The US extends sanctions waiver to Russia’s Lukoil, Millicom subsidiary settles FCPA violations, and a UK survey reveals widespread gaps in sanctions awareness – plus other key updates.
Lexology PRO explores some of the most useful articles published on Lexology and externally across key areas anti-money laundering and counter-terrorist financing (AML/CTF), sanctions, fraud, and anti-bribery and corruption compliance to help businesses stay abreast of key issues.
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Anti-money laundering
On 17 November 2025, the US Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking designating 10 Mexico-based gambling companies as a primary money laundering concern. The rule would bar financial institutions (FIs) from opening or maintaining correspondent accounts that process transactions involving any of these companies and would require them to apply special due diligence to correspondent accounts to prevent such misuse. Written comments are due by 17 December 2025.
On 7 November 2025, the Hong Kong Customs and Excise Department fined an unnamed money service operator HK$328,000 (US$42,158) for AML violations uncovered during a 2022 inspection. These include failing to conduct proper customer due diligence, maintain records, and providing false or misleading documents.
On 6 November 2025, Germany’s Federal Financial Supervisory Authority (BaFin) levied a €45 million (US$52 million) fine against a Frankfurt-based JP Morgan subsidiary for AML deficiencies. According to BaFin, the bank failed to file suspicious activity reports in a timely manner between October 2021 and September 2022.
On 6 November 2025, the Central Bank of Ireland fined Coinbase €21.4 million (US$24.7 million) for AML/CTF breaches under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010. Between April 2021 and March 2025, the company allegedly failed to monitor transactions adequately and neglected to report suspicious activity to Ireland’s Financial Intelligence Unit and the Revenue Commissioners.
On 5 November 2025, the UK Gambling Commission imposed a £650,000 (US$848,000) fine on NetBet and required the operator to undergo an independent audit following findings of AML and social responsibility failures. According to the regulator, NetBet relied excessively on financial triggers, failed to assess risks linked to high-risk gambling and third-party relationships, among other compliance failures.
Sanctions
After sanctioning Lukoil on 22 September 2025, the US extended a sanctions waiver for the Russian oil company on 14 November 2025, allowing it to continue operating many of its businesses until 13 December 2025. The extension follows reports that US private equity fund Carlyle is considering acquiring Lukoil’s international assets, after a previously planned sale to Swiss commodities trader Gunvor fell through.
On 13 November 2025, Mexico’s Financial Intelligence Unit (UIF), acting in coordination with the US Office of Foreign Assets Control and FinCEN, blocked financial operations and suspended the activities of 31 entities linked to the Pacific Cartel. According to UIF, the action targeted international money laundering and tax crime networks, adding individuals and companies to the Blocked Persons List and filing complaints for illicit financial operations.
According to a survey published by the UK Home Office on 6 November 2025, only 17% of around 3,400 surveyed businesses in the UK were “specifically aware” of the financial sanctions regime and how it affected them. It also found that surveyed businesses “seldom” understood the distinction between financial sanctions and the wider UK sanctions regime.
Fraud
Thailand’s Ministry of Digital Economy and Society reiterated its commitment to tackling online crimes on 12 November 2025 , including illegal gambling, by suspending implicated officials and prosecuting those involved in document forgery. The regulator announced it had shut down over 40,000 gambling websites within the past month.
Anti-bribery and corruption
A Millicom subsidiary agreed to pay US$18 million as part of a deferred prosecution agreement with the US Department of Justice to resolve a Foreign Corrupt Practices Act 1977 charge over payments to Guatemalan officials, according to a 10 November announcement by the company. It will return over US$58 million in benefits from the payments and pay a US$60 million fine as part of the agreement.
On 6 November 2025, the Singapore Corrupt Practices Investigation Bureau charged an officer at the National Environment Agency with multiple corruption offences, including accepting over 20,000 Singapore dollars (US$14,800) in bribes, under the Prevention of Corruption Act 1960. According to Singapore’s Corrupt Practices Investigation Bureau, the payments were intended to prevent the reporting of malpractices.