OFAC’s $4.7m real estate penalty is a sanctions case study in plain sight
On 24 November 2025, the US Treasury’s Office of Foreign Assets Control (OFAC) imposed a $4,677,552 civil penalty on an individual for willfully dealing in blocked real property linked to a Russia sanctions designation, and for failing to comply with an OFAC subpoena. This is OFAC’s largest publicly announced penalty against an individual to […]
Millicom’s TIGO Guatemala resolution: $118m paid to close US foreign bribery investigation
Millicom International Cellular, the Luxembourg-incorporated telecoms group behind the Tigo brand in Latin America, has agreed a two-year deferred prosecution agreement (DPA) with the US Department of Justice (DOJ) to resolve a long-running foreign bribery investigation tied to its Guatemalan business. The matter was resolved through its Guatemalan subsidiary, Comunicaciones Celulares S.A. (doing business as […]
The shadow fleet that would not die: how OFAC finally caught up with the “Kunlun legacy” network
There is a temptation to treat the “shadow fleet” as something new. It is often discussed as a Russia-era phenomenon, but the same methods have long been associated with Iran and Venezuela too. In reality, it is often the same playbook, reused for years, with different company names, different flags, and a slightly different corporate […]
What to expect in corporate governance compliance in 2026: The trends shaping enforcement, liability and training
Corporate compliance in 2026 is defined less by new tick-box rules and more by a clear shift in regulatory intent. Across fraud, bribery, employment law, cyber security and financial services, the direction of travel is consistent: broader corporate liability, stronger personal accountability for senior leaders, and higher expectations of training, controls and internal reporting. […]
Beyond the Modern Slavery Act: inside the UK’s proposed new business and human rights law
The UK is on the verge of a major shift in how it tackles forced labour and human rights abuses in global value chains. Last month, the Independent Anti-Slavery Commissioner published a model legislative proposal aimed at strengthening the UK’s approach beyond the current Modern Slavery Act framework. The proposal follows growing political and […]
One in six Britons was asked to pay a bribe last year. Is your business at risk?
The UK is often assumed to have strong protections against bribery and corruption thanks to its strong legal framework. Yet this can mask a troubling reality: bribery and corruption persist in everyday life, not just within organisations but in routine interactions affecting millions of citizens. A recent report by the International Society of Economic Criminology […]
The UK’s 2025 anti-corruption plan has landed. What are the implications for businesses and the public sector?
The government has finally published the UK Anti-Corruption Strategy 2025, a five-year plan that sits alongside the Economic Crime Plan and the new Failure to Prevent Fraud offence. On paper it is ambitious. It talks about professional enablers, sets out plans for new enforcement tools and promises better protection for public money. At the […]
As the UK tightens corporate crime laws, culture could make or break firms
Recent years have seen seismic shifts in corporate criminal law, from the Bribery Act 2010 to the Economic Crime and Corporate Transparency Act 2023 (ECCTA), and now additional legislation on the table. In response, many firms are ramping up compliance programmes, policies, and risk-management frameworks. Under newly expanded liability provisions (e.g., via ECCTA and […]
HMRC’s new handbook sheds light on growing trade-based money laundering risks
Luxury goods that were actually phantom shipments, with no goods ever delivered. Agricultural imports that were falsely declared, concealing narcotics hidden within legitimate trade. These are just two examples of how criminals exploit global trade to launder illicit funds, making it difficult for businesses to identify and prevent illegal activity within their supply chains. For […]