‘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.

“we should acknowledge the simple fact that, in economic terms, Russia matters much more to the EU than it does to the US, and that the EU matters to Russia much more than the US does to Russia.” In this episode, Justine is joined by George Voloshin, corporate intelligence expert and ACAMS CGSS instructor, in which they discuss Russian-EU trade and considerations for entities with Russian exposure. George provides a detailed overview of the dynamics of Russia and the EU’s economic relationship, including energy dependency, and talks to the difficulties of ascertaining ownership and control and conducting due diligence on high profile Russian business people of corporations, as well as what companies need to think about to prepare for a potential worst-case scenario. George is the Head of Paris Branch, Aperio Intelligence, having joined the firm in December 2016. Prior to joining Aperio, George headed the Russia/CIS coverage at a leading French corporate intelligence firm and previously collaborated with a number of UK-based advisory and analytical organisations as well as government clients. He is the author of two books on the geopolitics of Central Asia and over a hundred articles on international affairs, with a focus on Russia and the former Soviet Union which are the primary areas of his specialisation. You can read George’s full bio at: https://www.aperio-intelligence.com/team/george-voloshin/

‘Diplomacy is not dead, but significant differences remain… and Russia’s intentions vis-à-vis Ukraine still remain clear. That means the path of deterrence, the path of economic sanctions, remains highly relevant’. In this episode, Justine is joined by Maria Shagina, Visiting Research Fellow, Finnish Institute of International Affairs, where they discuss the state of play for diplomatic efforts between Russia and the West, considerations to keep in mind should the situation escalate further, and how the sanctions options being considered differ between the US and the EU. Dr Maria Shagina is a Visiting Fellow at the Center on US Politics and Power at the Finnish Institute of International Affairs (FIIA) and a member of the Geneva International Sanctions Network at the Graduate Institute, Geneva. Her research interests cover economic statecraft, international sanctions and energy politics, with a particular focus on the post-Soviet states. Her research on Russia sanctions has been cited in The New York Times, Washington Post, and Financial Times, among others. Before joining FIIA, Maria was a postdoctoral fellow at the Center for Eastern European Studies (CEES) at the University of Zurich. You can read Maria’s full bio at: https://www.fiia.fi/en/expert/maria-shagina

‘humanitarian groups cannot be expected to provide assistance in these complex areas without some risk… we have to accept that this is a situation where you cannot eliminate risk, it has to be managed’ In this episode, Justine is joined by Sue Eckert, Senior Associate (Non-resident), Humanitarian Agenda, Center for Strategic and International Studies, where they discuss United Nations Security Council Resolution 2615, including the complexity involved in passing the Resolution and significance it has for processing payments into Afghanistan. Justine and Sue also discuss the dire situation on the ground in Afghanistan, and next steps for the international community to ensure the successful flow of vital assistance. Sue has formerly served as assistant secretary of commerce for export administration responsible for dual-use export control and sanctions policies, and was a former staff member of the House of Representative's Committee on Foreign Affairs. Sue is also a co-chair of the humanitarian workstream of the ACAMS International Sanctions Compliance Task Force. You can read Sue’s full bio at: https://www.csis.org/people/sue-eckert

‘there’s never been a situation, of which I’m aware, in which an entity like the Taliban…are designated, and have long since been designated, and now are controlling an entire country’ In this episode, Justine is joined by Adam M. Smith, Partner, Gibson Dunn, to talk about the humanitarian situation in Afghanistan, including the implications from the Central Bank funds being frozen, to what extent sanctions in place affect the government, recently introduced Afghanistan General Licenses, and the options available to the international community to ensure the movement of permissible humanitarian funds. Adam is a partner in the Washington, DC office of Gibson Dunn. He is an experienced international lawyer with a focus on international trade compliance and white collar investigations and has previously served as the Senior Advisor to the Director of OFAC and as the Director for Multilateral Affairs on the National Security Council. Adam also recently spoke to the US Senate Committee on Banking, Housing and Urban Affairs Committee at a hearing on ‘Afghanistan’s Future: Assessing the National Security, Humanitarian and Economic Implications of the Taliban Takeover’. You can view the hearing here: https://www.banking.senate.gov/hearings/afghanistans-future-assessing-the-national-security-humanitarian-and-economic-implications-of-the-taliban-takeover Read Adam’s full bio at https://www.gibsondunn.com/lawyer/smith-adam-m/

