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Developments · monthly edition

September 2026

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

55 entries · 7 stories moved · 27 issuing bodies

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30Sep
UKenforcementAML & financial crimeNew

FCA fines Robin Crispin William Odey £1.53m and bans him from regulated activity after the Upper Tribunal upholds all five integrity findings

By a Final Notice of 30 September 2026, the FCA fined Robin Crispin William Odey £1,529,374 and banned him from any function in regulated activity.

30Sep
UKsanctionsSanctions

OFSI opens the 2026 annual frozen asset review: values as at 30 September, returns due by 30 November 2026

OFSI's 2026 annual frozen asset review is open: holders of designated persons' funds or economic resources must report them, valued at close of business on 30 September 2026, by Monday 30 November 2026.

29Sep
SwitzerlandenforcementAML & financial crimeSupervision & standardsNew

FINMA concludes its fifth enforcement proceeding against Julius Bär — CHF 250m capital add-on, about CHF 10m confiscated (not yet final)

On 29 September 2026 FINMA concluded its fifth enforcement proceeding against Julius Bär in under ten years, finding serious breaches of risk-management and anti-money-laundering rules.

29Sep
EUSwitzerlandenforcementAML & financial crimeNew

EPPO reports searches in 19 countries, Switzerland among them, in the 'Troja' investigation into used phones sold as new under the VAT margin scheme

On 29 September 2026 the EPPO reported searches in 19 countries, including Switzerland, against a criminal organisation suspected of selling over one million used mobile phones as new.

28Sep
EUsanctionsSanctionsUpdatedNew

EU implements earlier UN committee decisions on the Taliban (1988) and DRC (1533) lists

In September 2026 the EU implemented earlier UN committee decisions on the Taliban (1988) and DRC (1533) lists.

28Sep
UKenforcementAML & financial crimeStage moved

FCA obtains confiscation orders against two people convicted over a GBP 1.5m crypto investment fraud

On 28 September 2026, at Southwark Crown Court, the FCA obtained confiscation orders against Raymondip Bedi (GBP 603,404·28) and Patrick Mavanga (GBP 247,997·99) under the Proceeds of Crime Act 2002.

28Sep
UKcase lawCivil fraud & litigationCrypto & MiCA

Court of Appeal sets aside a crypto-fraud judgment that made a non-party exchange user 'the unwitting insurer' of the victim's loss

In Jones v Persons Unknown CITATION, the Court of Appeal set aside a crypto-fraud judgment that had ordered Huobi Global Ltd to transfer 98·2 BTC from a named wallet to a fraud victim.

28Sep
UKSwitzerlandUNsanctionsSanctionsUpdated

The 1267 Committee amends one ISIL (Da’esh) and Al-Qaida entity entry (QDe.168); the UK and Switzerland follow within a day

On 28 September 2026 the UN 1267 (1999), 1989 (2011) and 2253 (2015) Committee amended one entity entry on its ISIL (Da'esh) and Al-Qaida Sanctions List, QDe.168 (listed 7 March 2022), by press release SC/16465.

25Sep
SwitzerlandsanctionsSanctionsUpdated

Switzerland amends its four UN-based TF/PF sanctions ordinances: new reporting duty and annual 15 February return from 1 November 2026

From 1 November 2026 Switzerland's Taliban, ISIL (Da'esh)/Al-Qaida, DPRK and Iran sanctions ordinances carry a new reporting duty and an annual return due by 15 February.

25Sep
EUregulatorySupervision & standards

EBA consults on revised ITS for joint decisions on institution-specific prudential requirements

On 25 September 2026 the EBA opened a consultation on revised Implementing Technical Standards for joint decisions on institution-specific prudential requirements under Article 113 CRD.

23Sep
SwitzerlandregulatorySupervision & standards

Council of States adopts Banking Act change requiring 90% CET1 backing of systemically important banks' foreign participations

On 23 September 2026 the Council of States voted 33 to 10, with two abstentions, to require systemically important banks to back foreign participations 90% with CET1 capital.

23Sep
Internationalcountry riskSupervision & standards

FATF publishes mutual evaluations of Türkiye and Canada

The FATF published mutual evaluations of Türkiye on 23 September 2026 and, with the Asia/Pacific Group on Money Laundering, of Canada on 29 September 2026.

23Sep
UKguidanceAML & financial crimeCivil fraud & litigation

FCA money-mules review: 238,396 suspected mules offboarded in 2025, with cash-out concentrated between the second and fifth account

The FCA's multi-firm review of 23 September 2026 found that firms offboarded 238,396 suspected money mules in 2025, up from 184,935 in 2023 and 233,269 in 2024.

