Seize & Desist

Jason Sandoval speaks with Jonathan Benton, former Head of the UK's Int. Corruption Unit at the National Crime Agency and now CEO and Founder of Intelligent Sanctuary, about the gap between criminal efficiency and institutional deliberation, and what it takes to close it in digital asset recovery. They discuss how immutable on-chain markers are used to identify wallet holders and support compliance with FATF's recommendations, as well as the legal questions being tested in court cases like Tulip, D'Aloia and Jones.

Seize & Desist speaks to practitioners across asset recovery, investigators, policymakers and people building tools in the field. No guest pays to appear, and nothing mentioned, including any tools or technology discussed, is endorsed or commercially connected to Asset Reality.

⏱️ Timestamps
01:30 – Jonathan’s years in law enforcement
14:45 – marking stolen crypto to identify wallet holders
19:00 – on-chain movement vs wallet attribution
28:45 – legal questions raised by Tulip, D'Aloia and Jones
33:45 – on-chain marking and FATF compliance
45:00 – building the International Anti-Corruption Coordination Centre

👤 About Our Guest
Jonathan Benton is CEO and Founder of Intelligent Sanctuary. He spent 30 years in UK law enforcement as a Detective Superintendent and the Head of the NCA's International Corruption Unit, leading some of Britain’s most complex corruption cases, including the Ibori case, the OPL 245 oil block scandal, and the case against the former Nigerian petroleum minister, as well as designing the International Anti-Corruption Coordination Centre.

🔑 Key Takeaways
Agility Is the Real Gap
Criminals move faster than institutions because nobody makes them fill out a form first. Procurement and policy cycles lag years behind criminal adoption of new tools.
On-Chain Visibility Isn't Attribution
Standard blockchain analytics show what happened on-chain, not who controls the wallet behind it. Closing that gap is what makes recovery possible.
Immutable Markers Turn Flags Into Evidence
A wallet marked with a police reference number, visible on any blockchain explorer and removable only by investigators, gives exchanges something concrete to act on.
Courts Are Setting the Rules Case by Case
Tulip, D'Aloia and Jones are testing a different legal questions, from exchange liability to service by NFT, shaping how digital asset recovery works in practice.

📚 Resources Mentioned
Jonathan Benton on LinkedIn: https://www.linkedin.com/in/jonathanbenton
Intelligent Sanctuary: https://isanctuary.io
Cambridge Int. Symposium on Economic Crime: https://www.crimesymposium.org

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⚠️ Disclaimer
Our podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making any decisions on the topics being discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

What happens to a seized mafia asset after the headlines fade? Dr Amber Phillips, Senior Lecturer in Criminology at UWE Bristol, has spent her career chasing that answer, starting with fieldwork in Calabria alongside anti-mafia organisations working to strip the 'Ndrangheta of its assets and its grip on local communities.
She joins Jason Sandoval to unpack her 'Beyond the Figures' research with financial investigators across England and Wales and the gap between headline recoveries and what practitioners count as success. Amber argues for a fifth 'D', Destination, alongside disruption, disentitlement and deterrence, and previews her new NCA/Home Office study, funded through the Asset Recovery Incentivisation Scheme (ARIS), on whether asset recovery genuinely deters crime.

⏱️ Timestamps
02:00 – Amber's route into asset recovery via Calabria
08:45 – how mafia power works and what asset recovery undermines
14:00 – the GOEL social reuse model in Calabria
17:50 – proposing a fifth D: destination as a measure of success
21:00 – Beyond the Figures
29:45 – how ARIS funding actually works

👤 About Our Guest
Dr Amber Phillips is a Senior Lecturer in Criminology at UWE Bristol, specialising in organised and economic crime. Her career began in Calabria with anti-mafia organisations and she now leads a new NCA/Home Office study examining whether asset recovery genuinely deters crime.

🔑 Key Takeaways
Numbers Do Not Tell the Story
Amber's research with financial investigators found headline figures often miss the disruption and investigative quality practitioners value most.

Destination Deserves Its Own D
Amber proposes adding Destination to the existing framework of disruption, disentitlement, deterrence and detection.

Low Value Orders Can Outperform High Value Ones
A small seizure from an early-stage offender can disrupt a criminal career as effectively as a six-figure one further down the line.

ARIS Funding Shapes Investigator Behaviour
How ARIS returns are split between confiscation and forfeiture orders can push investigators toward the more lucrative route, not the more powerful one.

