FinCrime Week

On 13 October 2026 the NCA reported on an international crackdown it hosted from 6 to 9 October, bringing together 15 law enforcement agencies and 15 technology companies. The NCA says almost 30 suspected scammers have been arrested, including 19 people in Ghana and nine in Nigeria's Delta State, with 303 electronic devices seized in Ghana. It says 3.7 million online profiles and accounts were removed by Meta, and that private sector partners identified a total of $11 million in potentially freezable funds. The NCA's page describes arrests and does not report any convictions.

On 12 October 2026 the UK added two individuals to the UK Sanctions List under the Iran (Sanctions) Regulations 2023: Ruhollah Bazghandi (Unique ID IRN0282, with Rouhollah Azimi recorded as a Primary Name Variation) and Shahram Ali Reza Tamarzadeh Jakki (Unique ID IRN0283, with Farhad Ali Tamarzadeh recorded as a Primary Name Variation). The notice records an asset freeze, a travel ban and a director disqualification sanction for each. In its statements of reasons the Secretary of State says there are reasonable grounds to suspect each is an involved person, citing hostile activity by the Government of Iran. For Bazghandi the stated grounds include espionage and threatening, planning or conducting attacks. For Jakki the stated ground is conduct supporting activity of that attack-related kind in a country other than Iran.

On 13 October 2026 the FCA announced that three individuals were arrested following a joint operation with the National Crime Agency. More than 100 FCA and NCA staff took part in searches at five residential premises in London and Manchester, and FCA investigators seized more than 30 mobile phones, laptops and tablets. The FCA describes the operation as targeting a suspected organised criminal group engaging in insider dealing and money laundering. The three people were being interviewed at police stations in London and Manchester. The announcement gives no trading or laundering values, and an arrest is not a finding of guilt.

On 16 October 2026 the FCA published a statement saying it had reviewed its regulatory action against individuals whose convictions have recently been overturned by the Court of Appeal. Because those convictions formed the basis for the FCA's action, it revoked the bans on Colin Bermingham, Philippe Moryoussef, Jonathan Mathew and Christian Bittar and removed the associated Final Notices from FCA channels. The FCA says it will take no further action against these individuals in relation to this matter. The statement is limited to those four people and does not describe the court's reasoning.

On 8 October 2026 the UK Government announced 38 new Russia sanctions designations. The announced targets include two Russian oil companies, 12 oil tankers described as part of Russia's shadow fleet, crypto exchanges and payment platforms, and suppliers of goods the UK, US and EU consider important to Russia's military production. The Government says it suspects the named crypto and payment entities are being used to circumvent financial sanctions, and says two of them processed or facilitated transactions with the A7 network. Those statements describe the Government's stated basis for the action and should not be extended to other platforms without evidence.

On 8 October 2026 the FCA published results from a survey of 411 corporate finance firms, to which 382 responded. Most respondents were small: 64% had nine or fewer employees and 89% had fewer than 50. The FCA says 63% reported a compliance function that was not dedicated solely to compliance, while 90% used some form of third-party compliance support. Forty-seven per cent reported carrying out all activities covered by the survey. Reported gaps included 90 firms without arrangements for whistleblowers to disclose concerns, 82 without a breach register, 82 where compliance did not attend management-body meetings, and 140 where regulatory compliance was not part of staff performance assessment. These are self-reported survey results, not findings from direct testing of every respondent.

On 5 October 2026 FinCEN announced that it was withdrawing two proposed digital-asset rules, with the Federal Register withdrawals effective on 6 October. The first was a 2020 proposal for banks and money service businesses to report, keep records and verify customers for certain transactions involving convertible virtual currency or digital assets held in unhosted or specified foreign-hosted wallets. The second withdrew both a 2023 finding that international convertible virtual currency mixing was a class of transactions of primary money laundering concern and a proposed special measure requiring enhanced records and reports. FinCEN says it will take no further action on the unhosted-wallet proposal. It also says illicit actors continue to use mixers, that it will continue monitoring mixer activity and that it may take future steps.

On 9 October 2026 OFSI added FAQ 205 on what happens to specific licences when a designated person is delisted. OFSI says UK financial sanctions cease to apply to that person or entity on delisting. A specific licence that concerns only the delisted person and no other relevant sanctions is no longer needed, and the holder does not need to ask OFSI to revoke it or contact OFSI about its status. Pending applications that cease to be required will be closed. If the person or entity is later relisted, earlier specific licences do not reactivate and a new licence application is required.

