Author: gracechurchfcp

HSBC fined £57.4m for customer deposit protection failings

Regulatory Fines
HSBC has been fined £57.4m by the Bank of England for “serious failings” over its measures to protect customer deposits.The bank failed to accurately identify deposits eligible for Britain’s Financial Services Compensation Scheme, the Bank’s Prudential Regulation Authority (PRA) said.Under the scheme, customer deposits are protected up to the value of £85,000. HSBC said it was pleased to have resolved the “historic matter”. The fine is the second highest to date imposed by the regulator, reflecting the seriousness of the failings, the PRA said.The regulator said the problems occurred between 2015 and 2022.Under depositor protection rules, banks must have systems…

NCA investigation ends in eight year jail term for east London money launderer who took payments for small boats crossings

Money Laundering, Prosecutions
A man investigated by the National Crime Agency for laundering money made by people smuggling networks involved in small boats crossings has been jailed for eight years.Iranian Asghar Gheshlaghian, 48, was convicted last week of running an unregistered money services business from an office block in Wood Green, as part of a network of bankers transferring money using the hawala system. He acted as a trusted middleman, accepting payments from migrants or their families, and then releasing money to the criminal gangs following the completion of their journeys to the UK, charging a commission at the same time. Gheshlaghian, who…

Deepfakes Are a Threat to UK Banks

Fraud
As fraudsters continue utilizing innovative technology for their illicit activities, financial institutions find themselves in an endless game of catch-up. A particularly concerning development for UK banks involves the surge in deepfake technology threats. According to a report from Sumsub, there was a 300% increase in deepfake incidents from 2022 to 2023 in the UK, with AI-driven identity fraud ranking among the top five in 2023. The UK’s vulnerability to such attacks is heightened due to its economic prominence, widespread adoption of digital banking, and considerable online presence. In an interview with the Financial Times, David Duffy, CEO at Virgin…

US and UK sanction senior Houthis over Red Sea shipping attacks

Sanctions
The US and the UK have imposed sanctions on four senior Houthi officials for their roles in supporting or directing attacks on commercial shipping in the Red Sea. Those targeted include Houthi defence minister Mohamed Nasser al-Atifi, commander of Houthi naval forces Muhammad Fadl Abd al-Nabi, coastal defence forces chief Muhammad Ali al-Qadiri and Muhammed Ahmad al-Talibi, described as the Houthi forces director of procurement. “The Houthis’ persistent terrorist attacks on merchant vessels and their civilian crews … threaten to disrupt international supply chains and the freedom of navigation, which is critical to global security, stability, and prosperity,” the US…

UK economic crime regime

Regulation
This guide to the UK economic crime regime sets out information on the relevant legislation impacting solicitors and firms. Money Laundering Regulations 2017The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) set out the main anti-money laundering (AML) requirements for firms. This legislation has been amended by the: Money Laundering and Terrorist Financing (Amendment) Regulations 2019, which came into force on 10 January 2020 and implemented broad changes to the MLRsMoney Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020, which made narrow changes mainly to the requirements around trust registrationThe Money Laundering and Terrorist…

NEW RESEARCH FROM TI-RUSSIA ACTS AS A REMINDER THAT THE UK NEEDS TO DOUBLE-DOWN ON ITS ROLE AS AN ENABLER OF FINANCIAL CRIME

Money Laundering, Trade Based Finance
Have you ever bought something that’s never arrived, or wasn’t quite what you expected? Frustrating, isn’t it, and maybe far too frequent an occurrence. Now imagine you wanted this to happen, and you intended to spend hundreds of thousands, possibly millions of pounds in the process. Your friends would think you’d gone mad. Yet this is exactly how hundreds of millions of pounds has been moved out of Russia and into the UK in recent years. Here’s how it works. Imagine you’re an organised criminal gang or a senior politician. You’ve managed to generate some income from activity that is…

National Crime Agency calls on parents to help young people recognise the signs of money muling

Money Laundering
The National Crime Agency is asking parents and carers to help young people avoid being persuaded or manipulated into laundering criminal cash. The NCA’s call follows three weeks of coordinated law enforcement action against money mules – a term given to individuals enlisted by criminals to move the proceeds of crime through their bank accounts in return for a cut of the sum. Around 6 in 10 money mules are under the age of 30, with most of these recruited between the ages of 17 and 24 while attending sixth form, college or university. At this age, young people may…

