FinCrime Intelligence Weekly
Treasury sanctions VTB Bank over Iran ties, ex-Vitol trader Javier Aguilar gets four years for bribery, the UK launches a 500 million pound AML strategy, and CoinEx shuts down after nine years.
Marco’s Take
Marco Beranzoni
Five stories this week, but only three of them share a spine. VTB Bank built its own settlement rail in Iranian rials and Russian rubles to move money outside the US dollar system. Javier Aguilar routed bribes to state oil officials through a front company called Oman Trading International. CoinEx spent years shifting jurisdictions ahead of regulators before deciding to shut down entirely.
None of that is people misusing ordinary accounts. It is institutions and individuals with real resources building parallel infrastructure, a new settlement system, a shell counterparty, a jurisdiction switch, purpose built to sit outside the controls most of us screen against. That is harder to catch than a bad transaction, because the infrastructure looks legitimate right up until you ask who actually benefits from it.
The UK’s new Anti-Money Laundering (AML) strategy and a warning from the UK Financial Conduct Authority (FCA) to law firms are the mirror image: the state building its own infrastructure to close that same gap. My slightly uncomfortable ask this week: pull your correspondent banking file and check how many relationships clear in a currency pair that never touches the US dollar. If you cannot answer quickly, that is the gap.
Read the VTB typology below before you read the enforcement item. The mechanism matters more than any single name attached to it this week.
See you next Monday.
Marco
OFAC's September 14 designation targets VTB's correspondent ties to sanctioned Iranian banks, a Tehran office expansion, and a rial to ruble settlement system built to grow bilateral trade.
A Brooklyn federal court sentenced Javier Aguilar to four years after jurors convicted him of bribing officials at Pemex in Mexico and Petroecuador in Ecuador to win contracts worth over $500 million.
The Home Office plans 500 new officers across law enforcement and regulators, funded by the Economic Crime Levy, to pursue illicit finance.
The exchange says a prolonged crypto downturn and rising compliance costs forced a full wind down, with withdrawals open until December 22, 2026.
FCA enforcement chief Steve Smart told the Law Society conference that law firms will not be caught out when the regulator takes over AML supervision of 60,000 legal and accounting firms by the end of 2028.
What changed this week, why it matters, and what to do about it.
| Region | Update | Why it matters | Action |
|---|---|---|---|
| UK | The UK government launched its Anti-Money Laundering and Asset Recovery Strategy for 2026 to 2029 on September 15, 2026, committing £500 million over three years from the Economic Crime Levy and funding 500 new officers across the police, the National Crime Agency (NCA), the Crown Prosecution Service (CPS), the FCA, and the Serious Fraud Office (SFO). | The NCA estimates that over £100 billion is laundered through the UK or UK corporate structures every year, and this funding shows where examination and investigation capacity is heading over the next three years. | Map your UK exposure against the agencies gaining headcount and prepare for more information requests modeled on the recent Operation Destabilise activity. |
| UK | At the Law Society Economic Crime Conference on September 17, 2026, FCA Executive Director of Enforcement and Market Oversight Steve Smart said the FCA will target professional enablers once it takes over AML supervision of 60,000 legal and accounting entities at the end of 2028. | Firms that rely on solicitors, accountants, or formation agents as part of their customer due diligence chain will move from today's patchwork of sector supervisors to a single, better resourced regulator. | List which professional intermediaries you use that currently sit under a weaker sector supervisor and schedule them for enhanced review ahead of the 2028 transfer. |
| US | The US Office of Foreign Assets Control (OFAC) designated Russia's VTB Bank on September 14, 2026 under Executive Orders 13902, 13662, and 14024, citing correspondent relationships with sanctioned Iranian financial institutions and a bilateral rial to ruble settlement system built to trade outside the US dollar. | The designation is part of Operation Economic Outcast, launched August 24, 2026, and signals continued pressure on banks helping Russia and Iran trade around sanctions. | Screen correspondent and payment relationships for non-dollar currency pairs tied to Russian or Iranian counterparties, and expect further designations under the same operation. |
| US | Former Vitol energy trader Javier Aguilar was sentenced on September 18, 2026 to four years by Judge Eric Vitaliano in Brooklyn federal court, for paying over $1 million in bribes from 2015 to 2020 to Mexican and Ecuadorean state oil officials to win over $500 million in contracts. | The bribes moved partly through a front company, Oman Trading International, and co-conspirators forfeited a combined $63 million or more, showing how far an intermediary structure can hide a scheme. | Review due diligence files on trading agents and intermediary counterparties for the same pattern: unclear commercial function, opaque ownership, and payments tied to officials' associates. |
| Global | Crypto exchange CoinEx announced on September 15, 2026 that it will fully shut down by late 2026, citing market downturn, falling liquidity, and rising regulatory and compliance costs, with withdrawals open until December 22, 2026. | CoinEx previously exited New York under a 2023 settlement, left the European Economic Area under the EU's Markets in Crypto-Assets (MiCA) regulation in June 2026, and faced scrutiny over Iran-linked transaction flows earlier in 2026. | If your institution has counterparty or customer exposure to CoinEx, confirm withdrawal timelines now and watch for phishing that impersonates the wind-down communications. |
The UK government launched its Anti-Money Laundering and Asset Recovery Strategy for 2026 to 2029 on September 15, 2026, committing £500 million over three years from the Economic Crime Levy and funding 500 new officers across the police, the National Crime Agency (NCA), the Crown Prosecution Service (CPS), the FCA, and the Serious Fraud Office (SFO).
