Author: gracechurchfcp

Belarusian Fertilizer Company Dodging EU Sanctions, Leaked Documents Show

A Belarusian state fertilizer company under European Union sanctions has found a way around the export ban by leasing its production lines to intermediary firms that pose as manufacturers, according to an investigation by the Belarusian Investigative Center (BIC). Some fertilizer produced by the sanctioned enterprise is shipped into the EU through Latvia using documentation that obscures its true origin. A leaked government document obtained by BIC confirms the government’s role in setting up the scheme to help the fertilizer company in “overcoming sanctions.” According to the leaked document, the government-backed scheme involves “special exporters,” which lease production facilities from…

Monzo Fined £21 Million Over Financial Crime Control Failings as FCA Flags ‘Systemic’ Lapses

The UK’s Financial Conduct Authority (FCA) has fined Monzo Bank £21,091,300 for serious and repeated failures in its financial crime controls, citing deficiencies in the digital bank’s customer onboarding, risk assessment, and transaction monitoring systems between 2018 and 2022. According to a statement issued Monday, the regulator found that Monzo’s financial crime framework failed to keep pace with its explosive growth, expanding from 600,000 customers in 2018 to over 5.8 million by 2022. The FCA said Monzo’s controls were not only inadequate but “obviously implausible” at times, such as when it onboarded customers listing famous London landmarks as their residential…

Spanish Police Arrest Son of Russian Defense Executive in Money Laundering Probe

Spanish police have arrested Dmitry Artyakov, the son of a top Russian defense official, on suspicion of laundering millions of euros through real estate deals in northeastern Spain. Artyakov, who is under U.S. sanctions, was detained on Saturday at his home in Girona as part of a probe led by Spain’s Anti-Corruption Prosecutor’s Office and coordinated by the Audiencia Nacional, Spain’s top criminal court, judicial sources confirmed to OCCRP. Authorities allege Artyakov acquired eight properties, including two adjacent luxury villas, in the coastal town of Castell-Platja d’Aro between 2005 and 2008 through funds linked to the “Troika Laundromat,” a massive…

Top Andorran Bankers Jailed over €70M Laundering Plot

Andorra’s top court on Tuesday sentenced 18 executives of Banca Privada d’Andorra (BPA) to prison terms ranging from three and a half to seven years for laundering money in favor of a single client. The ruling also bars them from working in the banking sector and, in some cases, includes expulsion from the country. The case was unusually complex. The court’s ruling runs 6,180 pages and took 20 months to complete. Legal proceedings began in 2018, spanned 195 days, with each session lasting six hours—and this is just the first of several cases tied to the bank’s collapse. The investigation…

UAE Off EU Watchlist, Critics Say Reforms Fall Short

Transparency International has criticized the European Parliament’s decision to approve the removal of the United Arab Emirates from the EU’s high-risk list for money laundering and terrorist financing, warning that the move undermines efforts to protect the bloc’s financial system. “While the UAE has introduced a series of welcome reforms, it’s still too soon to judge whether these have significantly strengthened the country’s defences against dirty money,” Eka Rostomashvili, campaigner at Transparency International, told OCCRP. She pointed to persistent gaps in enforcement, especially in the real estate sector, where suspicious transactions exposed by journalists remain uninvestigated. An investigation Dubai Unlocked,…

UK Strikes Off 11,500 Companies in Crackdown on Fraud and Shell Entities

British authorities have struck off 11,500 firms from the Companies House register following a coordinated campaign to dismantle corporate entities used to enable fraud and money laundering in the U.K. and abroad. The crackdown, led by the National Economic Crime Centre (NECC), is part of a broader government effort to prevent the abuse of U.K. corporate structures, which officials estimate are involved in laundering more than £100 billion ($134 billion) annually. The removed companies failed to meet Registered Office requirements under the Companies Act 2006. Many were linked to high-risk incorporation addresses and corporate formation agents suspected of facilitating criminal…

Barclays Fined £42 Million by FCA Over Financial Crime Control Failures

The UK’s Financial Conduct Authority (FCA) has fined Barclays Bank UK and Barclays Bank a combined £42 million for separate and serious failures in their financial crime risk management, marking the latest in a series of enforcement actions against the bank over weak anti-money laundering (AML) controls. The fines stem from two unrelated cases involving WealthTek LLP and Stunt & Co, both of which exposed significant lapses in Barclays’ due diligence and monitoring practices, according to the FCA’s Final Notices issued on July 16, 2025. Failure to Flag WealthTek’s Client Money Activities Barclays Bank UK PLC was fined £3.1 million…