UK publishes two new Russia sanctions regulations and two new General Licences

Sanctions
On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russia’s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a number will come into force on 26 December 2023 and 1 January 2024. Separately, on 15 December, the UK also designated Novikombank, which is now…

New unit to crack down on firms dodging Russian sanctions

Sanctions
Companies who are found to be dodging strict trade sanctions, including those imposed since the war in Ukraine, will face tougher penalties with the creation of a new Office of Trade Sanctions Implementation (OTSI). Industry and Economic Security Minister Nusrat Ghani is today [11 December 2023] announcing the creation of a new unit to crack down on companies dodging Russian sanctions. The OTSI will be responsible for the civil enforcement of trade sanctions, including those against Russia. The unit will help businesses comply with sanctions and investigate potential breaches, issuing civil penalties and referring cases to HMRC for criminal enforcement…

Financial services regulation: Adapting to change

Regulation
The Financial Conduct Authority (FCA) is making significant changes in response to its new responsibilities and past regulatory failures, but it needs to manage the related risks if it’s to meet its commitments, including reducing and preventing financial crime, according to a new report by the National Audit Office (NAO). The FCA regulates approximately 50,000 firms in an industry worth more than £170 billion to the UK economy. The financial services sector is undergoing significant changes; the FCA began a transformation programme in 2020-21 in response to these changes and this will take a number of years to realise. Reshaping…

RBC Slapped with $7.4M Penalty by Fintrac Over Anti-Money Laundering Non-Compliance

Money Laundering, Prosecutions
Canada’s financial intelligence agency, the Financial Transactions and Reports Analysis Centre of Canada (Fintrac), has levied a substantial $7.4 million penalty against the Royal Bank of Canada (RBC) for its non-compliance with anti-money laundering (AML) and terrorist financing measures. Fintrac’s findings reveal multiple violations, including the failure to submit suspicious transaction reports when there were reasonable grounds to suspect connections to money laundering offenses. Out of 130 case files reviewed, RBC neglected to submit 16 suspicious transaction reports, leading to the hefty penalty. The administrative penalty, imposed on November 3, follows a compliance examination conducted by Fintrac in 2022. Despite…

Council and Parliament reach political agreement to criminalise violation of EU sanctions

Regulation, Sanctions
The Spanish presidency of the Council and the European Parliament concluded their negotiations for an EU law which introduces criminal offences and penalties for the violation of EU sanctions. This directive ensures that those who violate or circumvent EU sanctions will be prosecuted. This gains particular importance in the context of the Russian war of aggression against Ukraine. The law lays down that member states will need to define certain actions as criminal offences. These include: helping persons subject to EU restrictive measures to bypass a travel bantrading sanctioned goods and running transactions with states or entities which are hit…

Bipartisan Anti-Crypto Terror Financing Bill Heads to U.S. Senate

Counter Terrorist Financing, Regulation
A bipartisan group of U.S. senators including Mitt Romney (R-UT) introduced legislation that expands sanctions to foreign entities supporting all U.S.-designated terrorist groups, including through crypto transactions, giving law enforcement an additional toolkit to tackle terror financing.“The Terrorist Financing Prevention Act of 2023, introduced by the Senators, aims to prevent Foreign Terrorist Organizations and their financial enablers, including those using digital assets, from accessing U.S. financial institutions, imposing sanctions and strict regulations to counteract these activities,” the bill reads.The proposed act broadens current sanctions, initially focused on Hezbollah, to include all U.S.-designated foreign terrorist organizations and their supporting foreign entities.…

Landmark Agreement: EU Nears Establishment of Robust Anti-Money Laundering Authority

Regulation
In a historic move, the European Union’s Council and Parliament have provisionally agreed to forge ahead with the creation of a groundbreaking European authority focused on combating money laundering and the financing of terrorism – the Anti-Money Laundering Authority (AMLA). This breakthrough represents a cornerstone in the broader anti-money laundering package, designed to fortify the EU’s financial system and protect the interests of its citizens. Under the terms of the provisional agreement, AMLA is set to wield both direct and indirect supervisory powers over high-risk entities within the financial sector. Notably, the agreement leaves the question of the authority’s seat…

