The Investigative Journal’s weekly digest of cross-border corruption, kleptocracy enforcement, and illicit-finance developments. This week’s edition tracks a high-profile money-laundering suspicion notice in Kyiv, the first U.S. FCPA jury verdict of 2026, new FATF jurisdictional changes, sanctions evasion advisories from OFAC, and the unwinding of the Venezuela kleptocracy file after the January capture of Nicolás Maduro.
Top Story: Ukrainian Anti-Graft Prosecutors Charge Zelensky’s Former Chief of Staff
Ukraine’s Specialized Anti-Corruption Prosecutor’s Office (SAPO) and the National Anti-Corruption Bureau of Ukraine (NABU) on May 11 issued a formal notice of suspicion against Andriy Yermak, the former head of the presidential office, in connection with what investigators describe as an organized money-laundering scheme valued at roughly 460 million hryvnias (approximately $10 million to $11 million). According to filings summarized by OCCRP, prosecutors allege the funds were laundered between 2021 and 2025 through a luxury residential development outside Kyiv known as “Dynasty,” and that a portion of the proceeds may have originated in earlier kickback schemes at the state nuclear utility Energoatom.
Yermak, who resigned in 2025 amid an initial wave of anti-corruption raids tied to Energoatom procurement, has denied wrongdoing through his attorney, Ihor Fomin, who called the suspicion notice groundless. SAPO head Oleksandr Klymenko has said prosecutors will seek pre-trial detention or bail of 180 million hryvnias (about $4.1 million). The presumption of innocence applies; no conviction has been entered, and the proceedings remain at the suspicion-notice stage under Ukrainian criminal procedure.
The case is significant beyond Kyiv. Western donors — including the European Union, the IMF, and U.S. Treasury — have conditioned reconstruction tranches on demonstrable progress against high-level corruption. A successful prosecution of a figure as senior as Yermak would mark the most consequential test to date of the post-2014 anti-corruption architecture that NABU and SAPO were designed to embody. Filings indicate the property project may have been a vehicle for layering proceeds from earlier energy-sector procurement schemes — a typology that maps closely onto OCCRP’s long-running reporting on Eastern European real-estate laundering corridors.
2. FCPA Jury Conviction in Pennsylvania Signals Continued Enforcement
On February 18, 2026, a federal jury in the Western District of Pennsylvania returned a guilty verdict against Charles Hunter Hobson, a former U.S. coal-company executive, on counts including substantive violations of the Foreign Corrupt Practices Act (FCPA), conspiracy to violate the FCPA, money laundering, money-laundering conspiracy, and conspiracy to commit wire fraud. Court records reviewed by Arnold & Porter’s Enforcement Edge indicate Hobson is scheduled for sentencing on June 25, 2026, and faces statutory maximums of up to 20 years on the money-laundering and wire-fraud conspiracy counts.
The verdict is notable because it lands during a period in which the Department of Justice has publicly recalibrated FCPA priorities. A February 10, 2025 memorandum from Deputy Attorney General authorized a pause and review of FCPA matters, and subsequent guidance directs the FCPA Unit in the Criminal Division’s Fraud Section to prioritize investigations connected to cartels and transnational criminal organizations, and to cases involving “substantial bribe payments, proven and sophisticated efforts to conceal bribe payments, fraudulent conduct in furtherance of the bribery scheme, and efforts to obstruct justice.” DOJ guidance also flags cases that deprive U.S. companies of fair competition or threaten national security.
According to a DLA Piper year-in-preview, staffing at the FCPA Unit remains lean — roughly a dozen prosecutors — and the SEC’s parallel FCPA Unit appears to have been effectively dissolved, with no SEC FCPA actions publicly recorded in 2025. The Hobson verdict suggests that, even with narrower enforcement parameters, individual prosecutions are advancing where the underlying conduct overlaps with money-laundering and wire-fraud theories that survive the policy realignment.
3. FATF Adds Kuwait and Papua New Guinea to Grey List; Four African Jurisdictions Removed
The Financial Action Task Force (FATF), at its February 13, 2026 plenary in Paris, added Kuwait and Papua New Guinea to its “Jurisdictions Under Increased Monitoring” list — colloquially the “grey list” — bringing the total to 23 countries. The list now includes Algeria, Bulgaria, Kenya, Syria, Venezuela, and Vietnam, among others. At an earlier October 2025 plenary, Burkina Faso, Mozambique, Nigeria, and South Africa were removed after FATF assessors documented sufficient progress on their action plans.
