The Investigative Journal’s weekly survey of international anti-corruption enforcement, kleptocracy investigations, sanctions activity, and the financial architecture that moves illicit money across borders.
Wise Money-Laundering Probe Nears Conclusion in Belgium
Belgian prosecutors are closing in on a conclusion in a long-running probe of London-listed money-transfer firm Wise, with filings indicating roughly €500 million ($583 million) in suspicious transactions are under examination, according to coverage by AML Intelligence. Investigators have been examining whether Wise accounts were used to move proceeds linked to fraud, drug trafficking, and corruption, and the company has been cooperating with Belgian authorities since the initial referral.
The case is significant beyond the firm itself. Wise’s business model — fast, low-friction cross-border retail transfers — sits at the intersection of legitimate consumer fintech and the typologies regulators now flag most often in suspicious-activity reports: layered small-value transactions, third-party intermediaries, and accounts opened with thin verification. Records suggest Belgian authorities are weighing whether the firm’s transaction-monitoring controls met EU AML obligations during the period under review.
For the broader fintech sector, the Wise probe is a marker. Regulators across the EU and UK have signaled that the post-Wirecard tolerance for “move fast” compliance postures inside licensed payment institutions is over. A negotiated resolution — if one materializes — would almost certainly set a benchmark figure for European money-services-business enforcement for the next several years.
OFAC Targets Sham Transactions in New Sanctions Advisory
The U.S. Treasury’s Office of Foreign Assets Control issued a sanctions advisory on March 31, 2026, titled Guidance on Sham Transactions and Sanctions Evasion, formally codifying its approach to a problem that has dogged the oligarch-asset program since 2022. OFAC’s advisory describes — with unusual specificity — the structures designated persons have used to “extinguish” formal ownership while retaining economic control: trusts naming spouses or minor children as beneficiaries, straw owners, front businesses, and opaque foreign holding vehicles.
The advisory cites concrete examples. In one, a blocked oligarch transferred his private jet to a trust with his unsanctioned wife as sole beneficiary, while continuing to use the aircraft. In another, a designated person moved funds into trusts established for minor children and then attempted to route money through U.S. banks. OFAC’s enforcement record now includes the $215.9 million penalty against GVA Capital and an $11.5 million settlement with IPI Partners, both arising from continuing-interest analyses.
The practical consequence for compliance officers is that “look-through” analysis is no longer optional. Records indicate OFAC expects financial institutions and corporate counsel to evaluate the economic substance of transactions involving recently restructured legal entities — particularly any structure created or amended after a beneficial owner’s designation date.
SFO Closes Ultra Electronics Bribery Investigation with £15 Million Resolution
The UK Serious Fraud Office secured a deferred prosecution agreement with British defence supplier Ultra Electronics Holdings Ltd, ending an eight-year investigation into corruption tied to the company’s Algerian business. Court filings indicate the resolution comprises a £10 million penalty plus £4.8 million covering the SFO’s investigative costs, with the High Court approving the DPA earlier this spring, according to Spotlight on Corruption.
The Ultra Electronics matter dates to a 2018 self-report. Filings indicate the SFO determined the company failed to prevent bribery committed by intermediaries pursuing defence contracts in Algeria — a “failure to prevent” charge under Section 7 of the UK Bribery Act, which does not require proof of senior-management knowledge. The negotiated outcome reflects a now-familiar SFO pattern: significant penalty, no contested trial, retained corporate independence, and a compliance monitor arrangement.
The closure coincides with what the SFO has publicly described as a more “intelligence-led, assertive” posture for 2026-27. The agency has also disclosed a fixed October 2026 trial date for former Petrofac executives Marwan Chedid and George Salibi, both charged with bribery offenses in February 2024 — a contested case the SFO will use to demonstrate trial capability that critics have argued the agency lacks.