EU Rolls Out 18th Sanctions Package Targeting Russia’s War Machine & Sanctions Circumvention

Brussels has approved its most comprehensive sanctions package yet against Russia, marking the 18th wave of EU action since the start of the war in Ukraine. The new measures aim to ratchet up pressure on the Kremlin’s energy revenues, financial lifelines, and military-industrial backbone, while also closing loopholes and clamping down on sanctions evasion through third countries and shadow networks. The package introduces a dynamic new oil price cap, cutting the ceiling for Russian crude from $60 to $47.60 per barrel and tying future adjustments to market averages, ensuring the price remains 15% below the six-month benchmark for Urals crude.…

Alleged Russian Tax Fraud Mastermind Funneled Millions Into Luxury Dubai Properties

Perched on a crescent of artificial islands known as Palm Jumeirah in Dubai, the Kempinski Hotel & Residences resembles a sprawling seaside palace. Many of the 244-unit development’s luxurious apartments and villas have reportedly sold for millions of dollars, some even before the complex officially opened in 2011. OCCRP reporters found that among the early investors was a company owned by Dmitry Klyuev, the alleged mastermind of a massive Russian tax scandal known as the Magnitsky Affair. The Magnitsky Affair was named after whistleblower Sergei Magnitsky, a lawyer who died in prison after giving evidence to Russian prosecutors about the…

UK Sanctions Balkan Gangs After Passport Fraud Reveal

A UK crackdown targets Balkan gangsters who used fraudulent Bosnian documents—just weeks after Bosnian journalists revealed the scale of the identity theft scheme. The move comes after Bosnia’s Center for Investigative Journalism (CIN) exposed how international fugitives obtained genuine Bosnian passports using stolen identities. The list of individuals and firms the U.K. Foreign Office sanctioned on Wednesday includes a range of targets, from a small boat supplier in Asia to informal Hawala money movers in the Middle East, and gang leaders based in North Africa. Among them are individuals accused of supplying fake passports and forged documents to Balkan gangs,…

Hong Kong Regulator Fines Three Banks for Anti-Money Laundering Failures

Key Takeaways IOBHK Hit with Largest Fine: Indian Overseas Bank’s Hong Kong Branch was fined HK$8.5 million (US$1.1 million) and ordered to conduct a look-back review and implement a remedial plan due to serious AML/CFT control failures.BCOM Entities Also Penalized: Bank of Communications (Hong Kong) Limited and its Hong Kong Branch were fined HK$4 million (US$512,000) and HK$3.7 million (US$474,000), respectively, for failing to properly feed transactions into their monitoring system.Deficient Transaction Monitoring: All three banks were found to have inadequate systems for monitoring customer relationships and identifying suspicious activity, undermining compliance with AML/CFT regulations.Regulatory Warning Issued: The HKMA emphasized…

Lithuanian Prime Minister Resigns Amid Corruption Scandal Involving EU Funds

Lithuanian Prime Minister Gintautas Paluckas resigned on Thursday following a widening corruption scandal that has engulfed his family and inner circle, triggering the collapse of his cabinet after less than a year in office. His resignation, confirmed first by President Gitanas Nausėda, came after Lithuania’s Financial Crime Investigation Service raided on Thursday UAB Dankora, a company co-owned by Paluckas’ sister-in-law. Investigators are probing whether European Union development funds intended for an electric boat charging facility were misused. The project — located in a village with no direct water access — had received more than 170,000 euros in EU funding, much…

Abramovich business associate Eugene Shvidler fails to overturn UK sanctions

A business associate of the oligarch Roman Abramovich has failed to overturn sanctions imposed on him after Russia’s invasion of Ukraine, after a supreme court judgment seen as a test case for the UK’s sanctions regime. Eugene Shvidler served on the board of companies owned by the former owner of Chelsea football club and now lives in the US. He was placed under sanctions by the UK government in March 2022 as part of measures to target Russia-linked oligarchs and officials after Vladimir Putin ordered the invasion of Ukraine. Shvidler, who was born in the USSR in 1964, grew up…

