Episode 286

2nd October – 4th October 2026

Sanctions

US Treasury Updates Sanctions Regimes Targeting Transnational Criminal Networks and Regulatory Compliance

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) enacted a series of sanctions enforcement and regulatory updates across multiple programmes. OFAC designated 10 individuals and entities associated with the foreign terrorist organisation Tren de Aragua, including FBI fugitive Anibal Alexander Canelon Aguirre, for operating an international cyber-fraud and cryptocurrency laundering network which siphoned over $40 million from US banks via automated teller machine "jackpotting" attacks. Concurrently, the Department amended the Cuban Assets Control Regulations under Executive Order 14404 to prohibit indirect financial transactions with military- and intelligence-linked entities on the State Department's Cuba Restricted List. Finally, OFAC updated its Specially Designated Nationals list by removing several individual, corporate, and vessel listings previously sanctioned under Belarus, counter-narcotics, and Libya programmes.

US Treasury Sanctions Shadow Banking "A7 Network" and Proposes Fund Transmittal Ban

As part of Operation Economic Outcast, the US Department of the Treasury has announced coordinated enforcement actions targeting the A7 Network, a shadow banking and sanctions evasion network led by Ilan Mironovich Shor with ties to Russia. Treasury's Office of Foreign Assets Control (OFAC) designated the A7 Network as a significant transnational criminal organisation, citing its role in disguising illicit payments as legitimate commercial trade for state and non-state actors including the Central Bank of Iran, the Islamic Revolutionary Guard Corps (IRGC), Hamas, ransomware groups, and North Korean cyber threat actors. Concurrently, the Financial Crimes Enforcement Network (FinCEN) issued an alert outlining key red flags for financial institutions and published a Notice of Proposed Rulemaking under the Combating Russian Money Laundering Act which would prohibit fund transmittals involving the network's sub-agents, which collectively processed over $17 billion between January 2025 and June 2026. The FinCEN press release is here.

UK Designates 31 New Individuals, Entities, and LNG Tankers Under Russia Sanctions Regime

The UK Foreign, Commonwealth and Development Office (FCDO) has updated the UK Sanctions List under The Russia (Sanctions) (EU Exit) Regulations 2019, adding 31 new designations targeting individuals, entities, and vessels involved in Russian military, political, and energy operations. The update imposes asset freezes, travel bans, trust services sanctions, and director disqualifications on Russian military commanders, occupation administrators, corporate executives, and individuals associated with the forced deportation and re-education of Ukrainian children, alongside corporate entities such as Novatek Gas and Power Asia Pte Ltd. Additionally, eight liquefied natural gas (LNG) tankers were specified under shipping and trade sanctions for carrying Russian-origin LNG to third countries, prohibiting them from entering UK ports or receiving chartering, operational, and financial services from UK persons. The government press release is here.

UK OFSI Amends Oil Price Cap General Licences to Extend Sakhalin-2 Expiration Date to December 2026

HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has updated its guidance, publication notices, and licensing documentation under the UK’s Maritime Services Ban and Oil Price Cap exception framework. The regulatory update formally amended General Licence INT/2022/2470156 (Exempt Projects and Countries) and General Licence INT/2025/5635700 (Russian Oil Exempt Projects) to extend the expiration date for the Sakhalin-2 project to 31st December 2026. Under the updated general licences, permitted entities and financial institutions may continue business operations, payment processing, and maritime transportation of Russian oil originating from Sakhalin-2 to Japan, provided that transactions exclude designated persons, prohibit reselling in third countries, and strictly comply with record-keeping rules and 30-day OFSI notification requirements.

UK OTSI Issues General Trade Licences Authorising Maritime LNG Transport from Sakhalin-2 to Japan and South Korea

The UK Office of Trade Sanctions Implementation (OTSI) published two general trade licences under the Russia sanctions regime authorising UK involvement in the maritime transportation of Russian liquefied natural gas (LNG) to Japan and South Korea. Designed to support the energy security of international partners as they reduce reliance on Russian energy, the targeted authorisations cover supply contracts concluded prior to 17th June 2025, for LNG originating specifically from the Sakhalin-2 Project. The licences will apply from 1st January 2027, when UK restrictions on pre-existing long-term contracts take effect, through until 31st March 2028, and strictly exclude trade under new contracts or any involvement of designated persons.

