‘As the other core markets for Russia are closing down and tightening the grip, they’re looking for other mechanisms. And we may be seen as an easier mechanism because we haven’t had the benefit of the learnings of the European and the American banks, where they have been really having to grapple with this on a day-to-day basis. We’re now really having to turn our attention to that indirect risk.’ -Kylie Oliver on sanctions risks in Australia ‘We need to think about customers and markets that we may touch into from Australia. It’s a very different risk landscape - much more complex I’d suggest - than it may be in the Northern Hemisphere around this Russian sanctions issue.’ -Gavin Coles on sanctions risks in Australia In the latest episode of the Sanctions Space Podcast, Justine is joined by Gavin Coles, Global Sanctions Officer at OFX and Kylie Oliver, Senior Manager Enterprise Sanctions Compliance at ANZ. They discuss how industry in Australia is dealing with a complex global sanctions environment, how sanctions exposure can manifest itself in the region, and vulnerabilities to secondary sanctions risks.

‘there must a deterrent effect, that people must be afraid to breach sanctions, especially when it involves common high priority goods or items that generate a lot of revenue to the Russian government to wage war in Ukraine. By proper deterrent effect, I mean real convictions with proper jail times or very hefty fines levied against those who have been intentionally involved in breaching sanctions or have been grossly negligent’ -Paulis Iļjenkovs on strengthening sanctions enforcement in the EU In the latest episode of the Sanctions Space Podcast, Justine is joined by Toms Platacis and Paulis Iljenkovs, Head and Deputy Head of Financial Intelligence Unit (FIU) Latvia respectively. They discuss the sanctions enforcement landscape in Latvia, including the recent development of the FIU becoming the national competent authority – a ‘one-stop shop’ - for sanctions. They also discuss the exposure to Russia sanctions in the Baltics, the importance of awareness raising among industry, and the potential role AMLA could play in strengthening enforcement.

‘It’s one of the most important developments I think you’ll see coming out of the US in terms of sanctions enforcement, probably for years’ -John Smith on the extension of OFAC’s statute of limitations to 10 years for sanctions violations. In the latest episode of the Sanctions Space Podcast, Justine is joined by John Smith, co-head of Morrison Foerster’s National Security practice and former Director of OFAC, and Chloe Cina, Partner at Morrison Foerster. They discuss the evolving sanctions enforcement landscape (across both the US and Europe), the extension to 10 years for statute of limitations for sanctions violations in the US and the resulting impact for industry, and the potential sanctions implications of the upcoming US elections. John E. Smith, former Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), is co-head of Morrison Foerster’s National Security practice, and a member of the Crisis Management group and Investigations + White Collar group. After serving 11 years as a top official at OFAC and three years as its Director, Mr. Smith brings to the firm unmatched experience in economic sanctions, enforcement, and national security. Read John’s bio here:https://www.mofo.com/people/john-smith. Chloe Cina is a partner in the London office of Morrison Foerster with unrivalled experience in EU and UK economic sanctions and export control measures. She has nearly two decades of experience in litigating and advising on complex national security issues, both within government and in-house at two leading global financial institutions. Read Chloe’s bio here:https://www.mofo.com/people/chloe-cina.

‘We’ve got new legal powers which we will be using… but also the scale of how we’re operating has, for OFSI at least, changed. Both in terms of the volume of self-disclosures and other intelligence we’re getting from different sources… and secondly how capabilities at OFSI are changing and transforming.' -Giles Thomson on changes in the UK sanctions enforcement landscape In the latest episode of the Sanctions Space Podcast, Justine is joined by Giles Thomson, Director of the UK Office for Financial Sanctions Implementation. They discuss sanctions priorities for the UK government, the evolving enforcement landscape, and transatlantic cooperation between OFSI and OFAC Giles Thomson has been Director of the Office for Financial Sanctions Implementation (OFSI) since November 2020. He is also the senior official in HM Treasury responsible for economic crime policy and is the UK’s Head of Delegation to the Financial Action Task Force. He has been working on sanctions and economic crime within HM Treasury since 2016. Prior to that, Giles held a range of positions across HM Treasury and the Foreign, Commonwealth and Development Office.