23Sep
UKsanctionsSanctionsEscalated

OFSI applies a presumption of denial to licence applications by five designated Iranian banks; GL INT/2025/7628424 will lapse on 22 October 2026

From 23 September 2026 OFSI applies a presumption of denial to licence applications by five designated Iranian banks operating in the UK, HM Treasury's licensing guidance states.

22Sep
UKcase lawCivil fraud & litigation

No service-out gateway for a free-standing freezing order in aid of enforcing an English judgment

In Gilbert v Broadoak Private Finance Ltd CITATION, the Court of Appeal held there is no gateway to serve out of the jurisdiction a free-standing freezing order in aid of enforcing an English judgment.

21Sep
UKenforcementAML & financial crime

FCA begins High Court proceedings against loan-note seller Hunter Jones over alleged unauthorised regulated activity

On 21 September 2026 the FCA began High Court proceedings against Osborne Baldwin Limited, trading as Hunter Jones and Hunter Jones Group, which sells loan notes.

21Sep
UKsanctionsSanctionsNewRemoved

UK Sanctions List, 7–21 September 2026: six new designations, variations under four regimes and one Russia revocation

Between 7 and 21 September 2026 the UK made six new designations, variations under four regimes and one Russia revocation, the FCDO's change history records.

18Sep
SwitzerlandsanctionsSanctionsEscalated

Switzerland amends its Belarus ordinance: digital Belarusian rouble transaction ban, new claims-enforcement annex and wider loan prohibition (AS 2026 480)

The amendment of 18 September 2026 to the Ordinance on measures against Belarus (AS 2026 480; in force 19 September 2026, with art.

18Sep
EUguidanceSupervision & standards

EBA publishes final Guidelines on third-party risk management (EBA/GL/2026/09), replacing the 2019 outsourcing Guidelines

On 18 September 2026 the EBA published final Guidelines on third-party risk management (EBA/GL/2026/09), replacing its 2019 outsourcing Guidelines.

16Sep
Switzerlandcase lawEmployment

Federal Supreme Court upholds the 2023 order cutting Credit Suisse managers' unpaid variable pay, reversing the Federal Administrative Court

On 16 September 2026 the Federal Supreme Court upheld the Federal Department of Finance's 2023 order cutting Credit Suisse managers' accrued but unpaid variable pay, reversing the Federal Administrative Court.

16Sep
UKenforcementAML & financial crime

FCA opens an investigation into possible Money Laundering Regulations offences at Euro Exchange Securities UK Ltd

On 16 September 2026 the FCA announced an investigation into possible Money Laundering Regulations 2017 offences by Euro Exchange Securities UK Ltd (EES) between 1 February 2020 and 4 June 2026.

16Sep
UKenforcementAML & financial crimeNew

FCA fines and bans Vector Wealth's former chief executive, Jeffrey Dawkins, and fines and restricts its former sales manager, Kadir Kanizi

The FCA has fined and banned Vector Wealth's former chief executive, Jeffrey St Patrick Dawkins, and fined and restricted its former senior sales manager, Kadir Yusuf Kanizi.

15Sep
UKenforcementAML & financial crimeNew

FCA prohibits a former law-firm manager after SRA findings of dishonest misuse of over GBP 28m of client money

By a Final Notice dated 15 September 2026, the FCA prohibited Nurul Miah and withdrew his approval to perform the SMF3 function at Oracle Consultants Ltd (in liquidation).

11Sep
EUenforcementAML & financial crimeStage moved

EPPO reports six convictions in Milan, including for money laundering, in the 'Moby Dick' VAT carousel funded by a Camorra clan

On 11 September 2026 the Court of Milan convicted six individuals, including one ringleader, of a transnational criminal association, VAT fraud and money laundering in the EPPO's 'Moby Dick' case, announced on 17 September.

11Sep
UKcase lawInternal investigationsCivil fraud & litigation

D&O insurers must keep advancing defence costs to former Petrofac officers facing Bribery Act charges

In Liberty Managing Agency Ltd v Chedid CITATION, Jacobs J held that D&O insurers must keep advancing defence costs to two former Petrofac officers facing Bribery Act charges.

10Sep
UKregulatoryPrivacy & dataUpdated

The Information Commissioner is abolished and its functions pass to the Information Commission from 30 September 2026

On 30 September 2026 the office of Information Commissioner was abolished and its functions passed to the Information Commission.

10Sep
UKenforcementAML & financial crimeStage moved

Guilty pleas to fraud and forgery over a fake takeover approach, in an FCA prosecution

On 10 September 2026, in an FCA prosecution, Christopher Woolcott pleaded guilty at Westminster Magistrates' Court to one count of fraud by false representation and three counts of making a false instrument.