The blacklist — formally “High-Risk Jurisdictions subject to a Call for Action” — remains limited to North Korea, Iran, and Myanmar. FATF guidance emphasizes that grey-listing is not itself a sanction but signals strategic deficiencies in anti-money-laundering and counter-terrorist-financing regimes that the listed country has committed to address.
In practice, the consequences are material. ComplyAdvantage and other AML-compliance analysts note that the most acute downstream effect is correspondent-banking de-risking: large international banks tend to withdraw or restrict relationships with smaller institutions in grey-listed jurisdictions, raising compliance costs, lengthening settlement times, and in severe cases cutting off correspondent access entirely. The Kuwait listing in particular is being watched by Gulf-focused compliance teams, because Kuwaiti institutions sit on a number of trade-finance corridors connecting the GCC, South Asia, and East Africa.
4. OFAC Sham Transactions Advisory Targets Oligarch and Cartel Concealment Structures
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on March 31, 2026 published a Sanctions Advisory titled “Guidance on Sham Transactions and Sanctions Evasion.” The advisory flags compliance risks arising from blocked persons — including Russian oligarchs and narco-trafficking cartel figures — using opaque legal structures, nominee arrangements, and back-dated paperwork to conceal continued beneficial interests in property and to facilitate sanctions evasion.
Akin Gump’s compliance team notes that the advisory identifies red flags such as transactions structured to evade the OFAC 50 Percent Rule, abrupt ownership transfers preceding designations, layered holding companies in secrecy jurisdictions, and reliance on professional intermediaries who may themselves be subject to enforcement risk. The advisory’s release comes against a backdrop in which the DOJ’s Task Force KleptoCapture and the Kleptocracy Asset Recovery Section were disbanded in February 2025 pursuant to an Attorney General memorandum, leaving OFAC and Treasury’s Financial Crimes Enforcement Network (FinCEN) as the principal Executive Branch instruments still actively pursuing oligarch-linked illicit finance. The Lawfare analysis cited by Transparency International USA argues this redistribution has elevated the importance of administrative sanctions enforcement relative to criminal asset recovery.
5. Switzerland Freezes Maduro-Linked Assets Following January Capture
Swiss authorities, following the January 3, 2026 U.S. operation that took former Venezuelan ruler Nicolás Maduro and his wife into custody and transferred them to New York to face narco-terrorism charges, moved to freeze assets connected to Maduro and 36 associated individuals. According to the Swiss federal statement summarized in international wires, the freezes are intended to ensure that “potentially illegally acquired assets cannot be transferred out of Switzerland” while criminal and asset-tracing proceedings continue in multiple jurisdictions.
Subsequent U.S. measures included Executive Order 14373, “Safeguarding Venezuelan Oil Revenue for the Good of the American and Venezuelan People,” signed January 9, 2026, and the issuance of a series of general licenses culminating in updates dated May 4, 2026. Treasury has also removed Delcy Rodríguez — currently functioning as interim president — from the Specially Designated Nationals list. The Venezuelan sanctions program now sits in an unusual posture: simultaneously deploying asset-freeze tools against the prior leadership while creating licensed channels for re-engagement with the transitional government on hydrocarbons revenue.
The Maduro file is likely to produce extensive cross-border asset-recovery litigation. Open-source reporting indicates Swiss, U.K., and Caribbean banking relationships are being mapped; records suggest a network of nominee entities used to hold real estate and securities. Filings in the U.S. narco-terrorism case may, over time, surface documentary chains that asset-recovery practitioners can use in parallel civil forfeiture proceedings.
6. Corporate Transparency Act Pulls Back on Domestic Beneficial-Ownership Reporting
FinCEN’s interim final rule, finalized March 21, 2025 and in effect throughout 2026, removes the requirement for U.S.-formed companies and U.S. persons to report beneficial-ownership information (BOI) under the Corporate Transparency Act. The reporting regime now applies only to entities formed under foreign law that have registered to do business in a U.S. state or tribal jurisdiction. On February 13, 2026, FinCEN issued an additional exceptive relief order easing customer due-diligence (CDD) requirements at covered financial institutions, exempting them from re-identifying beneficial owners each time a legal-entity customer opens a new account.
Anti-corruption analysts at Transparency International USA and the Global Anticorruption Blog have warned that the rollback narrows the federal beneficial-ownership transparency baseline that Congress legislated in 2021. The state-level response has been uneven: New York’s LLC Transparency Act took effect January 1, 2026, and California is advancing its own statute. Compliance teams now face a patchwork in which the federal database covers only foreign-formed entities while state databases capture varying slices of domestic LLCs and corporations. For investigators tracing illicit flows, the practical implication is that single-source federal lookups are no longer sufficient; cross-referencing state filings and commercial registries is increasingly necessary.