UK OFSI Launches 2026 Annual Frozen Assets Reporting Exercise

HM Treasury’s Office of Financial Sanctions Implementation (OFSI) has issued a Financial Sanctions Notice initiating the United Kingdom's annual Frozen Assets Reporting (2026) review. Under the mandate, all individuals and institutions holding or controlling funds or economic resources owned, held, or controlled by designated persons subject to UK financial sanctions must report their asset values as of close of business on 30th September 2026. Completed returns, covering both UK-based assets and relevant overseas holdings subject to UK sanctions legislation, while excluding accounts blocked solely by foreign authorities such as OFAC, must be submitted to OFSI using an official template no later than Monday 30th November 2026. OFSI noted that foreign currency holdings, securities, and cryptoassets must be reported in GBP values, reminding firms that failing to comply with financial sanctions legislation or attempting to circumvent its provisions constitutes a criminal offence.

Fraud

National Trading Standards Launches AI Scam Watchlist as Survey Shows Half of UK Adults Struggle to Identify Fraud

National Trading Standards (NTS) in the UK has launched its official AI Scam Watchlist, highlighting how criminal networks are deploying artificial intelligence tools, including voice cloning, deepfakes, digital humans, and synthetic images, to scale and personalise existing frauds such as shopping, romance, and investment schemes. Accompanying research indicates that nearly half (47%) of UK adults find it increasingly difficult to verify genuine online content, while 24% report feeling overwhelmed by the growing technical sophistication of scams. Regulatory and consumer protection leaders noted that while AI reduces the technical barriers for fraudsters to execute convincing campaigns, core preventive measures, such as making independent checks, verifying sender identities, and pausing before transferring funds, remain critical defences against AI-enabled fraud.

Two Government Contractors Plead Guilty to $80 Million Federal Set-Aside Procurement Fraud Scheme

The US Attorney’s Office for the Middle District of Pennsylvania announced that Thomas Lauer and Rebecca Davis have pleaded guilty to conspiracy to commit major fraud against the United States. Federal prosecutors established that between 2007 and 2014, Lauer and Davis conspired fraudulently to obtain five set-aside contracts valued at over $80 million awarded to Davis's firm, Elstner Construction Company, at Letterkenny Army Depot under the Small Business Administration’s 8(a) Business Development Programme. Davis admitted to violating programme rules by re-entering the 8(a) programme after prior participation under a different corporate name and submitting false compliance certifications, while Lauer also admitted to misrepresenting employee expenditure levels to secure a $5.3 million Service-Disabled Veteran-Owned Small Business contract at the Salem VA Medical Centre. Under their respective plea agreements, Davis agreed to pay $6 million in restitution, while Lauer agreed to pay approximately $6.45 million in restitution, with both defendants facing a maximum statutory sentence of up to five years in prison.

Fifteen Alleged Gang Members Charged in $620,000 Mail Theft and Bank Fraud Conspiracy in New York

Federal prosecutors in the Northern District of New York have unsealed a criminal complaint charging fifteen alleged members and associates of the Untouchable Gorilla Stone Nation gang with participation in a bank fraud conspiracy. According to court documents, the defendants operated in Albany and surrounding regions since at least September 2024, allegedly stealing cheques from business and residential mailboxes to defraud individuals, financial institutions, and the US Treasury out of more than $620,000 to fund gang operations. Investigated jointly by the FBI, US Postal Inspection Service, IRS-CI, and the Albany Police Department under "Operation Certified Delivery," the bank fraud conspiracy charge carries a maximum statutory penalty of up to 30 years in prison, a $1 million fine, and five years of supervised release.