FATF Adds Kuwait and Papua New Guinea to Grey List
The Financial Action Task Force, meeting in plenary in February 2026, added Kuwait and Papua New Guinea to its list of jurisdictions under increased monitoring — the so-called “grey list.” Both countries had completed mutual evaluations identifying significant deficiencies and, according to FATF’s published assessment, failed to demonstrate sufficient remediation progress within the post-evaluation window.
Kuwait’s listing reflects what FATF described as gaps in operational effectiveness rather than the absence of regulatory frameworks. The country has the laws on paper; data shows it has struggled to translate them into investigations, prosecutions, and asset freezes. Papua New Guinea was grey-listed on structural grounds: weaknesses in AML supervision, underuse of financial-intelligence-unit analysis, and gaps in beneficial-ownership transparency that FATF assessors flagged as systemic.
The next FATF plenary in June 2026 will indicate whether additional jurisdictions are moved onto — or off — the list. Grey-listing carries measurable economic cost: prior IMF research has linked listings to declines in capital inflows of several percentage points of GDP, an outcome that typically focuses domestic political attention more effectively than years of technical-assistance reports.
Transparency International CPI Shows Continued Democratic Backsliding
Transparency International released its 2025 Corruption Perceptions Index on February 10, 2026, with results that mark a continued erosion in the scores of established democracies. The index ranks 182 countries, and the global average fell to 42 of 100. According to Transparency International, 122 countries now score below 50, and only five jurisdictions score above 80 — down from 12 a decade ago.
Denmark (89), Finland (88), and Singapore (84) topped the rankings; South Sudan and Somalia (both 9) and Venezuela (10) anchored the bottom. The United States scored 64 and slipped one position to 29th overall. Canada (75), New Zealand (81), the United Kingdom (70), France (66), and Sweden (80) also showed declines from prior cycles.
Transparency International’s accompanying analysis links worsening CPI scores to restrictions on civic space. Records indicate 36 of the 50 largest CPI decliners over the past decade have constrained press, assembly, or NGO freedoms. The organization also noted that more than 90 percent of journalists murdered while investigating corruption over the same period were operating in low-scoring jurisdictions — a data point that underscores why corruption reporting in many countries remains a physical-risk profession.
ICIJ Investigation Forces Malawi Mining Review
An International Consortium of Investigative Journalists investigation published earlier this year — in partnership with Platform for Investigative Journalism (PIJ) Malawi — has prompted the Lilongwe government to launch a formal review of beneficial-ownership disclosures at a strategic mining concession. ICIJ’s reporting documented how Chinese-linked firms acquired effective control of the asset through ownership changes that filings indicate were not disclosed to Malawian regulators in the form required by national mining law.
The mining ministry has pledged a fact-finding exercise that could result in fines or administrative action, according to ICIJ’s follow-up coverage. The case illustrates a recurring pattern in extractive-sector corruption investigations: the gap between formal compliance with disclosure rules and the practical visibility regulators have into ultimate ownership, especially when ownership chains pass through Hong Kong, Mauritius, or British Virgin Islands vehicles.
The Malawi review is one of several jurisdictions worldwide where ICIJ’s Pandora Papers follow-on data — now incorporating beneficial-ownership records for more than 9,000 offshore companies, foundations, and trusts — has triggered domestic regulatory action. The pattern is one TIJ has flagged in prior coverage: investigative leaks producing measurable enforcement outcomes only where domestic regulators have both legal authority and political space to act.
FTI Consulting Settles VTB Bank Sanctions Violation for $1.05 Million
OFAC announced a $1.05 million settlement with FTI Consulting earlier this week to resolve apparent violations of U.S. sanctions on Russian state-owned VTB Bank, according to coverage by Eastern Herald. Filings indicate the underlying conduct involved professional services rendered in connection with VTB debt during a period when the bank was subject to U.S. sectoral sanctions under Directive 1.