'they have a critically important role to play. I think we’re at an inflection point… export controls have never been more important – and the reason why is because of the nature of the national security threat, which has really changed over the last decade or two.' -Assistant Secretary Axelrod on the importance of the role of financial institutions with respect to export controls. In the latest episode of the Sanctions Space Podcast, Justine is joined by Matthew Axelrod, Assistant Secretary for Export Enforcement at the Bureau of Industry and Security. They discuss the evolving role of export controls, ramping up engagement across government and industry, as well as both the significant enterprise risk export control violations can pose for organizations and the critical importance that industry meets the moment. Matthew S. Axelrod currently serves as the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security, a position to which he was unanimously confirmed by the United States Senate in December 2021. In this capacity, Matt leads a cadre of special agents and analysts dedicated to a singular mission – keeping the most sensitive technologies out of the world’s most dangerous hands. Read Matthew’s full bio here: https://www.commerce.gov/about/leadership/matthew-s-axelrod

‘The last time this was done - with Iraq - you had two things we’re not going to have here, which is number 1 a [UN] Security Council Resolution, and number 2 the consent of the government of Iraq. We are not getting either in the case of Russia, at least in the near term. And so the credibility of the international mechanism is going to be really important. And so I think it can be done but, look, everything is unprecedented until you do it the first time’. -David Mortlock on the likelihood of seeing Russian asset recovery In the latest episode of the Sanctions Space Podcast, Justine is joined by David Mortlock, Co-Chair of Global Trade & Investment Group, Managing Partner for Washington, DC at Willkie Farr & Gallagher. They discuss the changing sanctions enforcement landscape, the state of play regarding seizure and recovery of frozen Russian assets, and how we may see the oil price cap evolve in 2024. David Mortlock is Chair of Willkie’s Global Trade & Investment Practice Group and Managing Partner of the Washington office. David is formerly the Director for International Economic Affairs at the White House National Security Council, in which capacity he advised the President and his National Security Advisor on sanctions, corruption and other international finance and trade issues. Read David’s full bio here: https://www.willkie.com/professionals/m/mortlock-david

‘You’re not in this classic terror finance space where you are looking at a group like Al Qaeda and people trying covertly to move donations or other forms of money to terrorist groups who have no ability to raise money through conventional means.’ -Edmund Fitton-Brown In the latest episode of the Sanctions Space Podcast, Justine is joined by Edmund Fitton-Brown, Senior Advisor at the Counter Extremism Project and former UK Ambassador to Yemen. They discuss the ongoing tensions in the Red Sea, the political situation in Yemen and the origin and aspirations of the Houthi group, as well as sanctions actions taken by the US and others against the Houthis. Edmund Fitton-Brown is Senior Advisor at the Counter Extremism Project and holds advisory or fellowship positions with RUSI, the Middle East Institute, The Soufan Center and New America. Edmund’s former roles have included UK Ambassador to Yemen and being Coordinator of the UN ISIL/Al-Qaida/Taliban Sanctions Monitoring Team. Read Edmund’s bio here: https://www.rusi.org/people/fitton-brown

‘There are going to be frictions – I think what we can hope for is that both sides will try to figure out a way to just kind of manage through the bumps in the relationship, and so while there will be challenges, and while there will be bumps, at the strategic level the relationship will remain broadly stable – at least that’s the hope.’ -Peter Harrell on US-China relations in 2024 In the latest episode of the Sanctions Space Podcast, Justine is joined by Peter Harrell, nonresident fellow at Carnegie Endowment for International Peace and attorney. They discuss recent and anticipated Russia sanctions developments (including EO 14114, increasing focus on third countries, and price cap developments), what may be in store for US-China relations and export controls, and priorities on Capitol Hill for 2024. Peter E. Harrell is a nonresident fellow at the Carnegie Endowment for International Peace. He also serves as an attorney advising companies and investors on international legal, regulatory, and geopolitical risks. As a member of Carnegie’s American Statecraft program, Harrell’s research focuses on issues of U.S. domestic economic competitiveness, trade policy, and the use of economic tools in U.S. foreign policy. Among a number of previous senior roles, from January 2021 through 2022, Harrell served at the U.S. White House as Senior Director for International Economics, jointly appointed to the National Security Council and the National Economic Council. Read Peter’s bio at https://carnegieendowment.org/experts/2357