9Sep
SwitzerlandsanctionsSanctionsEscalated

Switzerland bans Sudanese-origin gold and gold-mining goods for Sudan (AS 2026 462)

Since 10 September 2026 Switzerland has banned the purchase, import, transit and transport of Sudanese-origin gold exported from Sudan after 9 September 2026, and related services, including financial services.

7Sep
UKSwitzerlandUNsanctionsSanctionsUpdated

SC/16446 follow-through: QDi.431's amendment reaches the UN file; the UK and Switzerland implement only QDi.436

The UN 1267 Committee's 4 September 2026 amendment to entry QDi.431 has now reached the machine-readable UN Consolidated List, in the file generated 2026-10-01T23:00Z.

7Sep
UKregulatoryAML & financial crimeSupervision & standards

Government gives a timetable for FCA AML supervision of professional services: first firms before end-2028, all in-scope firms by mid-2030

The Government expects the FCA to begin supervising the first legal, accountancy and trust or company service businesses before the end of 2028, and all in-scope firms by mid-2030.

7Sep
UKsanctionsSanctionsEscalated

UK widens Iran sanctions: SI 2026/983 in force 29 September 2026

Since 29 September 2026 the UK's Iran sanctions have been wider, under the Iran (Sanctions) (Amendment) Regulations 2026 (SI 2026/983), made on 7 September and laid on 8 September.

4Sep
EUenforcementAML & financial crime

EPPO signs a working arrangement with China's Supreme People's Procuratorate

On 4 September 2026 European Chief Prosecutor Laura Kövesi and Chief Grand Prosecutor Ying Yong of China's Supreme People’s Procuratorate signed a working arrangement on judicial cooperation, with a 2026 to 2028 action plan.

4Sep
UKcase lawCivil fraud & litigationProfessional negligence

Liquidators' Quincecare and dishonest-assistance claims against a bank over an alleged Ponzi scheme survive strike-out

In Denaro (UK) Ltd (in liquidation) v Bracken CITATION, the court refused Barclays Bank UK PLC's application to strike out the liquidators' claims against it.

4Sep
UNsanctionsSanctionsUpdated

The 1267 Committee amends two entries on the ISIL (Da’esh) and Al-Qaida Sanctions List; the machine-readable list reflects only one of them

On 4 September 2026 the UN 1267 (1999), 1989 (2011) and 2253 (2015) Committee amended two entries on its ISIL (Da’esh) and Al-Qaida Sanctions List, QDi.431 and QDi.436 (press release SC/16446).

4Sep
SwitzerlandUSsanctionsSanctionsRemoved

OFAC records three sanctions actions between 2 and 4 September 2026, one of which removes a Swiss-registered company from the SDN List

On 3 September 2026 OFAC removed a Swiss-registered company from the SDN List, one of three actions between 2 and 4 September.

3Sep
UKenforcementProfessional negligenceNew

FCA publishes a Decision Notice proposing to prohibit and fine an adviser over defined benefit pension transfer advice; the notice is referred to the Upper Tribunal

On 3 September 2026 the FCA published a Decision Notice to prohibit Daniel Philip Thomas and fine him GBP 742,700 over defined benefit pension transfer advice.

3Sep
UKenforcementCivil fraud & litigationStage moved

SFO reports three directors sentenced for fraudulent trading in the Ethical Forestry investment scheme

On 3 September 2026 the SFO announced that three directors of Ethical Forestry Limited were sentenced at Southwark Crown Court for fraudulent trading, after guilty pleas in January 2026.

2Sep
EUenforcementAML & financial crimeStage moved

EPPO reports five convictions in Paris over EUR 275 800 of ERDF money for a waste-treatment project

On 2 September 2026 the EPPO announced that the Paris Criminal Court convicted three French companies and their two executives of fraud involving EUR 275,800 of European Regional Development Fund money.

2Sep
UKregulatoryAML & financial crimeCivil fraud & litigation

Crime and Policing Act 2026 SIM-farm offences commence on 29 October 2026 under Commencement No. 3

The Crime and Policing Act 2026's SIM-farm offences come into force on 29 October 2026, under SI 2026/960, made by the Home Office on 2 September 2026.

2Sep
UKenforcementInternal investigationsCivil fraud & litigationStage moved

SFO announces that the ENRC litigation has concluded on confidential terms

On 2 September 2026 the SFO announced that ENRC, the SFO's Director, Dechert LLP and David Neil Gerrard had settled their long-running civil proceedings out of court, on confidential terms.