Commodity Futures Trading Commission Imposes $91 Million Penalty on Freepoint Commodities for Fraudulent Conduct

Fraud, Prosecutions
The Commodity Futures Trading Commission (CFTC) has issued an order while simultaneously filing and settling misappropriation-based fraud charges against Freepoint Commodities LLC, a commodities merchant headquartered in Stamford, Connecticut. The fraudulent activities, spanning from 2012 to 2018, involved deceptive conduct aimed at obtaining material non-public information from a South American state-owned enterprise (SOE) concerning the purchase and sale of fuel oil. The CFTC’s order mandates Freepoint to pay more than $91 million in civil monetary penalties and disgorgement. The order reveals that Freepoint’s fraudulent conduct included the improper acquisition and trading on the SOE’s material non-public information, constituting a breach…

Former Special Agent in charge of the New York FBI Counterintelligence Division sentenced to 50 Months for conspiring to violate U.S. Sanctions on Russia

Prosecutions, Sanctions
A former Special Agent in Charge (SAC) of the FBI Counterintelligence Division in New York, was sentenced to 50 months in prison and ordered to pay a $40,000 fine for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and to commit money laundering in connection with his 2021 agreement to provide services to Oleg Deripaska, a sanctioned Russian oligarch. According to court documents and statements made in court proceedings, Charles McGonigal, 55, of New York, New York, pleaded guilty in August. “Charles McGonigal helped advance the interests of a sanctioned Russian oligarch, breaking his oath to safeguard our…

Vatican court convicts cardinal Angelo Becciu of embezzlement

Fraud, Prosecutions
A Vatican court on Saturday sentenced a once powerful Italian cardinal to five years and six months in jail for financial crimes at the end of a historic trial. Angelo Becciu, 75, a former adviser to Pope Francis who was once considered a papal contender himself, is the most senior clergyman in the Catholic church to face a Vatican criminal court. He and nine other defendants, including financiers, lawyers and ex-Vatican employees, were on trial over accusations of financial crimes focused on an opaque London property deal. Court president Giuseppe Pignatone read out the verdict on Saturday, with Becciu accused…

Joint action in Germany and Italy against money laundering via rental of luxury cars

Money Laundering
Eurojust has assisted the German and Italian authorities in a coordinated action against large-scale money laundering through the fake long-term rental of mainly luxury cars. Seven suspects were arrested across the two countries for using a car hire agency to launder the proceeds of drug trafficking, extortion and illegal betting for other criminals. The enterprise has been seized in addition to a real estate complex and nearly one hundred mainly luxury vehicles.The criminal network primarily used a German-registered car rental agency, which rented out over 150 vehicles for periods of three to four years to customers in Italy. Via fake…

Key findings from Phase 2 of Travers Smith review

PEPs
NatWest Group (NWG) has today published the key findings and recommendations from Phase 2 of the Travers Smith independent review – commissioned by the Board in July – relating to account closures at Coutts over the 24-month period prior to 28 July 2023. The key findings and recommendations report (the report) published today was compiled by Travers Smith. The Phase 2 review analysed 84 customer account closures – including all relevant PEP cases exited over the relevant period – building a total sample of around 10% of relevant account closures in the period. The report confirms that decision-making was consistent…

Treatment of Politically Exposed Persons under the Money Laundering Regulations

Legislation, PEPs
My Noble Friend the Treasury Lords Minister (Baroness Vere of Norbiton) has today made the following Writen Ministerial Statement. Today the Government has laid The Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (SI 2023/1371) a Statutory Instrument to amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Regulations) in relation to the treatment of Politically Exposed Persons (PEPs) who are entrusted with prominent public functions by the UK (known as ‘domestic PEPs’). The amendment makes clear that under the Regulations the starting point for banks and other regulated firms in their…