7. UK Serious Fraud Office Secures First Corporate Bribery DPA in Five Years
The UK Serious Fraud Office (SFO) secured a Deferred Prosecution Agreement with Ultra Electronics Holdings Limited resulting in a £10 million penalty and £4.8 million in SFO costs, according to a government announcement summarized by Spotlight on Corruption. The DPA is the SFO’s first corporate bribery resolution since Glencore’s £276 million 2022 penalty and marks a notable restart of UK corporate enforcement activity.
The agency simultaneously closed an unrelated decade-old prosecution of two former London Mining PLC employees after disclosure issues. Lexology’s UK Regulatory Outlook for January 2026 notes the SFO has approximately 26 known open investigations, and is positioning to make early use of the new “failure to prevent fraud” corporate offence that came into force in 2025. Practitioners expect the offence — which mirrors the 2010 Bribery Act’s section 7 failure-to-prevent model — to drive a pipeline of corporate self-reports and resolutions over the coming 18 months.
8. Transparency International Releases the 2025 Corruption Perceptions Index
Transparency International published the 2025 Corruption Perceptions Index (CPI) on February 11, 2026, ranking 182 countries on perceived public-sector corruption on a 0–100 scale. Denmark (89), Finland (88), and Singapore (84) led the rankings, while South Sudan and Somalia tied at the bottom with scores of 9, followed by Venezuela at 10. Western European nations accounted for nine of the top ten places, but Transparency International noted that the regional average has declined more rapidly than any other in recent years — a finding the organization attributes to slipping rule-of-law indicators and stalled anti-corruption reforms.
The CPI is a perception index, not a measure of actual corruption volumes, and Transparency International cautions against over-interpretation. The organization’s framing is that 31 countries have significantly reduced perceived corruption since 2012, while the remainder have stayed flat or worsened. For TIJ readers tracking corridor risk, the CPI is most useful as a triangulating data point alongside FATF assessments, Basel AML Index scores, and country-specific judicial-independence reporting.
Leads for Deeper Investigation
Several threads emerging from this week’s developments warrant follow-up reporting. First, the Yermak suspicion notice points to a “Dynasty” real-estate vehicle that may be the entry point into a wider network of Energoatom-linked property laundering — court documents, when unsealed, should permit a corporate-records mapping exercise. Second, the OFAC sham-transactions advisory implicitly catalogs typologies that practitioners say correspond to specific identified evasion cases; cross-referencing the advisory’s red flags against recent OFAC designations could surface the underlying conduct. Third, the Swiss Maduro freezes are likely to produce listed-asset disclosures over the coming months; comparing those to leaked offshore datasets in the ICIJ Offshore Leaks database may reveal previously unknown intermediaries. Fourth, the new FATF grey-listings of Kuwait and Papua New Guinea will trigger compliance reviews at correspondent banks — public Suspicious Activity Report data, where available, may flag elevated SAR volumes connected to those jurisdictions in coming quarters.
The Investigative Journal welcomes tips on any of these threads. Records suggest a number of corridors that bear closer scrutiny; we will return to them in subsequent editions. — Eduardo Bacci, editor.
Sources
- OCCRP — Former Ukrainian Presidential Aide Implicated in Money Laundering Probe
- Ukrainska Pravda — Zelenskyy’s former chief of staff Yermak charged with money laundering
- RFE/RL — Ukrainian Anti-Graft Prosecutor Seeks Detention of Zelenskyy’s Ex-Chief of Staff
- Arnold & Porter — FCPA jury verdict against Charles Hunter Hobson
- DLA Piper — FCPA Year in Review 2026
- FATF — Jurisdictions Under Increased Monitoring, 13 February 2026
- FATF — High-Risk Jurisdictions subject to a Call for Action, February 2026
- ComplyAdvantage — FATF Plenary February 2026 Key Updates
- Akin Gump — OFAC Sanctions Advisory on Sham Transactions
- Lawfare — Dismantling of the Kleptocracy Team
- Transparency International USA — AG Memo on Anti-Corruption Enforcement
- Switzerland orders freezing of Maduro-linked assets (SWI swissinfo.ch)
- OFAC — Venezuela-Related Sanctions
- FinCEN — Removal of BOI Reporting Requirements for U.S. Companies
- Spotlight on Corruption — SFO Ultra Electronics DPA
- Transparency International — 2025 Corruption Perceptions Index
- ICIJ — Offshore Leaks Database