Congress Takes Aim at Dirty Money in the Multi-Billion-Dollar U.S. Art Market

The Antiquities Coalition commends Senators John Fetterman (D-PA), Chuck Grassley (R-IA), Sheldon Whitehouse (D-RI), Dave McCormick (R-PA), and Bill Cassidy (R-LA), and Andy Kim (D-NJ) for introducing the Art Market Integrity Act, a commonsense proposal to apply anti-money laundering (AML) safeguards to high-risk art transactions. For years, criminals have exploited the art market’s regulatory gaps to move and hide illicit funds, finance armed conflict and terrorism, and evade U.S. sanctions. This bipartisan bill fights back through the Bank Secrecy Act (BSA)—a key tool for detecting and preventing financial crime—in recognition of the American art market’s global significance and its growing…

Law firm that failed to spot it was acting for PEP fined £173k

A law firm that failed to identify that the beneficial owner of its client was a politically exposed person (PEP) has been fined £173,000 by the Solicitors Regulation Authority (SRA). Cambridge-based Taylor Vinters no longer exists, having merged with London firm Mishcon de Reya in 2021 and been fully absorbed in 2023; the misconduct predates that. It has struck a regulatory settlement agreement with the SRA and the size of the fine reflects the fact that it was an alternative business structure, meaning the £25,000 limit on the SRA fines for traditional firms does not apply. The agreement said that,…

HSBC Targeted in Swiss Probe Linked to Ex-Lebanon Central Banker

HSBC Holdings Plc’s Swiss private bank is the focus of a Swiss investigation into suspected money-laundering connected to the alleged embezzlement of hundreds of millions of dollars by the former head of Lebanon’s central bank. Swiss federal prosecutors opened the probe in January into HSBC Private Bank (Suisse) SA, an unnamed individual and four other “unknown persons” in relation to the case, it said in a statement on Wednesday. It declined to comment further given the probe is ongoing. Since 2020, Swiss prosecutors have been investigating the case surrounding Riad Salameh, Lebanon’s former central bank governor, who was then charged…

Penalty issued for breach of Russia Sanctions

The Office of Financial Sanctions Implementation (OFSI) has imposed a £300,000 monetary penalty against Markom Management Limited (MML) for a breach of UK financial sanctions imposed against Russia following the 2014 annexation of Crimea. The breach relates to MML’s involvement in the making of a payment of £416,590.92 to a designated person, who remains subject to an asset freeze under current Russia sanctions. This payment was in breach of the UK sanctions in force at the time in response to Russia’s annexation of Crimea. MML gave instructions to make the payment from another company’s bank account with the knowledge that…

Bargain Hunt expert jailed for selling art to suspected Hezbollah financier

A former Bargain Hunt art expert has been jailed for two years and six months for failing to declare art he sold to a suspected financier of Hezbollah. In the first prosecution of its kind, Oghenochuko Ojiri, 53, admitted eight counts under the Terrorism Act 2000 of failing to make a disclosure during the course of business before his sentencing at the Old Bailey on Friday. Hezbollah is a group proscribed as a terrorist organisation by the UK.  Judge Mrs Justice Cheema-Grubb said Ojiri had been aware the art he had sold was to Nazem Ahmad, who had been sanctioned in 2019…

Czech bitcoin scandal sparks fears of state role in money laundering

PRAGUE – The Czech government is scrambling to contain the fallout from a €40 million bitcoin donation linked to a convicted drug trafficker, which forced Justice Minister Pavel Blažek to resign and triggered a National Security Council meeting over fears the state was used to launder criminal proceeds. Prime Minister Petr Fiala confirmed intelligence services would be involved, warning of new threats posed by cybercrime and the need for institutional resilience. “There is a publicly expressed suspicion that the state may have been misused through the justice ministry, possibly in connection with serious international crime,” Fiala said. The donation came…

FinCEN Issues Advisory Highlighting Iranian Oil Smuggling, Shadow Banking, and Weapons Procurement Typologies

Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is issuing an Advisory to assist financial institutions in identifying, preventing, and reporting suspicious activity connected to Iranian illicit financial activity, including oil smuggling, “shadow banking,” and weapons procurement. The Advisory replaces FinCEN’s 2018 Iran Advisory, which FinCEN is rescinding today. The Advisory supports the implementation of the U.S. maximum pressure campaign against Iran outlined in National Security Presidential Memorandum (NSPM-2) and provides updated red flags and information on current trends and typologies for Iranian sanctions evasion and other illicit activity. Concurrently, Treasury’s Office of Foreign Assets Control…

Environmental crimes are often hidden by ‘flying money’ laundering schemes (commentary)

In the Tang dynasty, Chinese merchants began buying rice on credit with a system that relied on trust and trade to sidestep the authorities — and taxes — to deliver goods immediately. In China it’s called, feiqian, and across the Middle East and South Asia, it’s known as hawala. These days it’s about more than rice. It’s called “flying money,” and it’s the tool for concealing financial crimes: tax-free remittances, washing dirty money, even funding terror and concealing wildlife crime. “Flying money is often used to denote Chinese money laundering or paying in-kind with a commodity instead of cash,” explains…

Man who tried to smuggle £1.2m in suitcases out of UK jailed

A man who tried to smuggle £1.2m in suitcases out of the United Kingdom to Lebanon has been jailed for 21 months, following a National Crime Agency investigation. Mazen Al Shaar custodyMazen Al Shaar, 48, was stopped by Border Force officers on Saturday 15 March this year as he was about to fly from Terminal Three at Heathrow Airport to Beirut in Lebanon. The supermarket worker, of Marsworth Close, Middlesex, said he only had £500 in cash on him and that he was leaving the UK to visit family. But officers searched his three suitcases and two of them contained…

OFAC Slaps $215 Million Penalty on GVA Capital for Russia Sanctions Violations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a hefty penalty of $215,988,868 against GVA Capital, a San Francisco-based venture capital firm. The firm is being held accountable for knowingly managing investments linked to Suleiman Kerimov, a Russian oligarch already under sanctions, and for failing to respond properly to an OFAC subpoena. This is a case that underscores the immense risks involved when gatekeepers like venture capital firms fail to uphold sanctions compliance. Between April 2018 and May 2021, GVA continued managing investments for Kerimov, after the Russian official had been added to the…

Alleged ‘Albanian Mafia Leader’ in Ecuador Accused of Laundering Cocaine Cash Via UAE Firm

An alleged Albanian cocaine kingpin based in Ecuador and arrested last week in the United Arab Emirates is accused of using the Middle Eastern country as a money laundering hub, according to court documents obtained by OCCRP. The documents come from a case in Ecuador, where Dritan Gjika is charged with leading a powerful drug trafficking organization. Gjika, 48, was arrested on May 26 in the UAE city of Abu Dhabi on an Ecuadorian warrant. In February, the State Attorney General’s Office named Gjika “the leader of Albanian mafia operations in Ecuador.” The court documents obtained by OCCRP reveal details…

EU Strengthens Financial Crime Fight with Updated High-Risk Country List

The European Commission is once again raising the stakes in the fight against financial crime by updating its list of high-risk countries. These jurisdictions, which exhibit significant gaps in their anti-money laundering (AML) and countering the financing of terrorism (CFT) frameworks, will now face increased scrutiny from EU financial institutions. In short, EU entities dealing with these countries will need to tread carefully, applying enhanced vigilance when engaging in financial transactions. The goal is simple: keep the EU’s financial system secure and ensure it doesn’t become a conduit for illicit activity. A closer look at the newly added names on…

Justice Department Resumes Foreign-Bribery Investigations with Focus on U.S. Competitiveness & National Security

The U.S. Department of Justice (DOJ) just announced that it will resume its foreign-bribery investigations, but with a narrowed focus aimed at protecting American businesses’ ability to compete on the global stage and safeguarding national security. This decision follows a four-month review prompted by an executive order from President Trump, which had paused such investigations earlier this year. Deputy Attorney General Todd Blanche made the announcement, according to the Wall Street Journal, revealing that nearly half of the ongoing Foreign Corrupt Practices Act (FCPA) cases would be closed to align with new enforcement guidelines. Under the revamped framework, investigations will…