New strategy to tackle organised crime

Organised Crime
A new strategy aimed at tackling the growing threat of serious and organised crime has been announced by the Home Secretary as the government steps up action to clamp down on criminal gangs operating in and against the UK. The National Crime Agency (NCA) estimate that there are at least 59,000 people in the UK involved in serious and organised crime and that it costs the UK at least £47 billion each year, equating to the cost of building around 450 new hospitals or supplying around 730,000 more affordable homes outside of London. The new strategy, which builds on the…

UK to remain global centre of ‘dirty money’ without offshore registers, MPs say

Money Laundering
Britain will remain the global centre of “dirty money” unless ministers revive stalled plans for public registers of who owns companies based in offshore havens such as the British Virgin Islands (BVIs) and Jersey, campaigners and senior MPs have said. The veteran anti-corruption campaigner Dame Margaret Hodge MP said it was a matter of national security to do away with the secrecy offered by the 10 inhabited overseas territories and three crown dependencies. In 2020, the government gave the overseas territories, which include the BVIs, Cayman Islands and Bermuda, a deadline of December 2023 to introduce public registers of corporate…

Ladbrokes and Coral owner to pay £585m to settle HMRC bribery inquiry

Bribery, Corruption
The owner of Ladbrokes and Coral has agreed to pay almost £600m to settle an investigation into alleged bribery at a business it owned in Turkey. Entain said it had reached an agreement with HM Revenue and Customs which will make the gambling giant pay a total of £585m in the form of a financial penalty and a “disgorgement of profits”. Under the terms of the agreement, the penalty, which includes an extra £20m charitable donation and a contribution of £10m towards the costs incurred by HMRC and the Crown Prosecution Service (CPS), will be paid in instalments over four…

SFO recovers £250,000 tennis club debenture from convicted fraudster

Asset Seizure
Today at Southwark Crown Court, the Serious Fraud Office (SFO) confiscated £250,000 from Achilleas Kallakis, one of the convicted fraudsters behind the UK’s largest ever mortgage fraud, held at the prestigious West London sports club, The Queen’s Club. SFO investigators identified the £250,000 debenture by tracing the funds through a complex chain of offshore accounts, including a purported family trust, to his £740 million fraud. Mr Kallakis’s name was displayed prominently alongside other notable members on the Debenture Board in the club’s reception in return for the debenture that he purchased in 2007. He also received club membership and access…

The EBA consults on new Guidelines on preventing the abuse of funds and certain crypto-assets transfers for money laundering and terrorist financing purposes

Digital Currencies
The European Banking Authority (EBA) today launched a public consultation on new Guidelines on preventing the abuse of funds and certain crypto-assets transfers for money laundering and terrorist financing purposes. These ‘travel rule’ Guidelines specify the steps that Payment Service Providers (PSPs), Intermediary PSPs (IPSPs), crypto-asset service providers (CASPs) and Intermediary CASPs (ICASPs) should take to detect missing or incomplete information that accompanies a transfer of funds or crypto-assets. They also detail the procedures all these providers should put in place to manage a transfer of funds or a transfer of crypto-assets that lacks the required information. These Guidelines aim…

Lawmakers call for EU crackdown after ICIJ’s Cyprus Confidential revelations

Corruption
European Union lawmakers have criticized Cyprus for its lax enforcement of sanctions against Russia and called for loopholes in anti-money laundering systems to be closed in the wake of revelations from the Cyprus Confidential investigation. During a European Parliament session in the French city of Strasbourg, the officials also debated over the need to speed up ongoing negotiations to better coordinate criminal penalties for sanction evasion across the bloc. The parliamentary session was called in direct response to the latest investigation by the International Consortium of Investigative Journalists, in partnership with Paper Trail Media and 67 media outlets. The project,…

Modern Slavery and Human Trafficking: An Expanding UK Market

Human Trafficking
This is the second in a series of articles on the top 10 serious and organised crime threats to the UK and their evolution over a decade. This article traces the journey of the threat posed by modern slavery and human trafficking, which has risen rapidly up the policy agenda over a decade. Across the globe, supply chains of every description are tainted by exploited labour. The UK is no exception: here as elsewhere, labour is often the greatest cost to business. Reducing this cost offers the fastest route to increased margins. For some businesses, they will use whatever means…