Why it matters:The NCA estimates that over £100 billion is laundered through the UK or UK corporate structures every year, and this funding shows where examination and investigation capacity is heading over the next three years.
Action:Map your UK exposure against the agencies gaining headcount and prepare for more information requests modeled on the recent Operation Destabilise activity.
At the Law Society Economic Crime Conference on September 17, 2026, FCA Executive Director of Enforcement and Market Oversight Steve Smart said the FCA will target professional enablers once it takes over AML supervision of 60,000 legal and accounting entities at the end of 2028.
Why it matters:Firms that rely on solicitors, accountants, or formation agents as part of their customer due diligence chain will move from today's patchwork of sector supervisors to a single, better resourced regulator.
Action:List which professional intermediaries you use that currently sit under a weaker sector supervisor and schedule them for enhanced review ahead of the 2028 transfer.
The US Office of Foreign Assets Control (OFAC) designated Russia's VTB Bank on September 14, 2026 under Executive Orders 13902, 13662, and 14024, citing correspondent relationships with sanctioned Iranian financial institutions and a bilateral rial to ruble settlement system built to trade outside the US dollar.
Why it matters:The designation is part of Operation Economic Outcast, launched August 24, 2026, and signals continued pressure on banks helping Russia and Iran trade around sanctions.
Action:Screen correspondent and payment relationships for non-dollar currency pairs tied to Russian or Iranian counterparties, and expect further designations under the same operation.
Former Vitol energy trader Javier Aguilar was sentenced on September 18, 2026 to four years by Judge Eric Vitaliano in Brooklyn federal court, for paying over $1 million in bribes from 2015 to 2020 to Mexican and Ecuadorean state oil officials to win over $500 million in contracts.
Why it matters:The bribes moved partly through a front company, Oman Trading International, and co-conspirators forfeited a combined $63 million or more, showing how far an intermediary structure can hide a scheme.
Action:Review due diligence files on trading agents and intermediary counterparties for the same pattern: unclear commercial function, opaque ownership, and payments tied to officials' associates.
Crypto exchange CoinEx announced on September 15, 2026 that it will fully shut down by late 2026, citing market downturn, falling liquidity, and rising regulatory and compliance costs, with withdrawals open until December 22, 2026.
Why it matters:CoinEx previously exited New York under a 2023 settlement, left the European Economic Area under the EU's Markets in Crypto-Assets (MiCA) regulation in June 2026, and faced scrutiny over Iran-linked transaction flows earlier in 2026.
Action:If your institution has counterparty or customer exposure to CoinEx, confirm withdrawal timelines now and watch for phishing that impersonates the wind-down communications.
Typology of the week
A sanctioned financial institution builds its own settlement infrastructure with a partner country to keep trade moving once US dollar clearing is closed off. It opens a physical banking presence in the partner jurisdiction and sets up correspondent accounts denominated in each country's own currency, routing bilateral trade through that pair instead of the dollar. Because the settlement never touches a US dollar correspondent, it can sit outside the screening most Western banks rely on.
Example
OFAC designated VTB Bank on September 14, 2026 under Executive Orders 13902, 13662, and 14024. Treasury said VTB established correspondent banking relationships with sanctioned Iranian financial institutions, opened bank offices in Iran with a growing presence since January 2025, moved billions in frozen Iranian assets, and built a bilateral settlement system using rial and ruble correspondent accounts to expand trade with Russia outside the US dollar system. Treasury Secretary Scott Bessent said Treasury would continue to identify, expose, and isolate Iran's enablers. The action is part of Operation Economic Outcast, launched August 24, 2026.
Recent actions and the control lessons behind them.
Vitol Inc.
Control failure:The bribes that won Vitol over $500 million in Pemex and Petroecuador contracts moved partly through a front company, Oman Trading International, for five years before the scheme surfaced. That points to a due diligence gap on the intermediary layer, not just on the direct counterparty, running from 2015 to 2020 without being caught internally.
Lesson:Screening a trading counterparty once at onboarding will not catch a front company used to route payments years into a relationship. Commodity trading firms need periodic reassessment of intermediary and agent structures, with particular attention to entities that add no clear commercial function beyond moving money toward a state official's network.
CoinEx will fully shut down by late 2026 and has left withdrawals open until December 22, 2026. Compliance and fraud teams with customers or counterparties on the exchange should communicate that deadline directly, confirm what CoinEx's own process is for claims on assets not withdrawn in time, and watch for phishing that impersonates the exchange's official wind-down communications.
VTB Bank's rial to ruble correspondent system was built specifically to settle trade outside the US dollar, where most Western sanctions screening is concentrated. Correspondent banks and payment processors should widen automated screening to cover non-dollar currency pairs involving Russian or Iranian counterparties, rather than treating US dollar clearing as the primary detection point.
Career & Skills Corner
When a national strategy document lands, like the UK's new Anti-Money Laundering and Asset Recovery Strategy for 2026 to 2029, skip straight to the money and the headcount. £500 million over three years and 500 new officers split across the police, the NCA, the CPS, the FCA, and the SFO tells you which agencies will have more capacity to open cases and ask harder questions over the next three years. Build that into your own planning: if the FCA is getting resourced up, your FCA-regulated relationships deserve a fresh look at file quality now, before the extra examiners arrive. Practitioners who read funding allocations as a forward map of supervisory attention, rather than as background news, get ahead of the requests instead of reacting to them.
I'm watching whether OFAC designates other banks building the same kind of non-dollar settlement infrastructure under Operation Economic Outcast, and how CoinEx's withdrawal window holds up as the December 22 deadline approaches.
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