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Developments · monthly edition

October 2026

Verified changes in financial crime, sanctions and regulation across the EU, the UK and Switzerland. Every entry links to its primary source.

56 entries · 6 stories moved · 28 issuing bodies · open edition, as at 27 October 2026

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23Oct
EUenforcementAML & financial crimeNew

Two convicted in Düsseldorf as members of a criminal organisation in the €200 million 'Goliath' VAT fraud, laundered through a Hawala network, the EPPO reports

On 23 October 2026 the Düsseldorf Regional Court sentenced two members of a criminal organisation behind the €200 million 'Goliath' VAT fraud, the EPPO reports.

23Oct
UKenforcementAML & financial crimeNew

FCA places anti-money laundering restrictions on six Annex 1 lenders and reviews 900 registered Annex 1 firms

On 23 October 2026 the FCA announced voluntary restrictions on six Annex 1 lenders after raising concerns about their anti-money laundering controls.

23Oct
UKguidanceAML & financial crime

FCA consults on updates to its Financial Crime Guide across fraud, cryptoassets, sanctions and proliferation financing

The FCA is consulting until 24 December 2026 on updates to its Financial Crime Guide, in CP26/38 of 23 October 2026.

22Oct
EUenforcementAML & financial crimeNew

EPPO searches in Slovakia in the 'Pantastic' probe into a €234 million customs and VAT fraud allegedly helped by bribed officials

On 20 and 21 October 2026 the EPPO in Bratislava had searches carried out in Slovakia in its 'Pantastic' probe into an alleged €234 million customs and VAT fraud helped by bribed officials.

21Oct
EUguidanceCrypto & MiCA

ESMA publishes reporting instructions for MiDAS, the central system that collects CASPs' MiCA record-keeping data for market-abuse surveillance

On 21 October 2026 ESMA published reporting instructions for MIDAS, the central system that collects CASPs' MiCA record-keeping data for market-abuse surveillance, and opened CASP onboarding.

21Oct
EUSwitzerlandsanctionsSanctionsRemoved

EU removes a Swiss-registered entity from its Iraq asset-freeze list, following the UN, Switzerland and the UK

By Implementing Regulation (EU) 2026/2388 of 21 October 2026, the European Commission deleted one entry from Annex IV to Council Regulation (EC) No 1210/2003, the EU's Iraq asset freeze.

21Oct
EUUSsanctionsSanctions

OFAC, 21 October 2026: Iran shadow-fleet designations with Greek addresses, and the Lukoil International licence extended to 21 November

On 21 October 2026 OFAC designated a law firm with addresses in Panama City and Piraeus, Greece, five linked individuals and a Piraeus shipping company with its vessels, under the Iran programme (E.O.

19Oct
UKcase lawCivil fraud & litigation

High Court holds London black-cab drivers' conspiracy claims against Uber time-barred: the alleged fraud was discoverable before June 2018

On 19 October 2026 the High Court held that London black-cab drivers' conspiracy claims against Uber are time-barred, in Garry White & Ors v Uber London Ltd & Ors CITATION.

19Oct
EUUSsanctionsSanctions

OFAC, 13–19 October 2026: six notices, including a Bank of America settlement and a licence for Bulgarian Lukoil entities extended to April 2027

On 15 October 2026 OFAC issued General License 130B, authorising transactions with four Bulgarian Lukoil entities, and entities they own 50% or more, until 12:01 a.m.

16Oct
UKenforcementAML & financial crimeRemoved

FCA revokes the bans on four individuals whose LIBOR/EURIBOR convictions were quashed; the Court of Appeal's 7 October judgment is published

On 16 October 2026 the FCA revoked its bans on four individuals whose LIBOR and EURIBOR convictions the Court of Appeal had quashed.

16Oct
UKcase lawCivil fraud & litigation

A judgment cannot be set aside for fraud under the 'fraud of a party' rule where the alleged fraud was a stranger's, not the judgment creditor's

A judgment cannot be set aside under the 'fraud of a party' rule for a stranger's fraud, the High Court held on 16 October 2026.

14Oct
Switzerlandcountry riskSupervision & standards

Switzerland's third national ML/TF risk assessment: exposure stable; high residual risk for wealth-management and crypto banks, fintechs, VASPs, trustees, money transmitters, lawyers and fiduciaries, and real estate

Switzerland's third national money-laundering and terrorist-financing risk assessment (NRA 26) finds risk exposure stable, the Federal Council was told on 14 October 2026.

14Oct
SwitzerlandsanctionsSanctionsUpdated

Switzerland amends its list of Venezuelan politically exposed persons whose assets are frozen, in force 16 October 2026

From 16 October 2026 Switzerland's list of Venezuelan politically exposed persons whose assets are frozen is amended.