British Reinsurance Brokers Resolve Bribery Investigations

Bribery, Corruption
Tysers Insurance Brokers Limited (Tysers) and H.W. Wood Limited (H.W. Wood), two U.K.-based reinsurance brokers, have agreed to resolve investigations by the Justice Department into violations of the Foreign Corrupt Practices Act (FCPA) arising from Tysers’ and H.W. Wood’s participation in a corrupt scheme to pay bribes to Ecuadorian government officials. Tysers and H.W. Wood each entered into a three-year deferred prosecution agreement (DPA) with the department in connection with a criminal information filed in the Southern District of Florida charging both companies with conspiracy to violate the anti-bribery provisions of the FCPA. “Tysers and H.W. Wood have admitted to…

U.S. Treasury Announces Largest Settlements in History with World’s Largest Virtual Currency Exchange Binance for Violations of U.S. Anti-Money Laundering and Sanctions Laws

Digital Currencies, Money Laundering
WASHINGTON — The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and IRS Criminal Investigation (CI), has taken unprecedented action to hold Binance Holdings Ltd. and its affiliates (collectively, Binance) accountable for violations of the U.S. anti-money laundering (AML) and sanctions laws that protect American national security and the integrity of the international financial system. Binance is the world’s largest virtual currency exchange, responsible for an estimated 60% of centralized virtual currency spot trading. Today, Binance settled with FinCEN and OFAC for violations of the Bank Secrecy Act (BSA)…

SFO secures conviction of solicitor for tipping off client about money laundering investigation

Money Laundering
Today at the Old Bailey the Serious Fraud Office (SFO) secured the conviction of William Osmond, a solicitor, who disclosed confidential details about an investigation and forged a legal document in an attempt to mislead investigators. Osmond, co-founder of a London-based commercial and property law firm Osmond & Osmond Solicitors Ltd, is the first ever solicitor the SFO has prosecuted with “tipping off” a client. Solicitors are legally obliged not to share details of money laundering investigations into their clients. Osmond was also the acting Money Laundering Reporting Officer for the firm, meaning he was expected to report any suspicions…

Leading firm fined £101,000 for anti-money laundering failures

Money Laundering
A leading South-West law firm has been fined £101,357 for failing to act over money laundering red flags on three property transactions, two of which may have involved a sanctioned entity. The Solicitors Regulation Authority (SRA) said both the fee-earner and the compliance team at Exeter-based Ashfords missed, did not adequately act on or sufficiently record the red flags, demonstrating “a failure in the firm’s client onboarding and ongoing monitoring processes”. This resulted in the firm receiving “significant sums into its client account in the absence of source of funds evidence”. Ashfords accepted the fine in a regulatory settlement agreement…

Binance chief Changpeng Zhao pleads guilty to money laundering charges

Money Laundering
The Binance chief executive, Changpeng Zhao, has resigned after pleading guilty to money laundering violations. “I made mistakes, and I must take responsibility. This is best for our community, for Binance, and for myself”, he said in a post on X. The Justice Department said it was requiring Binance, the largest crypto-exchange in the world, to pay $4.3bn (£3.4bn) in penalties and forfeitures. It said Binance had helped users bypass sanctions across the world. “Binance enabled nearly $900 million in transactions between US and Iranian users, and facilitated millions of dollars in transactions between US users and users in Syria,…

UK cracks down on gold and oil networks propping up Russia’s war economy

Sanctions
Foreign Secretary announces 29 new UK sanctions targeting individuals and entities operating in and supporting Russia’s gold, oil and strategic sectors. new UK sanctions target 29 individuals and entities operating in and supporting Russia’s gold, oil and strategic sectorsthose sanctioned include Russia’s largest gold refiner and international networks propping up Russia’s gold, oil and finance industriesto date the UK has sanctioned over 1,800 individuals, companies, and groups under our Russia sanctions regimeTwenty nine individuals and entities operating in and supporting Russia’s gold and oil sectors have been sanctioned by the UK today [8 November]. New listings include both Russian oligarchs…

United States and United Kingdom Take Coordinated Action Against Hamas Leaders and Financiers