EU Urged to Toughen Anti-Corruption Directive

Civil society groups are urging the European Union to adopt stronger anti-corruption measures as negotiations over the proposed EU Anti-Corruption Directive enter their final phase. An open letter released June 2 calls on EU leaders to show “genuine political will” and support the robust provisions already backed by the European Parliament. The directive aims to create a common framework for preventing and tackling corruption across member states and is now under negotiation between the Parliament and the Council of Ministers. The letter is backed by 57 organizations, including 23 national chapters and partners of Transparency International. Transparency International’s research highlights…

Cyprus Court Reinstates Abramovich-Linked Firm in VAT Probe

A Cypriot court this week ordered that a defunct company owned by sanctioned Russian billionaire Roman Abramovich’s offshore trust be reinstated so it can pay the 14 million euros in VAT it failed to pay before it was closed.. Blue Ocean Yacht Management Limited, BOYM, which operated for more than two decades before its dissolution last July, was ultimately owned by a Cyprus trust that benefited Abramovich. For more than a decade before it folded, Blue Ocean contested in court a 2012 order by Cyprus’ tax authority compelling the firm to pay the multimillion-euro tax bill. Details of the unpaid…

EU Cuts UAE From Money Watchlist, Flags Monaco

Two days after the European Commission overhauled its list of high-risk countries for money laundering, removing the United Arab Emirates (UAE) while adding several others, including Monaco, Lebanon, and Venezuela, a Member of the European Parliament said that the Parliament will examine the commission’s decision. “The members of the ECON committee will now engage with the Commission to clarify the evidence underlying the decisions for listing and de-listing of individual countries,” Markus Ferber, a German MEP with the European People’s Party (EPP) told OCCRP commenting on the updated list. “At this stage, it is too early to give a clear…

New Corporate Enforcement Policies Focus on Transparency & Cooperation in White-Collar Crime Cases

At the 2025 SIFMA Anti-Money Laundering and Financial Crimes Conference in Washington, D.C., Matthew R. Galeotti, the head of the U.S. Department of Justice’s Criminal Division, unveiled significant changes to the Department’s approach to white-collar crime enforcement. In his speech, Galeotti underscored a shift towards increased transparency and fairness for businesses, with an emphasis on self-reporting and cooperation in exchange for more predictable outcomes in investigations and penalties. The focus of these revisions, Galeotti explained, is to eliminate the punitive overreach that has historically deterred businesses from engaging in proactive compliance and reporting efforts. Highlighting the Department’s role in tackling…

Ex-Georgian Minister Detained in $920k Corruption Probe

A court in Tbilisi on Monday ordered two months of pre-trial detention for Georgia’s former deputy economy minister, who is accused of systematically abusing his position to amass more than 2.5 million lari (US$920,000) in illicit funds with the help of accomplice Some of the money he made this way was invested in property abroad, which he declared only after reporters uncovered it. Romeo Mikautadze, who served as Deputy Economy Minister, was arrested Friday evening by Georgia’s State Security Service (SSS). According to an official statement, Mikautadze allegedly used his position, connections, and experience for personal gain—providing unfair advantages to…

Italy Arrests 11 in €520m ‘Moby Dick’ VAT Fraud Case

Authorities in Italy have arrested 11 people suspected of laundering hundreds of millions of euros from a Europe-wide tax fraud scheme that exploited cross-border trade and relied on mafia-style protection. The suspects, detained in coordinated raids across Milan and Palermo, are accused of operating a criminal network behind what investigators call one of the most complex VAT fraud cases ever uncovered in the European Union. The operation, code-named Moby Dick, centers on a carousel scheme that used shell companies to move electronic goods — such as AirPods and laptops — across borders, issuing fake invoices worth more than €1.3 billion…

SFO Deepens Global Anti-Corruption Alliances with US & International Partners

SFO Joins Global Anti-Corruption Alliance: The Serious Fraud Office has become a member of the International Anti-Corruption Coordination Centre to strengthen its international enforcement capabilities.Enhanced Intelligence Access: Membership provides the SFO with greater access to intelligence on overseas corruption involving politically exposed persons and multinational firms.Autonomy Maintained: While collaborating internationally, the SFO will retain full control over its investigations.Part of Broader Strategy: The move follows the formation of a tri-national taskforce with France and Switzerland and updated corporate guidance on reporting misconduct.Proven Global Impact: Since 2017, the IACCC has helped identify over £1.8 billion in stolen assets and aided investigations…

