software updates, and report suspected incidents to cyber authorities.