Crypto, Front Companies and Sanctions Evasion: The NCA’s $5.2 Million Forfeiture

On 27 August 2026, the National Crime Agency (NCA) announced that ENEX Premium Trading Limited had agreed to forfeit more than $5.2 million (£3.84 million) following a civil recovery investigation into suspected money laundering and sanctions evasion. The agreement closes proceedings arising from an NCA investigation into the source of funds held in UK accounts controlled by the company.

ENEX Premium Trading Limited describes itself as an agricultural trading and logistics company involved in the handling, transportation and financing of grains, oilseeds and oilseed meals. The company is owned by Azerbaijani national Nadir Valiyev and is registered in St Kitts and Nevis. Between July and September 2024, significant sums were transferred into newly opened UK accounts held by ENEX. When opening those accounts, Mr Valiyev stated that the source of the funds was his personal wealth and retained earnings from previous trading businesses, including UAE-registered Burston Trading FZE.

In November 2024, the NCA obtained an Account Freezing Order over funds held in ENEX's UK accounts while it investigated the provenance of the money following reports published in 2024 alleging that companies associated with Mr Valiyev had been involved in the shipment of stolen Ukrainian grain. 

During its investigation, the NCA identified what it described as a network of suspected front companies and bank accounts used to facilitate transactions through UK Electronic Money Institutions before converting funds into cryptocurrency. The agency traced the frozen funds to bank accounts in China held by ENEX, which had reportedly processed tens of millions of pounds from suspected front companies between July and September 2024.

The NCA further stated that a number of entities making payments into ENEX's Chinese accounts were subsequently designated under US sanctions for allegedly facilitating illicit Iranian oil sales and revenue generation and for sending funds to the Iranian Qods Force. On the basis of its investigation, the NCA suspected that the funds subject to the Account Freezing Order represented the proceeds of money laundering.

As part of the resolution, ENEX and Mr Valiyev agreed to forfeit the funds. However, Mr Valiyev has denied engaging in criminal activity.

The case represents a further example of the NCA's bold use of its civil recovery powers to target suspected money laundering and sanctions evasion, including where funds have moved through complex international corporate and financial structures. This result builds on the NCA’s precedent-setting outcome in NCA v Aven in which the NCA secured the first recovery of sanctioned funds under the Proceeds of Crime Act 2002. For those operating in or advising on cross-border trade, commodity finance and digital asset markets, the case carries a clear message: the NCA is actively scrutinising complex international fund flows, particularly where they intersect with sanctions risk, cryptocurrency and opaque corporate structures. It is prepared to act swiftly against well-resourced and sophisticated opponents using its civil powers to freeze and forfeit assets suspected to represent the proceeds of crime.

The Burges Salmon asset recovery team has extensive experience advising on the complex intersection of POCA, sanctions and digital assets. If you would like to discuss any issues or themes arising from this development, please contact Rhiannon Price and Eve Jenkins.