This month’s top stories:
- US federal prosecutors indict Indian billionaire Gautam Adani for alleged involvement in USD 265 million bribery and fraud scheme;
- European Public Prosecutors’ Office uncovers criminal syndicate based in the Baltics and makes arrests in Estonia, Latvia, Lithuania, and Italy in connection with an investigation into a VAT fraud scheme that has caused loss of EUR 297 million; and
- UAE Central Bank suspends currency exchange for anti-money laundering and counter-terrorist violations after strengthening financial crime legislation.
Americas
US: Federal prosecutors indict Indian billionaire Gautam Adani for alleged involvement in USD 265 million bribery and fraud scheme
On 20 November, New York federal prosecutors unsealed a five-count indictment against Indian billionaire Gautam Adani, the chairperson of the multinational conglomerate Adani Group, as well as seven other business executives for their alleged involvement in a USD 265 million bribery scheme. Adani and the other defendants are charged with orchestrating a far-reaching scheme to bribe Indian government officials to secure billions of dollars’ worth of contracts. Adani and renewable energy executives Sagar Adani and Vneet Jaain are also accused of lying to US investors and global financial institutions about the alleged bribery scheme as they sought to raise USD 3 billion in loans and bonds. The US Securities and Exchange Commission is also suing Adani and Sagar Adani in relation to the alleged bribery scheme. The Adani Group has denied the charges.
Brazil: Former president Bolsonaro and allies indicted by federal police for 2022 alleged coup attempt
On 21 November, Brazilian federal police indicted former President Jair Bolsonaro and 36 other individuals, including dozens of Bolsonaro’s former and current aides, for an alleged coup attempt to keep him in office following his defeat in the 2022 election. This is the third indictment against Bolsonaro by federal police, following indictments for his alleged role in embezzling jewellery gifted to the Brazilian presidency and falsifying COVID-19 vaccination cards. Brazilian federal police can issue an indictment after their investigation finds indications of authorship of a crime. However, the Attorney General's Office is now responsible for ultimately determining whether there is sufficient evidence to bring a formal complaint against those accused, at which point a request could be issued for Bolsonaro’s arrest. The three indictments are still pending. Bolsonaro has denied the accusations.
Europe
Italy: 43 individuals arrested and EUR 520 million seized in VAT fraud investigation
On 14 November, the Guardia di Finanza, an Italian law enforcement agency specialised in fighting financial and tax crime, arrested 43 individuals and seized EUR 520 million in an investigation concerning an alleged VAT fraud scheme. The investigation, which was led by the European Public Prosecutors’ Office (EPPO), uncovered transactions between fake companies that disappeared before settling their tax debts. According to Italian authorities, the scheme was also used by members of Italian criminal organisations such as the Camorra and Cosa Nostra for money laundering purposes. EPPO’s investigation into the scheme led to arrest warrants being issued in several other countries, and over ten law enforcement agencies conducted search and seizure operations relating to this case. The scheme may have involved over 195 individuals and 400 companies, according to media reporting.
Croatia: Health minister arrested on charges of corruption, influence peddling, and money laundering
On 15 November, Vili Beroš, the Croatian minister of health (2020-2024), was arrested during an anti-corruption raid conducted by Croatia's Office for the Suppression of Corruption and Organised Crime (USKOK). Beroš and seven other individuals are accused of corruption, influence peddling, and money laundering relating to public contracts in the country’s state hospitals between 2022 and 2024. After the arrests, the EPPO requested to take over the case launched by USKOK, claiming that it had an ongoing investigation into the matter, which reportedly fell within its competence as part of the affected contracts involved EU funding. However, on 19 November, Ivan Turudić, Croatia’s State Attorney General, decided that the case should continue under USKOK’s oversight, and on 21 November, the EPPO handed over its investigation to Croatian authorities. Following the arrest, Croatia’s prime minister Andrej Plenković (2016-present) dismissed Beroš from his ministerial position. Beroš has denied wrongdoing.
UK: Sanctions imposed on foreign individuals accused of corruption, embezzlement, and money laundering abroad
On 21 November, the UK announced sanctions against three individuals who are accused of corruption, embezzlement, and money laundering in their home countries: Isabel dos Santos, daughter of Angola’s former president José Eduardo do Santos (1979-2017); Dmitry Firtash, a Ukrainian oligarch active in the oil and gas sector; and Aivars Lembergs, a Latvian businessperson and former politician. The restrictions include travel bans and assets freezes. Representatives of Isabel dos Santos and Dmitry Firtash have denied their involvement in any wrongdoing, and Aivars Lembergs has denied similar accusations in the past.