Bribery and Corruption

Former Restaurant Supply Cooperative CEO and Brother Indicted in $80 Million Kickback and Money Laundering Scheme

A federal grand jury in the Southern District of Florida has unsealed an indictment charging Janet Risi Field, former CEO of Independent Purchasing Cooperative, Inc (IPC), and her brother, Steven Louis Risi, for allegedly operating a decades-long bribery, kickback, and money-laundering scheme. Federal prosecutors allege that between 1996 and 2021, Field used her position overseeing supply chain operations for over 20,000 fast-food franchise locations to solicit secret payments from vendor brokers in exchange for food and services supply contracts. The defendants allegedly funnelled more than $60 million in illicit kickbacks through shell companies and personal slush funds, defrauding thousands of restaurant franchisees of over $80 million while concealing the arrangement from IPC's board. Both defendants face charges of conspiracy to commit money laundering and engaging in unlawful monetary transactions, with Risi Field facing additional charges including wire fraud and honest services wire fraud.

United States Withdraws from Council of Europe's Anti-Corruption Monitoring Body GRECO

The United States has formally notified the Council of Europe of its withdrawal from the Group of States against Corruption (GRECO), ending its participation in the Strasbourg-based anti-corruption watchdog after 26 years. A US Department of State spokesperson stated that an internal review concluded membership no longer provided tangible benefits to national security, signalling a shift toward direct tools such as sanctions, visa restrictions, and targeted assistance over multilateral monitoring. In response, the Council of Europe acknowledged the US as a valuable contributor and noted that GRECO remains open to resuming future cooperation to strengthen integrity and prevent corruption.

Market Abuse

SEC Charges Former Pharmaceutical Executive Mukesh Asudani with Insider Trading Ahead of Acquisition Announcement

The US Securities and Exchange Commission (SEC) has filed civil fraud charges in the US District Court for the Southern District of New York against Mukesh Asudani, a former Senior Vice President of Human Resources at a publicly traded pharmaceutical company. The SEC alleges that Asudani engaged in illegal insider trading ahead of the 11th October 2021 public announcement that Supernus Pharmaceuticals Inc had agreed to acquire Adamas Pharmaceuticals Inc. The complaint charges Asudani with violating Sections 10(b) and 14(e) of the Securities Exchange Act of 1934 along with Rules 10b-5 and 14e-3 thereunder, and seeks permanent injunctive relief, disgorgement with prejudgment interest, a civil penalty, and an officer-and-director bar.

Other Financial Crime

ESMA Recommends Revisions to Strengthen EU MiCA Framework for DeFi, Staking, and Fraud Prevention

The European Securities and Markets Authority (ESMA) submitted its official response to the European Commission's consultation on reviewing the Markets in Crypto-Assets Regulation (MiCA), calling for targeted updates to address emerging digital finance models. ESMA's recommendations aim to enhance investor protection through stricter marketing controls on influencers, transparent cost disclosures, and proportionate requirements for staking, lending, and borrowing activities. To strengthen EU-wide supervisory capabilities, the regulator called for expanded authority to block fraudulent websites, freeze cryptoassets suspected of involvement in market abuse or terrorist financing, restrict unauthorised third-country entities, and prohibit regulated firms from offering services tied to non-compliant stablecoins. Furthermore, ESMA advocated for clear criteria to define decentralised finance (DeFi), binding opinions on token classification, streamlined white-paper notification procedures, and a long-term framework for tokenised capital markets.

Former NCA Officer Ordered to Repay £1.8 Million Following Bitcoin Theft from Dark Web Seizure

The Crown Prosecution Service (CPS) has secured a £1,810,678.93 confiscation order under the Proceeds of Crime Act 2002 against former National Crime Agency (NCA) officer Paul Chowles. Chowles, 44, was sentenced in July 2025 to five years and six months in prison after pleading guilty to theft and money laundering charges for stealing 50 Bitcoin, originally worth approximately £60,000, which had been seized during a law enforcement investigation into the dark web marketplace Silk Road 2.0. Financial investigators recovered 30 Bitcoin from Chowles, and the CPS Proceeds of Crime Division secured the confiscation order to reflect the cryptocurrency's appreciated market value, with the recovered funds directed toward a victim compensation order.