
Economic Crime Law:
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Corruption Exposure Index 2026
…and reflections on financial crime indexes in the age of AI For decades, Transparency International’s Corruption Perceptions Index has been the preeminent comparative ranking of countries’ anti-corruption credentials. One widespread critique has been that the CPI consistently underestimates the role of Western financial centres in perpetuating large-scale corruption. For example, while you are unlikely to…
Can the US Lift Sanctions on Iran?
There is a remarkable amount of complexity in answering this simple question. The 14-point MOU published in the media provides for multiple sanctions-related concessions by the US: The Trump administration is briefing the press that sanctions will be lifted if Iran ‘behaves’. This is wrong in at least two respects: The rest of the sanctions…
Economic Complicity in International Crimes: Principles and High-Level Roadmap
Earlier this year, I had the opportunity to work on a project exploring the financial dimension of international crimes, i.e. war crimes, crimes against humanity, genocide and the crime of aggression. The project’s premise was that international crimes are big business, and generate a significant financial footprint, yet their financial disruption — and prosecution of…
Lord Leggatt’s Lament: Why the Dissent in Shvidler is Wrong
Eugene Shvidler is a British multi-billionaire of Russian origin. He is a friend of Roman Abramovich, formerly of Chelsea Football Club’s fame, and until March 2022 used to sit on the board of Evraz, a UK-listed company with subsidiaries all over the world, including Russia. Despite being a British citizen, Shvidler is now sanctioned by…
Will the Ukraine Special Tribunal Confiscate ‘Proceeds of Aggression’?
On 25 June, Ukraine and the Council of Europe signed an agreement establishing a Special Tribunal for the Crime of Aggression against Ukraine. Forming part of the agreement is the Statute that sets out the Special Tribunal’s powers, composition and key procedures. In light of the enormous damage that Russia’s aggression against Ukraine causes on…
Russia (Non) Sanctions Matrix
There are multiple databases or ‘trackers’ of Russia sanctions. They are important for compliance purposes and assessing the effect of sanctions. What is lacking is an accessible summary of sanctions that could be, but have not been, imposed on Russia. Such a resource could be a repository of ideas for Western governments to draw upon,…
Frozen Russian State Assets
The Key to Enforcing the Largest Financial Debt of Our Times? This post was first published on Verfassungsblog and is re-published with its kind permission. In February 2022, a coalition of states including all G7 economies froze approximately US$300 billion in Russian state assets. Those consist of foreign currency reserves accumulated by the Central Bank…
The Weird World of Receiving Payments from Sanctioned Persons in Australia
Two recent situations have prompted me to consider an issue I never focused on before: namely, the legality of receiving payments from — rather than making payments to — sanctioned persons in Australia. It has turned out to be a surprisingly interesting question. The first of the two situations involves the decision of the Australian…
US Tornado Cash Judgment: Baffling, and No One Knows What It Means
The extravaganza of extraordinary sanctions judgments continues. Last time, I considered the Federal Court’s unusually bold interpretation of Australian sanctions laws in the case involving a company partly owned by two sanctioned Russian oligarchs. Then, two weeks ago, the US Court of Appeals for the Fifth Circuit struck down US sanctions against Tornado Cash, a…
An Extraordinary Sanctions Judgment from Australia
There has been a great deal of anxiety across the ‘collective West’ about Russian sanctions evasion. Insofar as trade is concerned, the mechanics are very simple. Goods are first exported to a neighbouring country and then moved on to their ultimate destination in Moscow, Saint Petersburg or elsewhere. Hence plenty of charts about the spectacular…
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