USA – NEW YORK Trends and Developments Contributed by: Jilan J. Kamal, Michelle Ben-David and Laszlo Herwitz, Herbert Smith Freehills Kramer
to conspiring to violate foreign corruption laws and manipulating oil prices in 2022. Meanwhile, in March 2025, the EDNY created a Trans - national Criminal Organizations Strike Force and has brought several cases against individuals accused of money laundering on behalf of such criminal enter - prises. In February 2025, for example, the EDNY charged Alain Bibliowicz Mitrani with conspiracy to commit money laundering and conspiracy to operate an unlicensed money transmitting business. Mitrani is accused of running a scheme to launder more than USD300 million for individuals affiliated with cartels and other TCOs, including the Sinaloa cartel, through a network of shell companies. The EDNY has also brought at least three additional cases against drug traffickers accused of money laundering, among other crimes. Given the EDNY’s long-time reputation as a leader in organised crime prosecutions, it seems likely that it will be a leader in the Trump administration’s focus on prosecuting cartels and transnational crimi - nal organisations for financial crimes. The EDNY has also pursued prosecutions for sanc - tions violations. In April 2025, the EDNY charged Hossein Akbari, Reza Amidi, and Iran-based Rah Roshd Company with conspiring to procure parts for Iranian unmanned aerial vehicles on behalf of the Ira - nian Revolutionary Guard Corps, in violation of US export control laws, as well as engaging in money laundering through their use of shell companies to hide the funds used to purchase the drone parts. In statements accompanying the charges, prosecutors emphasised the importance of preventing the use of American intellectual property and technology by hos - tile regimes. In June 2025, the EDNY charged Iurii Gugnin, founder of Evita Investments and Evita Pay with money laun - dering, fraud, and violations of the International Emer - gency Economic Powers Act, in connection with his alleged role in laundering more than USD500 million through the US financial system on behalf of sanc - tioned Russian entities. Gugnin was also accused of helping export sensitive technology to Russia in vio - lation of export control laws. In a statement accom - panying the indictment, US Attorney for the Eastern District, Joseph Nocella Jr, emphasised that Gugnin’s
activities both threatened the integrity of the US finan - cial system and harmed national security. Whether under an FCPA, sanctions, or bribery and money laundering regime, it is expected that EDNY and SDNY prosecutors will focus on foreign bribery and transnational crime that tangibly harms US gov - ernmental or corporate interests. Financial institutions and other gatekeepers of the US financial system may be caught up in these investigations for wittingly or unwittingly facilitating or enabling these offences. It is therefore also expected that federal prosecutors will increase scrutiny of financial institutions and their compliance with regulations intended to detect these types of offences. Public benefits fraud As part of its emphasis on American economic secu - rity at the federal level, the May 2025 Galeotti Memo - randum announced that, going forward, there would be an increased focus on fraud impacting government programmes. As part of these efforts, the DOJ co- ordinated the 2025 National Healthcare Fraud Take - down, a combined effort across federal prosecutors’ offices and state and local law enforcement. In New York, this initiative resulted in multiple indict - ments in the EDNY in June 2025 of 15 individuals on charges including healthcare fraud, wire fraud, and unlawful monetary transactions. Collectively, the indictments allege that these individuals conspired to fraudulently bill Medicare and Medicaid for more than USD10.6 billion. Meanwhile, in June 2025, the SDNY charged Dr Ali Rashan with five counts of fraud for allegedly submitting fraudulent billing to insurance companies for USD24 million worth of COVID-19 tests that were never performed. While that initiative focused on fraud perpetrated by individuals, the SDNY has also demonstrated that it will continue to pursue corporate healthcare fraud cases. In April 2025, the SDNY announced that it had reached a USD202 million settlement with Gilead Sci - ences to resolve allegations that the company violat - ed the False Claims Act (FCA) and the Anti-Kickback Statute (AKS). Gilead had been accused of paying healthcare providers more than USD23.7 million in honoraria, free food, and drinks as part of the compa -
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