On 30 September 2026 the FCA opened its authorisation gateway, allowing crypto firms to apply for authorisation under the future UK cryptoasset regime. The FCA says firms intending to continue operating in the UK should apply by 28 February 2027. The new regime itself comes into force on 25 October 2027, so the gateway opening on 30 September was an application milestone and not the start of the regime. The FCA states that authorisation is not automatic. Existing firms that apply during the application period can continue providing cryptoasset services, including taking new business, while an unresolved application is assessed. Applicants will be assessed against FCA standards covering consumer protection, safeguarding of customer assets, market integrity and financial resilience.

The government's Proceeds of Crime factsheet for the Crime and Policing Act 2026 was updated on 30 September 2026. It describes reforms to confiscation under Parts 2 and 4 of the Proceeds of Crime Act 2002, including changes to confiscation orders and their enforcement. It also describes a mechanism to redirect additional recovered funds towards victims who have outstanding compensation orders, and costs and expenses protections for enforcement authorities in specified civil recovery proceedings. The Act also introduces offences concerning the possession or supply of SIM farms without good reason or adequate due diligence. The factsheet does not state a commencement date, and the update date should not be read as the date any provision came into force.

On 1 October 2026 the UK government announced a Russia sanctions package of 31 measures. The package comprises 23 individuals and entities and eight ships, so the figure of 31 counts measures and is not a count of newly designated people or companies. The vessels include three shadow fleet vessels, two vessels providing bunkering services and three Russian owned ice class vessels. The package also targets disinformation networks and people connected with abuses in occupied Ukraine. The announcement says existing licensing arrangements were extended on a targeted and time limited basis to cover LNG, to support the energy security of Japan and South Korea.

On 28 September 2026 the FCA announced that it had obtained confiscation orders against Raymondip Bedi and Patrick Mavanga. Bedi was ordered to pay £603,404.28 and Mavanga £247,997.99. The FCA says at least 65 investors lost £1,541,799. It says it has identified and contacted victims and that funds recovered through the confiscation process will be returned to victims. The two defendants were sentenced in July 2025, so the event reported this week is the confiscation and victim recovery stage, and not the original conviction or sentencing.

On 23 September 2026 the FCA published findings from a multi-firm review into money mule activity and cashing out, drawing on a survey of 35 retail banks, building societies, challenger banks, payment institutions and EMIs, together with a public/private cell involving 22 regulated firms that examined 140 cases covering seven fraud types. The FCA states that 238,396 suspected mule accounts were reported closed in 2025, compared with 184,935 in 2023 and 233,269 in 2024. It is explicit that this increase should not be read as proof that underlying mule account prevalence has grown, since it may also reflect growth in firms' customer bases and improvements in how firms identify mule activity. On cashing out, the FCA found that fraud proceeds were usually moved through two to five mule accounts before being cashed out, with the highest concentration of cash-out activity occurring at the second mule account in the chain. Card payments were the most common cash-out method, and international and crypto cash-outs were generally higher in value than other methods.

On 22 September 2026 the FCA set out its plan for AML supervisory reform, under which it will take over anti-money laundering and counter-terrorist financing supervision of legal service providers, accountancy service providers, and trust and company service providers currently supervised by professional body supervisors (PBSs) or by HMRC. The FCA states that approximately 60,000 businesses and sole practitioners are expected to be affected by the transfer. It says legislation is still required before the reform can take effect, and that it does not expect the phased transition to begin until late 2028, with the remaining PBS-supervised population moving to the FCA by around 2030. The FCA states that, in the meantime, nothing changes: affected businesses should continue their existing AML processes and current supervisory relationships.

On 23 September 2026 the Office of Financial Sanctions Implementation (OFSI) introduced an immediate presumption of denial for licence applications made by, or connected to, five designated Iranian banks: Bank Sepah, Melli Bank plc, Bank Saderat, Persia International Bank and Bank Tejarat. OFSI states that applications continue to be considered individually, and that applicants must demonstrate clear and compelling reasons for a licence to be granted. OFSI also confirms that General Licence INT/2025/7628424 will not be renewed when it expires on 22 October 2026. In FAQ 204, added to OFSI's UK financial sanctions FAQs on 24 September 2026, OFSI states that licences for the covered banks will only be granted where required by law or in exceptional and urgent circumstances.

On 22 September 2026 the UK and Cambodian governments announced a new memorandum of understanding addressing online scam networks. The announcement states the cooperation will include closer intelligence sharing, joint financial and digital investigations, and stronger protections for trafficking victims linked to scam operations. The UK Government places the initiative within wider international efforts targeting scam compounds operating across Southeast Asia.