UK Drops Sanctions on Controversial Serbian Arms Dealer

Three years after blacklisting him, the United Kingdom has lifted sanctions on Slobodan Tešić, one of the Balkans’ most powerful arms dealers, Serbian investigative outlet KRIK reported. Tešić remains under U.S. sanctions imposed in 2017 for alleged corruption and illegal arms deals. The British government did not disclose why it removed the restrictions against him last week. The arms dealer was added to the U.K. sanctions list in December 2022 for allegedly bribing Bosnian officials, including the late chief prosecutor Milorad Barašanin and former security minister Selmo Cikotić. The longtime arms broker has denied the accusations, calling them part of…

US Sanctions Myanmar Militia Tied to Cyber-Scams, Human Trafficking

The U.S. has slapped sanctions on a militia aligned with Myanmar’s ruling military junta, accusing the group of facilitating cyber-scam operations that have bilked billions from American victims over the past three years. The U.S. Treasury Department designated the Karen National Army (KNA) as a “transnational criminal organization” on Monday, and also sanctioned three of its leaders: Saw Chit Thu, and his two sons, Saw Htoo Eh Moo and Saw Chit Chit. The KNA runs a large territory on the frontier with Thailand that “is home to multiple cyber scam syndicates,” Treasury said in its announcement. The syndicates rely largely…

Julius Baer’s Fine in Money Laundering Case Compounds Legal Woes

(Bloomberg) — Julius Baer Group Ltd. has been ordered to hand over 4.4 million Swiss francs ($5.2 million) including confiscated profits linked to alleged failures in money laundering controls, in a fresh setback for the bank’s newly installed management team.The Zurich-based bank had been under investigation over transactions that had occurred between 2009 and 2019 and linked to operations in Monaco and Singapore, according to a person familiar with the matter.The previously undisclosed “enforcement proceeding” is separate to an existing Finma probe into losses linked to the Signa real estate empire, in which Baer was forced to write off $700…

US Lawmakers Pass Megobari Act Targeting Threats to Georgia’s Democracy

The U.S. House of Representatives has passed a bill authorizing sanctions against members of the Georgian government who pose a threat to the country’s stability, security, and democratic development. After Congress approved it on Monday, the bill — called the Megobari Act which means “friend” in Georgian — will now move to the Senate for debate and a vote. If approved in the Senate, it will be sent to U.S. President Donald Trump for final approval and signature into law. “The passage of the MEGOBARI Act sends a strong message to the Georgian people that the U.S. supports them as…

Man Sentenced to Over 30 Years in Prison for Crypto-Terror Financing Scheme

Defendant Collected and Sent More Than $185,000 to ISIS A Springfield, Virginia, man was sentenced yesterday to 364 months in prison for his efforts to provide material support to the Islamic State of Iraq and al-Sham (ISIS), a designated Foreign Terrorist Organization. According to court records and evidence presented at trial, from at least October 2019 through October 2022, Mohammed Azharuddin Chhipa, 35, collected and sent money to female ISIS members in Syria to benefit ISIS in various ways, including by financing the escape of female ISIS members from prison camps and supporting ISIS fighters. Chhipa would raise funds online…

EU Fraud Probe Nets 12 Arrests, €9.6M in Assets Seized

talian authorities arrested 12 people and seized more than 9.6 million euros ($10.9 million) in assets as part of a sweeping investigation into an alleged fraud scheme targeting European Union agricultural subsidies, officials said Wednesday. At the request of the European Public Prosecutor’s Office (EPPO) in Naples, the Financial Police (Guardia di Finanza) in Caserta carried out the arrests under an order from a judge at the Court of Salerno. The case centers on a suspected criminal network that allegedly defrauded the EU of more than 12.5 million euros ($14.2 million) in agricultural funds between 2018 and 2022. Prosecutors say…

FCA confiscates over £300,000 from convicted fraudsters

The FCA has secured confiscation orders of £305,284 against Raheel Mirza, Cameron Vickers and Opeyemi Solaja for their roles in an investment fraud. This amounts to all their remaining assets. The confiscation proceedings for Reuben Akpojaro have been adjourned to a later date. The money will be returned to investors at the earliest opportunity. Failure to pay can lead to imprisonment. Between June 2016 and January 2020, the defendants cold called people to convince them to invest in a shell company. They then claimed to trade their client’s money in binary options (a type of fixed odds financial betting) when…