The settlement is modest by OFAC standards but instructive in its targeting. Professional-services firms — consulting, accounting, legal — have been the focus of growing enforcement attention since the 2022 expansion of the Russia sanctions program, on the theory that advisory work on financing structures involving sanctioned entities can itself constitute a prohibited service. The FTI matter is one of a small but growing line of cases that puts that theory into settled enforcement record.
For the broader professional-services sector, the takeaway is that engagement intake and conflict-checking procedures need to capture sanctions-nexus risk at the matter level, not just the client level. A client that is not itself a sanctioned person can still generate a sanctions violation if the work product touches blocked debt, blocked equity, or a blocked counterparty.
DOJ Resumes FCPA Enforcement with Revised Priorities
The U.S. Department of Justice has resumed Foreign Corrupt Practices Act enforcement following the February 2025 executive order that had paused new cases, with revised written priorities issued by the Deputy Attorney General’s office. According to law-firm summaries of the new guidance, prosecutors are now directed to focus FCPA resources on cases implicating U.S. national security or economic competitiveness; conduct involving cartels and transnational criminal organizations; schemes that rely on money launderers or shell companies; and matters involving state-owned-entity employees.
The first post-pause trial conviction came in September 2025 with the FCPA conviction of Carl Zaglin, owner of Atlanco LLC. In August 2025, DOJ declined prosecution of Liberty Mutual Insurance under the FCPA after the company self-reported and disgorged approximately $4.7 million in profits tied to a bribery scheme involving roughly $1.47 million in payments to officials at state-owned Indian banks. The Liberty Mutual declination — paired with disgorgement — illustrates the DOJ’s continuing willingness to credit cooperation and remediation even under the revised, narrower enforcement framework.
For defense and dual-use companies operating in jurisdictions where state-owned entities dominate procurement, the revised guidance is functionally a re-prioritization, not a retreat. The threshold for federal interest has moved up; the universe of conduct that meets the new threshold remains substantial.
Leads Warranting Deeper Investigation
Three threads from this week’s developments warrant deeper TIJ inquiry. First, the Wise resolution — when it lands — will create a comparison case for several other European payment institutions known to be under preliminary scrutiny; TIJ will track the penalty-to-volume ratio against earlier Wirecard-era benchmarks. Second, OFAC’s sham-transaction advisory effectively invites whistleblower submissions on trust-and-LLC structures created after February 2022, and the agency’s enforcement docket over the next two quarters will reveal whether that invitation produces actionable referrals. Third, the FCPA priority shift toward state-owned-entity schemes points to a likely uptick in cases tied to the Gulf, Southeast Asia, and Latin American jurisdictions where national oil companies, sovereign-investment vehicles, and state procurement agencies remain the dominant counterparties for U.S. and allied companies.
The through-line across all eight stories this week is the same one Transparency International’s CPI numbers describe in aggregate: corruption is a financial-architecture problem more than a legal-text problem. The texts are increasingly there; the architecture — beneficial-ownership transparency, sanctions look-through, intermediary supervision — still lags.
Sources and Further Reading
- Organized Crime and Corruption Reporting Project (OCCRP)
- ICIJ: Chinese firms and Malawi mine ownership
- Transparency International — Corruption Perceptions Index 2025
- FATF — Jurisdictions Under Increased Monitoring, February 2026
- OFAC — Sanctions Advisory on Sham Transactions
- Spotlight on Corruption — SFO/Ultra Electronics DPA
- AML Intelligence — Wise Belgian money-laundering case
- Alston & Bird — DOJ FCPA enforcement 2026 priorities
- Eastern Herald — FTI Consulting / VTB OFAC settlement
- ComplyAdvantage — FATF February 2026 plenary summary
Eduardo Bacci is an investigative journalist and editor for The Investigative Journal. This digest is compiled from public records, regulatory filings, and verified investigative reporting. Pending matters are noted as such; settled cases are described on the public record. The Investigative Journal welcomes corrections to factual claims via the standard right-of-reply process.