Sanctions
WASHINGTON — Today, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed its third round of sanctions targeting Hamas-affiliated individuals and entities since the October 7 Hamas terrorist attacks on Israel. This action designates key Hamas officials and the mechanisms by which Iran provides support to Hamas and Palestinian Islamic Jihad (PIJ). Today’s designations are coordinated with action by the U.K. and are aimed at protecting the international financial system from abuse by Hamas and their enablers. The U.S. Department of State is concurrently designating a leader of PIJ’s military wing. “The United States will continue to…

Taiwanese authorities seize $320M in country’s largest crypto laundering scheme

Digital Currencies, Money Laundering
The case has surpassed all previous records of money laundering investigated by the Criminal Investigation Bureau in Taiwan Taiwan authorities have arrested an individual suspected of laundering a record 10.4 billion Taiwanese dollars ($320 million) via digital assets. This marks the largest single case of crypto-related money laundering in the island nation’s history. Identified only by the surname Qiu, the suspect was arrested in June upon his return from a trip to Southeast Asia, according to Taichung’s Criminal Investigation Bureau and local media. The case emerged from an investigation initiated last year into a fake securities trading app. A probe…

US Regulators Agree to Ramp Up Oversight of Systemically Risky Non-Banks

Regulation
In a significant policy shift, U.S. regulators have cleared the path for an increased oversight of asset managers, hedge funds, and other non-bank financial institutions that are perceived to pose potential risks to the country’s financial system. This move marks the revival of a robust regulatory framework that had been sidelined during the previous administration of President Donald Trump. The Financial Stability Oversight Council (FSOC), led by the Treasury Department and composed of other major federal agencies, has also introduced a new framework aimed at identifying impending risks within the financial system. This decision is an integral part of the…

France demands EU corruption-busting watchdog with teeth

Corruption
France wants the European Union to create an independent watchdog authority to fight corruption in the EU institutions, which have been rattled by ongoing scandals in recent months. France’s President Emmanuel Macron and French Secretary of State for European Affairs Laurence Boone are proposing an independent anti-corruption body that would have powers to check officials’ income and spot conflicts of interest, Boone told POLITICO’s Brussels Playbook. And now they’re pushing for other EU countries to endorse the plan. Earlier this year, the European Commission proposed the creation of an ethics body with lofty goals but no enforcement power to impose…

ADGM introduces the worlds first DLT Foundations Regime

Digital Currencies, Regulation
The Registration Authority (RA) of Abu Dhabi Global Market (ADGM) officially released the Distributed Ledger Technology (DLT) Foundations Regulations 2023, marking a significant milestone in the evolution of digital assets regulatory frameworks across the region and at an international level. This newly implemented legislative structure is designed to provide a comprehensive framework for DLT Foundations and Decentralised Autonomous Organisations (DAOs), enabling them to operate and issue tokens recognising the unique needs of the Blockchain industry. This new regime comes in line with ADGM’s strategy to foster initiatives in the broader blockchain and digital asset realm. By setting a global benchmark…

Singapore’s DBS Takes a Hit from Money-Laundering Affair

Money Laundering
Singapore’s largest bank, DBS, is grappling with financial exposure of approximately S$100 million (US$73.8 million) in connection with a recent money-laundering scandal that has rocked the city-state, according to the bank’s chief executive, Piyush Gupta. He made this revelation during a press briefing on Monday, shedding light on the bank’s involvement in the ongoing investigation. Gupta disclosed that DBS had provided financing for property purchases involving individuals or companies currently under investigation by Singaporean authorities. In August, the local police made headlines when they arrested 10 foreign nationals on charges that include fraud and money laundering, sending shockwaves throughout the…

Cyprus Wing of Auditing Giant PwC May Have Breached Sanctions in Work for Oligarch

Sanctions
As Russian tanks rolled into Ukraine in late February 2022, staff at the Cypriot wing of international auditing giant PwC were rushing to tie up the sale of hundreds of millions of dollars’ worth of assets owned by Russian oligarch Alexey Mordashov. Like other pro-Kremlin billionaires, Mordashov — described by Forbes as Russia’s richest person in 2021 — was at risk of having his European assets frozen if authorities sanctioned him in response to the invasion. At PwC Cyprus, staff exchanged documents marked “URGENT” and “PLEASE APPROVE” as they prepared paperwork to sell Mordashov’s stake in German travel company TUI…