14Oct
EUregulatoryCrypto & MiCA

EBA classifies USDC as the first significant e-money token under MiCA; dual EBA–ACPR supervision from 12 November 2026

On 14 October 2026 the EBA classified USDC, issued in the EU by Circle Internet Financial Europe SAS, as the first significant e-money token under MiCA.

14Oct
UKguidanceAML & financial crime

FCA Market Watch 86: 'material weaknesses' in market abuse surveillance at seven retail brokers

The FCA found 'material weaknesses' in market abuse surveillance at seven UK retail brokers, it reports in Market Watch 86 of 14 October 2026.

13Oct
EUsanctionsSanctionsRemoved

EU deletes two Belarus entries, and renews the Guinea regime to 27 October 2027 while removing two individuals

On 13 October 2026 the Council deleted two Belarus entries and renewed the Guinea regime to 27 October 2027, removing two individuals.

13Oct
UKguidanceInternal investigationsUpdated

SFO updates its Corporate Cooperation Guidance: a company's lawyers may discuss a possible self-report with its Director of Legal Services first

From 13 October 2026 a company's lawyers may discuss a possible self-report directly with the SFO's Director of Legal Services and General Counsel, through a dedicated email address, before submitting it.

12Oct
EUsanctionsSanctionsUpdated

EU extends the chemical-weapons sanctions framework to 30 October 2031 and its listings to 30 October 2027

On 12 October 2026 the Council extended the EU's chemical-weapons sanctions framework to 30 October 2031 and its listings to 30 October 2027.

12Oct
EUsanctionsSanctionsNew

EU lists three persons and four entities under its DPRK regime, citing DPRK–Russia cooperation and UN sanctions evasion

On 12 October 2026 the EU listed three persons and four entities under its DPRK regime, citing DPRK–Russia cooperation and UN sanctions evasion.

12Oct
UKcase lawCivil fraud & litigationCrypto & MiCA

High Court rules that Chinese law governs fraud victims' proprietary claims to the Bitcoin held in POCA civil recovery (DPP v Qian)

On 12 October 2026 the High Court held that Chinese law governs fraud victims' proprietary claims to Bitcoin held in the DPP's civil recovery proceedings, in Director of Public Prosecutions v Zhimin Qian & Anor CITATION.

12Oct
UKenforcementAML & financial crimeNew

Guilty pleas to fraud, forgery and money laundering at two Nexus advice firms, in an FCA prosecution; four clients lost £2m

On 12 October 2026, in an FCA prosecution, the director and the business operations manager of two Nexus advice firms pleaded guilty at Portsmouth Crown Court to fraud and forgery.

12Oct
UKsanctionsSanctionsUpdated

UK replaces its Global Human Rights sanctions regime with a wider Global Human Rights and International Humanitarian Law regime, in force 15 October 2026

From 15 October 2026 the UK's Global Human Rights sanctions regime is replaced by a wider Global Human Rights and International Humanitarian Law regime, under SI 2026/1071.

12Oct
UKsanctionsSanctionsNew

UK designates two individuals under the Iran regime for hostile activity; one Russia variation; new OFSI general licence for ground rent and service charges

On 12 October 2026 the UK designated two individuals under the Iran (Sanctions) Regulations 2023 for hostile activity by the Government of Iran, with an asset freeze, travel ban and director disqualification.

9Oct
EUsanctionsSanctionsUpdated

EU renews the Nicaragua and Niger regimes and removes the Libya high-seas inspection provisions

On 9 October 2026 the Council renewed the EU's Nicaragua and Niger regimes and removed its Libya high-seas inspection provisions, in five acts in force from 13 October 2026.

9Oct
EUsanctionsSanctionsUpdated

EU renews the Sudan sanctions regime to 10 October 2027 and amends three entries

On 9 October 2026 the Council renewed the EU's Sudan sanctions regime to 10 October 2027 and amended three entries.

9Oct
UKcase lawCivil fraud & litigation

Investor wins summary judgment in fraudulent misrepresentation against an investment manager; rescission for fraud removes the contractual liability cap

On 9 October 2026 an investor won summary judgment for fraudulent misrepresentation against an investment manager in Shaw v Coleman Capital LLP (in liquidation) & Ors CITATION.

9Oct
EUUKSwitzerlandUSsanctionsSanctions

OFAC, 2–9 October 2026: five notices, including the designation of the International Criminal Court and parties in France, the UK and Switzerland

On 9 October 2026 OFAC designated the International Criminal Court, at its seat in The Hague, under ICC-EO14203, and issued related general licences.