On 16 September 2026 the FCA published PS26/18, its final guidance on when cryptoasset activities need FCA authorisation, which sits in the Handbook as PERG 18. The FCA states that from 25 October 2027 the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 will introduce new regulated activities for cryptoassets into its perimeter, and that anyone wishing to carry on those activities by way of business in the UK will need to apply for authorisation unless a relevant exemption applies or they can use the savings or transitional run off provisions. The FCA also states that existing registrations and permissions will not convert automatically, and that the application window for firms wanting to use the transitional arrangements opens on 30 September 2026 and closes on 28 February 2027. PERG 18 describes itself as the FCA's view of how the statutory perimeter applies to regulated cryptoasset activities. It says it does not create, widen or narrow the regulated activities, specified investments, exclusions or exemptions set out in legislation, and that it does not bind the courts. The FCA adds that it plans to consult on further changes to the guidance in late 2026, following a Government statutory instrument amending the underlying regulations.

On 17 September 2026 the US Treasury's Office of Foreign Assets Control (OFAC) designated BitBank, which Treasury describes as an Iranian digital assets exchange controlled by OFAC-designated financier Babak Zanjani, together with its developer, Pishtaz Simorgh Electronic Trade Company, and three individuals Treasury calls associates of Zanjani: Hossein Ali Zaker Hossein, Mohammad Mahdi Zaker Hossein and Seyed Adel Heidari. Treasury states that all designations were taken pursuant to Executive Order 13902. It gives different bases within that order: BitBank and Pishtaz Simorgh for operating in the digital asset sector of the Iranian economy, and each of the three individuals for having acted or purported to act, directly or indirectly, for or on behalf of Zanjani, Pishtaz Simorgh and Dot One Value Creation Group respectively. Treasury describes the designated persons as key components of the Iranian regime's digital assets-based sanctions evasion infrastructure and states that OFAC-designated Hormuz Safe Marine Services Authority has used BitBank since June 2026 to transfer payments it received to the Iranian regime. Treasury points readers to OFAC FAQs 1250 and 1257 on sanctions risk associated with Iranian digital asset exchanges.

On 15 September 2026 the US Department of Justice announced that Alex Nain Saab Moran, a former Minister of Industry in the Maduro government, pleaded guilty to conspiracy to launder monetary instruments. The plea was heard by US District Judge Kathleen M. Williams in Miami. According to court documents, DOJ states that Saab carried out a nearly decade-long conspiracy to corruptly profit from Venezuela's CLAP food and medicine programme. As part of the plea, DOJ states that Saab admitted organising a system of bribes and other illegal payments to public officials so that entities secretly controlled by the conspirators could win Venezuelan government contracts, and that he used shell companies outside Venezuela to launder the proceeds around the world, including to the United States. DOJ also states that the conspirators used fake companies, false invoices, false shipping records and other fraudulent documents to skim hundreds of millions of dollars, but the release does not present that description as part of the plea. Saab faces a maximum penalty of 20 years in prison. DOJ states that a sentencing date has not been set and that a federal judge will determine any sentence after considering the US Sentencing Guidelines and other statutory factors.

On 15 September 2026 five members of an organised crime group were sentenced at Liverpool Crown Court to a combined total of almost 40 years in an NCA case involving the facilitation of illegal entry by Vietnamese migrants and the laundering of more than £1.6m in cash from the criminal activity. The NCA worked jointly with French and Belgian law enforcement partners. The NCA states the group took migrants' passports in France, used them as a form of debt bondage, collected money from the migrants and sent payments back to Vietnam through Post Offices and money transfer bureaux including Western Union, MoneyGram and Ria. Production Orders served on those three providers showed more than £1.65m transferred across 740 transactions to accounts in Vietnam between July 2024 and October 2025. The NCA also states that migrants were placed in workplaces under debt bondage arrangements, including nail salons referred to in the group's messages, and that many worked in the grey economy after arriving. Individual sentences ranged from four years to 12 years and six months.

On 8 September 2026, the US Treasury's Office of Foreign Assets Control (OFAC) designated 36 targets under an action Treasury branded 'Operation Economic Outcast'. Twenty-seven are Iranian airlines, including Iran Air Tour, Iran Aseman Airlines, Kish Airlines, Qeshm Air and Saha Airlines, designated under Executive Order 13902 for operating in Iran's aviation sector. Of the nine remaining targets, eight entities and one individual, Ibrahim Ali Mohamed Mohamed Mahran, based across the UAE, Türkiye, Malaysia, Kazakhstan and the UK, were designated under Executive Order 13224, as amended, for roles including supporting Mahan Air, aircraft management, cargo services, logistics and general sales agent activity. Treasury cited different bases for different targets within that group, including material support, ownership or control, and leadership or official status, rather than a single uniform basis. Treasury separately suspended three general licences previously available under the Iranian Transactions and Sanctions Regulations. All property and interests in property of designated persons within US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.