‘It’s the biggest deal. It’s the tip of the spear in the regulators effort to constrain Russia’s war ability’ -Melissa Duffy speaking about strategic trade and export controls In the latest episode of the Sanctions Space Podcast, Justine is joined by Melissa Duffy, Partner, Trade and National Security at Fenwick & West LLP. Speaking on the margins of the ACAMS Vegas conference, they discuss the increasing use of strategic trade controls and export controls in countering Russia and China, demystifying the HS codes identified by the US and its partners, and the growing expectations on financial institutions to be the ‘eyes and ears’ of sanctions and export controls compliance. Melissa focuses her practice on a broad range of international trade matters, including export controls, OFAC sanctions, regulation of emerging technologies, digital trade, CFIUS, tariffs and national security issues involving several U.S. agencies, both civil and criminal. She advises multinational companies across a wide range of sectors, including technology, financial, manufacturing, consumer goods, and energy. Melissa counsels clients on day-to-day compliance operations, and she advocates daily before the U.S. government, in coordinating meetings for clients with regulators, drafting requests for regulatory guidance, preparing export and sanctions license requests, advising on rulemakings, preparing commodity classification and jurisdiction requests, counseling on tariff strategies, and investigating and preparing complex voluntary disclosures. Read more here: https://www.fenwick.com/people/melissa-duffy

‘I think the risk is still high. It’s going to take some time for the Wagner Group’s new leaders to step into those roles… I still see the organization as a significant threat to international peace and stability’ In the latest episode of the Sanctions Space Podcast, Justine is joined by Jason Blazakis, Professor of Practice, Nonproliferation and Terrorism Studies; Director of Center on Terrorism, Extremism, and Counterterrorism at the Middlebury Institute of International Studies. Speaking on the margins of the ACAMS Vegas conference, they discuss the implications of recent Wagner Group developments – including its new leadership, strength, and relationship with the Russian government - and how we can counter the group’s ‘Swiss Army knife’ malicious activities, such as electoral interference, misinformation, and taking advantage of failing states. Jason Blazakis is a professor at the Middlebury Institute of International Studies (MIIS) where he focuses on threat financing, sanctions, violent extremism, and special operations related research. He is also the Director of MIIS’s Center on Terrorism, Extremism, and Counterterrorism where he directs research on domestic terrorism, terrorism finance, recruitment, propaganda, and the use of special operations to counter transnational threats. Read more here: https://www.middlebury.edu/institute/people/jason-blazakis

‘What we’re really seeing is the use of professional enablers, both by oligarchs to continue to hide their assets, and also in the export controls sanctions cases where they’re using shell corporations to hide the true shipment of goods’ In the latest episode of the Sanctions Space Podcast, Justine is joined by Jonathan Schnatz, Special Agent and Senior Analyst at the U.S. Internal Revenue Service, Criminal Investigation (IRS:CI). Speaking on the margins of ACAMS Europe conference, they discuss sanctions evasion trends, including how the IRS:CI targets professional enablers of financial crime, common tactics for avoiding export controls, and the critical importance of public-private information sharing and cooperation. Special Agent Jonathan Schnatz is a Senior Analyst with IRS Criminal Investigation. Jonathan chairs the IRS:CI Professional Enabler Group as part of the Joint Chiefs of Global Tax Enforcement (J5). The J5 is an alliance between the criminal tax authorities of Australia, Canada, Netherlands, United Kingdom, and United States focused on combatting transnational tax and financial crimes. The Enabler Group collaborates through sharing intelligence to identify and disrupt offshore service providers, promoters, and financial institutions facilitating financial crimes.