📚 Resources Mentioned
Dr Amber Phillips on LinkedIn
Bristol247 on the NCA/Home Office study
Seize & Desist E32 with Sal Melki, NCA
Seize & Desist E35 with Oliver Bullough

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⚠️ Disclaimer
Our podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making any decisions on the topics being discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

Oliver Bullough has written three books on how dirty money moves around the world. His single biggest finding is so low-tech it almost sounds like a joke. Jason Sandoval, former DEA special agent and Asset Reality’s Head of European Operations, spent thirty years chasing the same problem. One investigated it, the other wrote about it. Together, they unpack why the global system for tackling money laundering is not working and what it would take to build something that does.

⏱️ Timestamps
02:30 – Money laundering as a meta-crime
13:00 – Carousel fraud and what a mission-led response looks like
24:00 – High-denomination banknotes and who is actually using them
29:30 – Operation Destabilise and cash-for-crypto
35:00 – Political will vs operational realities
40:10 – Asset recovery as a fourteen-point swing
42:20 – Oliver’s prescription

👤 About Our Guest
Oliver Bullough is an award-winning journalist and author of Moneyland, Butler to the World, and Everybody Loves Our Dollars. He has spent his career mapping how dirty money moves globally, writing for The Guardian, The New York Times, GQ, and The Economist. This is his second appearance on Seize and Desist.

🔑 Key Takeaways
Criminals Go Where Defences Are Weakest: As banks tightened controls, criminal wealth moved to crypto and trade finance, which remain vastly under-regulated.

Carousel Fraud Shows What Works: The UK’s near-complete defeat of carousel fraud shows what happens when intelligence, law enforcement and legislation pull together with a shared mission.

High-denomination Banknotes Undermine Everything: Fewer than 15% of US transactions are now done in cash, yet demand for $100 bills keeps rising. Central banks are printing them without asking where the demand is coming from.

Asset Recovery Is a Fourteen-Point Swing: Taking assets from criminals degrades their capability and improves law enforcement’s at the same time.

Political Will Is the Missing Variable: Every intervention Oliver identifies is achievable. The barrier is the political will to confront the interests of those with wealth to hide.

📚 Resources Mentioned
Everybody Loves Our Dollars by Oliver Bullough: https://amzn.eu/d/06emtzVh
Butler to the World by Oliver Bullough: https://amzn.eu/d/gaqVRE9
Moneyland by Oliver Bullough: https://amzn.eu/d/ezB43Rv
Oliver Bullough on The Guardian: https://www.theguardian.com/profile/oliverbullough
Seize & Desist Episode 19 with Oliver Bullough: https://link.cohostpodcasting.com/d9980f5e-8a52-48d5-a31b-0ecfe2a3cc89?d=eJs8ymAzD&v=8112

📬 Stay Connected
If you found this episode useful, make sure you:
Subscribe to Seize & Desist wherever you listen
Follow Asset Reality on LinkedIn and X for updates, resources, and future episodes
Share this episode with colleagues working in asset recovery, investigations, or financial crime

⚠️ Disclaimer
Our podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making any decisions on the topics being discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

Jill Thomas speaks with Tristram Hicks about why cash seizure is one of the most powerful tools available to law enforcement and what it takes to build asset recovery systems that deliver at scale. As one of the lead practitioners behind the UK's Proceeds of Crime Act and an international capacity building adviser, Tristram explains what turns legislation into results, why financial DNA changes how investigators approach every crime, and what FATF's new asset recovery guidance means for practitioners worldwide.

⏱️ Timestamps
00:05 – Introductions
01:41 – POCA: from dozens of cases to 5000+ a year
11:45 – The cash seizure spark that changed UK practice
16:12 – Incentivisation and why recycling assets changes minds
23:10– Financial DNA: every financial transaction leaves a trace
27:30 – How things used to be vs what we should be working towards
33:20 – The need for statistics in asset seizure
37:30 – The importance of cross agency reporting systems
40:30 – Magic wand: bring cash seizure powers inland

👤 About Our Guest
Tristram Hicks is the author of The War on Dirty Money and one of the most experienced asset recovery practitioners working internationally today. He spent ten years at the centre of the UK's Proceeds of Crime Act implementation, leading operational financial investigation teams at Scotland Yard while helping shape national policy. He has since worked across Europe, the Balkans, and beyond, advising governments on how to build asset recovery systems that deliver results in practice.