FinCEN published a Financial Trend Analysis, issued pursuant to Section 6206 of the Anti-Money Laundering Act of 2020, analysing 5,702 Bank Secrecy Act reports filed by 471 financial institutions between 1 March 2025 and 28 February 2026 that identified approximately $17.5bn in suspicious activity linked to suspected health care fraud (completed and attempted transactions combined). Depository institutions filed 89% of the reports and accounted for 87% of the dollar volume. Home health care businesses were the most frequently identified type of suspected fraudulent provider, appearing in over a fifth of the dataset. FinCEN separately detailed a Puerto Rico-specific pattern in which Medicaid recipients allegedly withdrew funds shortly before an eligibility review to obtain a bank balance certification letter showing they qualified, then redeposited the funds within days; 59 Puerto Rican financial cooperatives filed 1,641 of the reports in the dataset, almost entirely describing this pattern.

The NCA's National Economic Crime Centre (NECC) published its 2025-26 Annual Report, confirming cryptoassets as the third-ranked priority among the nine 'Economic Crime System Priorities' agreed with the FCA, HM Treasury and the Home Office as part of Economic Crime Plan 2 (the priorities themselves were published in July 2025; only professional enablers and politically exposed persons rank above cryptoassets). The report states the NECC is 'developing a more proactive and intelligence-led crypto capability' and cites 'the innovative use of crypto asset products to evade detection and move illicit value at scale' as a growing feature of the illicit finance landscape. It also updates figures for Operation Destabilise, the NECC's investigation into Russian-speaking cash-to-crypto laundering networks: 129 arrests and over £25m seized in cash and cryptoassets in the UK since 2022, plus a further $24m and over €2.6m seized internationally using intelligence the operation generated.

Edwin Omokhuale, 39, was arrested by An Garda Síochána at Dublin Airport on 9 September 2026 as he attempted to board a flight to Paris, acting on an NCA warrant. The NCA states he is wanted in connection with money laundering linked to an alleged fraud of approximately $23m (around £17m) against an Australian mining company in early 2023, in which company employees were allegedly deceived into transferring funds to accounts controlled by UK-based fraudsters. Omokhuale, who lived in the UK at the time of the alleged fraud, appeared before a Dublin court on 10 September 2026 as extradition proceedings to the UK began. No charges have been determined by a UK court and the allegations remain unproven.

OFSI imposed a £4,732,830.58 civil monetary penalty on Citibank, N.A.'s London branch under section 146 of the Policing and Crime Act 2017, for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019 and the Global Anti-Corruption Sanctions Regulations 2021. Across eight separate breach categories, the bank processed 970 payments worth a combined £19.7m involving designated persons and banks including Alfa-Bank, Gazprombank and Credit Bank of Moscow, largely in the year following Russia's 2022 invasion of Ukraine. OFSI rated the case Level 4, its most serious category, and applied a 40% combined discount for voluntary disclosure, cooperation and early settlement against a baseline penalty of £7.89m.

FinCEN analysed 33,904 Bank Secrecy Act reports filed between September 2023 and December 2025 and identified approximately $12.7bn in financial activity linked to suspected 'pig butchering' and romance-baiting investment scams, run largely by transnational criminal groups operating scam compounds in Southeast Asia. The alert details the scam lifecycle, from fake investment platforms and 'guarantee marketplaces' selling laundering and phishing services, through shell companies, money mules and stablecoin transfers, and encourages 314(b) information sharing between institutions.

The SEC charged Mark D. Hanf, former CEO of Pacific Private Money Group LLC, and Hoai-Nam Chu Phan (Nam Phan), former COO of a PPMG subsidiary, over a Ponzi-like scheme run from December 2021 to November 2025. The Novato, California-based fund raised over $80m from roughly 190 mostly retail investors, many retired senior citizens, on promises of guaranteed returns from real estate-secured loans. The SEC alleges returns were largely paid from new investor money rather than genuine loan income, that Hanf personally misappropriated more than $7m, and that outstanding investor obligations of approximately $121m are backed by less than $17m in recoverable assets.

The FCA has decided to ban Daniel Thomas, a director at DPT Financial Solutions Limited (an appointed representative of Quilter Financial Services), from working in financial services and fine him £742,700 after provisionally finding that he recklessly gave defined benefit pension transfer advice he was neither qualified nor permitted to provide. Thomas has referred the Decision Notice to the Upper Tribunal, so the findings remain provisional and the FCA will take no action until the Tribunal reaches its decision. Thomas advised 53 clients across 63 transfer cases, some of them British Steel Pension Scheme members the FCA regards as particularly vulnerable, earning over £173,000 in fees. The FCA provisionally found that he misled clients and pension providers about his qualifications, separately provided misleading information to his principal firm about his involvement in the pension transfer cases, destroyed client records, and failed to cooperate with the investigation.