‘The amount of resources they have going into this is significant - there are people in every state in the country focused on this… and I expect you will see more and more actions as the year goes on’ -Craig Timm on looking to the horizon for DOJ on sanctions In the latest episode of the Sanctions Space Podcast, Justine is joined by Craig Timm, Senior Director of Anti-Money Laundering at ACAMS. They discuss key takeaways from the Global Sanctions Summit at ACAMS Hollywood, the role the US Department of Justice plays in the sanctions enforcement ecosystem, for example through fines and asset forfeiture, and how its focus is expected to evolve through increasing focus on enablers, ramping up of enforcement actions, and more. In Craig’s role at ACAMS, he oversees government, law enforcement, and private sector engagement in the United States and works to drive collaboration across the global anti-financial crime space. Prior to joining ACAMS, Craig had more than 15 years of anti-financial crime experience across the public and private sectors. At the Department of Justice, Craig served as a Deputy Chief in the Asset Forfeiture and Money Laundering Section (now Money Laundering and Asset Recovery Section) at headquarters in Washington, DC. In that role, he led a team of prosecutors responsible for enforcing criminal violations of the Bank Secrecy Act, U.S. economic sanctions, and money laundering laws committed by financial institutions and their employees. He led the prosecution of some of the largest financial institutions in the world including HSBC and BNP Paribas.

‘I always like to describe Congress as writing in pen, and the administration as writing in pencil’ In the latest episode of the Sanctions Space Podcast, Justine is joined by Matt Zweig, Senior Director of Policy at FDD Action. They discuss how sanctions are introduced within the US political system, who the key movers and shakers are, and looking ahead to future Congressional sanctions priorities. Previously, Matt served as Senior Fellow at the Foundation for Defense of Democracies. From July 2019 to December 2020, Matt served as the Senior Sanctions Advisor in the Office of the Special Representative for Syria Engagement. From 2001 to 2018, Matt served on the House Foreign Affairs Committee, including for more than 10 years as Senior Professional Staff, where he was responsible for sanctions and illicit finance policy. You can read Matt’s full bio here: https://www.fddaction.org/team/matt-zweig/

‘Unfortunately, I must say that you don’t have to be a criminal mastermind to come up with a sanctions evasion or circumvention scheme… most of the time, they’re not very sophisticated’ In the latest episode of the Sanctions Space Podcast, Justine is joined by Toms Platacis, Acting Head of Latvia’s Financial Intelligence Unit. They discuss current sanctions evasion typologies in Latvia – ranging from the sophisticated (dismantling range rovers into individual pieces and later reassembling) to the unsophisticated (smugglers violating sanctions by concealing cigarettes within timber, not realising the latter is prohibited). Toms and Justine also discuss how these risks will evolve, how sanctions can be strengthened at EU level, and what it has been like for Latvia to be on the frontlines of Russia sanctions implementation. Toms Platacis is Latvia’s Acting Head of Financial Intelligence Unit of Latvia (FIU Latvia) since June 2022. Toms previously was Deputy Head of the Financial Intelligence Unit of Latvia (FIU Latvia) since January2021, and prior to this he was leading Strategic analysis and Cooperation Coordination Division responsible for implementation of the Public-Private Partnership in the FIU Latvia. Toms contributes also as an evaluator to Moneyval/FATF peer reviews. His previous professional experience relates to several law firms, including Deloitte Legal, where he specialized in financial crime prevention and participated in several large-scale projects abroad.

‘We should not consider Wagner as a traditional mercenary group, but more as a powerful weapon used by Russia and we should all feel threatened by its expansion because it’s a rising global threat’ -Nathalia Dukhan on the threat posed by the Wagner Group In the latest episode of the Sanctions Space Podcast, Justine is joined by Nathalia Dukhan, Senior Investigator at The Sentry, and Naureen Chowdhury Fink, Executive Director of the Soufan Center. Their discussion takes a closer look at the Wagner Group, including how it contributes to regional insecurity and instability, its level of support and ongoing relationship with the Russian government, and how it uses gold, diamonds and other minerals to self-finance and evade sanctions. They also discuss the financial tools available to counter the Wagner Group, including financial sanctions and the possibility of designating Wagner as a Foreign Terrorist Organization. Nathalia Dukhan is a Senior Investigator at The Sentry, who works on the Central African Republic with a focus on the economic and financial drivers of sectarian violence. Nathalia, with last episode’s guest Justyna Gudzowska, recently published a Politico Opinion. Read that here: https://www.politico.com/news/magazine/2023/01/27/russia-wagner-ukraine-biden-terrorist-organization-00079799 Naureen Chowdhury Fink is the Executive Director of The Soufan Center. She previously served Senior Policy Adviser on Counterterrorism and Sanctions at the United Kingdom’s Mission to the United Nations, leading representation and negotiations in the Security Council and General Assembly. Prior to that, she has worked with UN Women and the UN Counter-Terrorism Executive Directorate (CTED). Read more here: https://thesoufancenter.org/team/naureen-chowdhury-fink/