UK / France: Joint investigation announced into suspected bribery by defence contractor Thales
On 22 November, the UK’s Serious Fraud Office (SFO) and the French financial crime prosecutor, the Parquet National Financier (PNF), announced a joint investigation into suspected corruption by Thales SA, a French manufacturer of electronic systems used in sectors including defence and aerospace. Four Thales entities in the UK and France are reportedly suspected of bribing foreign officials in connection with a defence contract in Asia. Thales has denied all allegations and confirmed that it is cooperating with both the SFO and the PNF.
Estonia / Latvia / Lithuania: EU prosecutor’s office uncovers criminal syndicate and arrests 32 individuals in connection with large cross-border VAT fraud
On 28 November, the EPPO announced that it had uncovered a criminal syndicate based in the Baltics and detained 32 individuals in Estonia, Latvia, and Lithuania in connection with a large cross-border VAT fraud. The EPPO suspects that the Baltics-based criminal syndicate carried out a VAT carousel fraud that caused a loss of VAT totalling EUR 297 million. The fraud allegedly spanned 15 EU member states and involved over 400 companies. In addition to the VAT fraud, EU investigators suspect that the scheme was used to launder the proceeds of drug trafficking, cybercrime, and investment fraud and may have had links to Russian organised crime. The alleged criminal syndicate and VAT fraud scheme were uncovered in the course of a wider EPPO investigation into VAT fraud in the EU.
Middle East and North Africa
UAE: Central Bank suspends currency exchange for anti-money laundering and counter-terrorist violations
On 22 November, the UAE’s Central Bank announced its decision to suspend Al Razouki Exchange, an international currency exchange operating in the UAE, for three years for violating anti-money laundering (AML) and counter-terrorist financing (CTF) laws. The Central Bank additionally closed two of Al Razouki Exchange’s branches in Deira and Al Murar, two areas in Dubai. Al Razouki Exchange has not responded publicly to the suspension. The Central Bank’s decision comes against the backdrop of the UAE’s strengthening of AML and CTF rules and regulations enacted in the months following the country’s removal from the Financial Action Task Force grey list in February this year.
Former Soviet Union
Russia: Journalistic investigation uncovers indications of sanctions circumvention through entities registered in British Overseas Territories
On 19 November, the Financial Times published an investigation which found that, in 2024, companies registered in the British Overseas Territories (BOTs) exported USD 134 million worth of controlled goods to Russia, thereby potentially violating UK sanctions against Russia that also apply in the BOTs. The Financial Times found that a large volume of sanctioned exports to Russia are organised through entities overwhelmingly registered in the British Virgin Islands (BVI), where low corporate disclosure and a lack of open ownership records make it difficult to identify other parties involved in the trade. The investigation found that one BVI entity alone was responsible for shipping USD 119 million worth of goods subject to UK export controls: this entity was listed in Russian documents as the exporter of the goods, despite them being physically shipped directly from China to Russia. UK MPs have called on UK Foreign Secretary David Lammy to ensure the establishment of public registers of beneficial ownership in the BOTs.
Russia: US imposes blocking sanctions on Gazprombank and six of its foreign subsidiaries
On 21 November, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) imposed sanctions on PAO Gazprombank, one of the last large Russia-headquartered banks not already sanctioned following Russia’s full-scale invasion of Ukraine. Gazprombank has been used as a conduit for defence-related payments by the Russian government and for foreign payments for Russian gas. Six of its foreign subsidiaries in Luxembourg, Hong Kong, Cyprus, Switzerland, and South Africa were also designated. The blocking sanctions prevent Gazprombank and its subsidiaries from accessing the international financial system.
Russia / Cyprus: Cypriot government revokes citizenship of 77 investors, including sanctioned Russian business figures
On 24 November, Cypriot authorities published the names of 77 naturalised citizens whose citizenship they had revoked, following a decision by the country's Council of Ministers. All 77 citizens had acquired Cypriot nationality through the Cyprus Investment Programme, which closed in November 2020 following widespread criticism from local and international media on integrity grounds. Those stripped of their Cypriot citizenship include Russian billionaire Oleg Deripaska, who has been subject to US sanctions since 2018 and UK and EU sanctions since 2022; and Ukrainian-born Israeli businessman Ihor Kolomoyskiy, who is currently facing charges of embezzlement and money laundering in Ukraine. He has denied the charges. This round of revocations follows earlier legal rulings that stripped citizenship from over 200 Cypriots who were naturalised through the now-defunct citizenship by investment programme due to false declarations made during the application process. These events highlight the need for robust and independent due diligence during the investor onboarding stage.
Russia: UK sanctions 30 ships in shadow fleet and two insurance companies
On 25 November, the UK government sanctioned a further 30 ships belonging to Russia’s so-called shadow fleet of oil tankers, bringing the total number to 73. Two Russian insurance companies, VSK and AlfaStrakhovanie, were also sanctioned for enabling the shadow fleet. Data from the UK Foreign, Commonwealth and Development Office suggests that half of the ships included in this sanctions package transported over USD 4.3 billion worth of oil and oil products, including gasoline, in the past year alone.
