Grain trader forfeits $5.2m after NCA traces payments to sanctioned firms

What happened

ENEX Premium Trading Limited has agreed to forfeit more than $5.2 million (£3.84 million) to settle a civil recovery investigation into suspected money laundering and sanctions evasion. The National Crime Agency (NCA) announced the outcome on 27 August 2026. The company is owned by Nadir Valiyev, an Azerbaijan national, and is registered in St Kitts and Nevis.

This is a civil settlement, not a conviction. Valiyev denied criminal activity and agreed to forfeit the funds. The NCA states that the settlement does not constitute an admission of unlawful conduct or evidence of criminal activity.

ENEX describes itself as an independent agricultural trading and logistics company handling, transporting and financing grains and oilseeds. Reports in 2024 alleged that Valiyev’s companies had been involved in the shipment of stolen Ukrainian grain. The funds at issue moved between July and September 2024, and the NCA obtained an Account Freezing Order in November 2024.

According to the NCA, payments entered UK accounts through electronic money institutions (EMIs, firms authorised to issue e-money and hold payment accounts). The agency identified a network of suspected front companies and bank accounts used to route transactions through UK EMIs to be converted into cryptocurrency. The frozen UK funds were traced to Chinese bank accounts held by ENEX, which had received money from suspected front companies and held tens of millions of pounds. The companies that paid into those Chinese accounts have since been designated under US sanctions for facilitating illicit Iranian oil sales and revenue, and sending funds to the Iranian QODS Force.

The Head of the NCA’s Combatting Kleptocracy Cell said officers “worked diligently to track the source of these funds, uncovering evidence that payments made into ENEX’s accounts had been made by US sanctioned companies.”

Why it matters

The headline number is the least interesting part. Read as analysis, the payment route is the lesson: an offshore-registered commodity trader, funded through UK e-money rails, with value converted into cryptocurrency and settled into a third country. At the moment the money moved, that looks like ordinary agricultural trade finance.

The timing point is the one worth sitting with. The NCA says the paying companies were designated by the US afterwards. A list screen run in the summer of 2024 would very likely have returned nothing. That suggests the control that mattered was not name screening. It was the ability to see that a grain trader’s counterparty pattern, corridor, and settlement method did not match its stated business.

The EMI leg suggests where routing risk now sits. The NCA’s description points to payment institutions being chosen deliberately as the entry point.

Practitioner angle

• Re-run screening on the payer side, not just the customer side. Where a corporate customer receives large inbound payments, retain and periodically re-screen the originating entity names, so a later designation triggers a lookback rather than nothing.
• Build a retrospective list-change process with a defined window. When a counterparty is designated, ask what it paid you in the preceding 12 to 24 months and whether those payments were reviewed at the time.
• Flag the commodity-trade shape specifically: offshore incorporation, e-money entry, fiat to crypto conversion, and settlement into accounts in a country unrelated to the physical trade route. Any two of those together in a trade finance or commodity relationship justify enhanced due diligence.
• For EMIs and payment firms, test whether monitoring reads counterparty concentration and onward crypto conversion as one connected pattern, not two separate alerts.
• Check whether your team can evidence source of funds for a commodity trader beyond the invoice. Paperwork the customer supplied is documentation, not verification.

The single most important action: identify your customers whose counterparties were designated after onboarding, and review what moved before the designation date.