‘As we look at Ukraine, as we look at these unprecedented sanctions, we really have to close the loopholes that are created by the Wagner Group’s presence in many countries around the world, in particular in Africa.’ The Sanctions Space Podcast is back! Justine is joined by Justyna Gudzowska, The Sentry, and Dan Tannebaum, Atlantic Council. Their discussion includes the illicit activities of the Wagner Group, the potential evolution of Russia sanctions, including possible 'skinny sanctions' and ‘freeze to seize’ measures, as well as looking ahead to key wider risks across 2023 Justyna Gudzowska serves as the Director of Illicit Finance Policy at The Sentry, an investigative and policy organization that follows the dirty money connected to African war criminals and transnational war profiteers and seeks to shut those benefiting from violence out of the international financial system. Daniel Tannebaum is a nonresident senior fellow at the Economic Statecraft Initiative of the Atlantic Council’s GeoEconomics Center and a partner in Oliver Wyman’s Risk and Public Policy Practice, where he leads the Anti-Financial Crime Practice for the Americas and serves as the firm’s global lead on sanctions. Read more at https://www.atlanticcouncil.org/expert/daniel-tannebaum/

ACAMS was honoured to be joined at our Europe conference by two advisors of the Office of the President of Ukraine - Professor Alexander Rodnyansky and Markiyan Kliuchkovskyi. In the margins of the event, Alexander and Markiyan sat down with Justine for this Sanctions Space Podcast Episode - their discussion includes the measures they're looking at to styme Russia's ability to fund its invasion, the weaponization of global food insecurity by Russia, and efforts being explored to use the assets of Russian oligarchs to support reconstruction of Ukraine. Alexander and Markiyan's full titles are as follows: -Professor Alexander Rodnyansky, Presidential Adviser and Member of the Dedicated Working Group, Sanctions Policy, Office of the President of Ukraine, Supervisory Board Member, The State Savings Bank of Ukraine -Markiyan Kliuchkovskyi, Advisor, Office of the President of Ukraine, Partner, Asters Law

“the oligarchs are symbolically important and also, if anybody is going to have an opportunity to whisper in the ear of Vladimir Putin and say ‘what you’re doing is completely wrong, completely inappropriate, unacceptable, you need to reverse what you’re doing’, it’s going to be one of those people. “ Following their appearance as witnesses to both the Treasury Select Committee and Foreign Affairs Committee earlier this week, Justine is joined by Tom Keatinge, founding Director of the Centre for Financial Crime and Security Studies at RUSI for this podcast episode. They discuss how to strengthen the effectiveness of sanctions on Russia, the challenge of international support for sanctions on Russian oil, and what may lie ahead in unchartered waters. Tom Keatinge is the founding Director of the Centre for Financial Crime and Security Studies (CFCS) at RUSI, where his research focuses on matters at the intersection of finance and security. He has a Master’s in Intelligence and International Security from King’s College London, where he studied the effectiveness of the global counterterror finance regime. Prior to joining RUSI in 2014, he was an investment banker for 20 years at J.P. Morgan. You can read Tom’s full bio here: https://rusi.org/people/keatinge

‘’In one week we have seen governments change their historical policy positions in what is really now being considered to be a watershed moment, particularly for defense policy.” In this episode, Justine is joined by Emily Rees, international trade policy expert and Founder, Trade Strategies, in which they discuss the enormous trade implications and challenges that will result from Russia’s invasion of Ukraine. Emily talks us through some of the key global exports and jurisdictions likely to be impacted, including the implications for major supply chain challenges as exports of essential materials used in the production of microchips, semiconductors, and other technology are disrupted, as well as the alarming prospect of heightened global food insecurity due to reductions in vital agricultural products such as wheat.

In this special episode, our two ACAMS podcasts meet for the second time - Financial Crime Matters and the Sanctions Space. Following conclusion of the second ACAMS Global Sanctions Summit, Justine and Kieran convene to discuss the current Russia-Ukraine crisis. Drawing on summit deliberations they explore the current state of play of the international sanctions response, including the prospect for a ‘start high, stay high’ approach.