8Oct
SwitzerlandregulatoryAML & financial crime

FINMA adopts partially revised Circular 2016/7 "Video and online identification": e-ID accepted for onboarding, in force 1 November 2026

From 1 November 2026 Swiss financial intermediaries may use the e-ID to identify clients onboarded digitally, under FINMA's partially revised Circular 2016/7 "Video and online identification", adopted on 8 October 2026.

8Oct
EUguidanceCrypto & MiCA

ESMA: CASPs should stop providing services in stablecoins that do not comply with MiCA; legacy exposures to be remediated within three months

ESMA's Opinion of 8 October 2026 states that CASPs should stop providing services in stablecoins that do not comply with MiCA.

7Oct
EUregulatoryAML & financial crime

AMLA consults on draft RTS establishing the central AML/CFT database — public hearing 3 November 2026

AMLA opened a consultation on 7 October 2026 on draft Regulatory Technical Standards under Article 11(6) of Regulation (EU) 2024/1620 (AMLAR) establishing a central AML/CFT database.

7Oct
EUenforcementAML & financial crimeNew

EPPO reports 62 detentions and over 300 searches in eight countries in the 'Hermes' VAT carousel investigation

On 7 October 2026 the EPPO carried out over 300 searches in eight countries and detained 62 suspects in its 'Hermes' investigation into a carousel VAT fraud in mobile phones and electronics.

7Oct
EUenforcementAML & financial crimeNew

EPPO indicts four in Czechia in the 'Záblesk' electronics VAT fraud, with plea bargains proposed for four more

On 7 October 2026 the EPPO's Ostrava office indicted four individuals for serious tax fraud in its 'Záblesk' electronics VAT investigation, and proposed plea bargains for four more to Prague's Municipal Court.

7Oct
EUregulatoryCrypto & MiCA

ESMA refreshes the Interim MiCA Register: 370 CASP records; non-compliant entities unchanged at 173

ESMA's MiCA page states that the Interim MiCA Register was last updated on 7 October 2026; the CASP file carries a server timestamp of 7 October 2026 13:00 GMT and the non-compliant-entity file 13:04 GMT.

7Oct
UKSwitzerlandUNsanctionsSanctionsRemoved

One Swiss-registered entity removed from the UN Iraq sanctions list; Switzerland and the UK implement the delisting

A Swiss-registered entity listed under the UN Iraq sanctions regime since 26 April 2004 (IQe.200) has been delisted, and Switzerland and the UK have implemented the removal.

6Oct
EUguidanceCrypto & MiCA

ESMA Q&A: a CASP may hold client funds briefly with a payment or e-money institution, but must move them to a bank or central bank account in its own name by the next business day

A CASP may hold client funds briefly with a payment or e-money institution, but must move them to a bank or central bank by the end of the next business day, ESMA states.

6Oct
UKsanctionsSanctionsRemoved

UK revokes one Syria designation; OFSI amends and extends the Maritime Mutual wind-down licence

On 6 October 2026 the UK revoked one designation under the Syria (Sanctions) (EU Exit) Regulations 2019, of an individual it designated on 31 December 2020.

2Oct
SwitzerlandregulatoryAML & financial crime

Federal Council consults on approving the Third Additional Protocol to the European Convention on Mutual Assistance in Criminal Matters — closes 19 January 2027

The Federal Council is consulting until 19 January 2027 on approving the Third Additional Protocol to the European Convention on Mutual Assistance in Criminal Matters (SR 0·351·1).

2Oct
LIregulatoryAML & financial crimePrivacy & data

Liechtenstein reopens its beneficial-ownership register in restricted form from 5 October — deadlines remain suspended

Liechtenstein's beneficial-ownership register (VwbP), closed to external users since the cyberattack of 30 July 2026, reopens in restricted form from Monday 5 October 2026, the Government states.

1Oct
EUregulatoryAML & financial crime

AMLA submits final draft RTS on customer due diligence, CDD thresholds, group-wide requirements and home–host cooperation to the Commission

On 1 October 2026 AMLA sent the European Commission final draft Regulatory Technical Standards on customer due diligence, CDD thresholds and group-wide requirements under the AMLR (Regulation (EU) 2024/1624).

1Oct
EUUKSwitzerlandUSsanctionsSanctionsNewRemovedNew

OFAC, 8 September–1 October 2026: 14 notices; designations of a UK-incorporated and a German-registered company and a de-listing of a Swiss national

Between 8 September and 1 October 2026 OFAC issued 14 notices; three touch EU, UK or Swiss parties.