🔑 Key Takeaways
Cash Seizure Is the Catalyst
Extending powers from the border inland transformed UK practice. Most jurisdictions have the same dormant authority available today.

Incentivisation Makes Legislation Work
The UK's Proceeds of Crime Act succeeded because it built an implementation committee and recycled confiscated proceeds back to the agencies doing the work. Once the financial incentive was in place, national volumes grew 14-fold.

Financial DNA Is Everywhere
Every financial transaction leaves a trace connecting people to people, places, and money.

Embed Financial Investigators at the Front Line
Working alongside criminal investigators from the point of arrest is what converts law into seizures. Parallel structures are far more effective than isolated ones.

📚 Resources Mentioned
The War on Dirty Money by Tristram Hicks | Amazon
Tristram Hicks on Substack
Tristram Hicks on LinkedIn
Tristram’s Critique of the FATF Guidance
FATF Guidance on Asset Recovery
EU Asset Recovery Directive (2024)
CARIN network

📬 Stay Connected
If you found this episode useful:
Subscribe to Seize & Desist wherever you listen
Follow Asset Reality on LinkedIn for updates, resources, and future episodes
Share this episode with those working in asset recovery, investigations or financial crime

⚠️ Disclaimer
Our podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making decisions on the topics discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

Aidan Larkin speaks with Tara Kavanaugh, a federal investigator with the U.S. Postal Inspection Service (USPIS) and liaison to the FBI's dark‑web opioid task force. Tara draws on a career spanning HUMINT work in the Middle East, signals intelligence at the NSA and crypto‑enabled investigations at USPIS to explain how modern crime moves across the mail system, the dark web, and digital‑asset ecosystems. She outlines the realities of mail‑based fraud, fentanyl supply chains, dark‑web vendor activity, and the growing “scamdemic,” while highlighting how postal data and blockchain analytics help identify offenders. They also discuss inter‑agency collaboration, investigative tooling and why asset recovery remains central to disrupting harm.

⏱️ Timestamps
00:00 – Early Career & Intelligence Background
04:40 – USPIS Crypto Investigations
06:45 – FBI Liaison Role & Dark‑Web Opioid Task Force
12:50 – Using Postal Intelligence to Strengthen Federal Cases
15:30 – Blockchain Tracing Patterns, Playbooks & Criminal Methods
21:45 – Agency Readiness, SOPs & Evolving Crypto Capabilities
25:45 – Crypto ATMs, Victim Risks & the Growing “Scamdemic”
32:40 - The Modern Investigator’s Toolkit & Global Collaboration

👤 About Our Guest
Tara Kavanaugh is a federal investigator at the U.S. Postal Inspection Service (USPIS) and liaison to the FBI’s Joint Dark‑Web and Opioid Task Force. Her career has spanned HUMINT operations in conflict zones, counterintelligence work at the NSA, dark‑web investigations targeting fentanyl vendors, and blockchain‑based tracing of narcotics proceeds and scam activity. Tara works across local, state, federal, and international partners like Europol to disrupt digital‑asset–enabled crime.

🔑 Key Takeaways
Asset Recovery Is Not Peripheral
From fentanyl vendors to terrorist financing, taking the money disrupts crime faster than arrests.

Inter‑Agency Collaboration Works When Data Flows
USPIS, FBI, Europol, and others share seized server data to proactively identify vendors and cases. USPIS postal metadata, label history, and mail‑stream analytics give investigators visibility that other agencies don’t have.

Crypto ATMs Are a Major Scam Vector
Elderly victims are overwhelmingly targeted, and the machines provide deceptive legitimacy.

Blockchain Tools Have Improved Dramatically
What once required hours of manual tracing now surfaces automatically across chains.

📚 Resources Mentioned
9CRC on Youtube
Europol's Project A.S.S.E.T
Alison Jimenez on Seize & Desist
Rich Lebel on Seize & Deist
Operation Shamrock
Asset Reality's FCA Approval

📬 Stay Connected
If you found this episode useful, make sure you:
Subscribe to Seize & Desist on Apple Podcasts, Spotify, or wherever you listen
Follow Asset Reality on LinkedIn for updates, resources, and future episodes
Share this episode with those working in asset recovery, investigations or financial crime

⚠️ Disclaimer
Our podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making decisions on the topics discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material. The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.