In this episode, Justine is joined for the second time by Dr. Hans-Jakob Schindler, Senior Director of the Counter Extremism Project, to talk about the ongoing situation in Afghanistan, including the Taliban’s revenue streams (such as the drug trade), the relationship with Al Qaeda and other terrorist groups, and the potential implications for sanctions, foreign investment, and international recognition deliberations. Hans was formerly Coordinator of the ISIL (Da’esh), al-Qaida and Taliban Sanctions Monitoring Team of the United Nations Security Council, where he briefed the members of the Security Council on the global terrorism threat and was responsible for the development of global counter terrorism sanctions. You can read Hans’s full bio at www.linkedin.com/in/hansjakobschindler.

‘we’ve entered a great power competition, that’s not between two blocs… but rather between two very highly integrated economic spheres’ In this episode of the Sanctions Space podcast, Justine sits down with Jonathan Hackenbroich, European Council on Foreign Relations (ECFR), to discuss economic coercion in the geo-political landscape, building resilience to sanctions and countersanctions, and why Nord Stream 2 is like a suitcase without a handle – hard to take along, hard to abandon. Jonathan Hackenbroich is a policy fellow for economic statecraft and the head of ECFR’s Task Force for Protecting Europe from Economic Coercion. His work for ECFR’s European Power programme focuses on economic coercion and geo-economics, especially sanctions policy. He is also an expert on German foreign policy. Read Jonathan’s full bio here: https://ecfr.eu/profile/jonathan_hackenbroich/

‘The use of sanctions has grown incredibly, the complexity of sanctions, the reach of US person globally, the use of secondary sanctions – these are all elements which have just escalated continually over recent years, and that has resulted in some pushback from other jurisdictions’ In this special episode, our two ACAMS podcasts meet - Financial Crime Matters and the Sanctions Space. Justine and Kieran discuss the unprecedented scale and pace of change of sanctions in 2020, key trends we are likely to see in the sanctions space over the coming year, and the Biden administration’s potential approach to key regimes such as China, Iran, and North Korea. Interested to learn more about Sanctions? Join our Global Sanctions Summit next week: https://www.acams.org/en/events/conferences/sanctions-space-summit

‘prepare for some very difficult times ahead, where the world’s number one and number two economies – when it comes to the US and China – will continue to fundamentally disagree on certain issues…. and that will continue to play a role in US sanctions response’ In this episode, Justine is joined by Jennifer Fowler, Director, Brunswick Group, and John Smith, Partner, Morrison and Foerster, to talk about US presidential transition, fighting illicit finance in the FATF, and words of wisdom for the upcoming global sanctions landscape. You can read Jennifer’s bio here: https://www.brunswickgroup.com/jennifer-fowler-i8218/, and John’s bio here: https://www.mofo.com/people/john-smith.html

‘we’re really at a point where we are saying – what are sanctions really? What do they actually do? They’re somewhere between a serious finger wag… and a financial hand-grenade’ In this episode, Justine is joined by Julia Friedlander, C. Boyden Gray Senior Fellow and Deputy Director, GeoEconomics Center, Atlantic Council, to talk about the risks arising from Russian dark money, the interplay between sanctions and other tools of economic statecraft, and what it’s like to work in the White House. You can read Julia’s bio here: https://www.atlanticcouncil.org/expert/julia-friedlander/

‘the rise of ISIL was a real turning point on global counter terrorism, only maybe eclipsed by 9/11' In this episode, Justine is joined by Dr. Hans-Jakob Schindler, Senior Director of the Counter Extremism Project, to talk about counter terrorism sanctions, the rise of ISIL (including lessons we can learn from it) and the wider impact of global terrorism. Hans was formerly Coordinator of the ISIL (Da’esh), al-Qaida and Taliban Sanctions Monitoring Team of the United Nations Security Council, where he briefed the members of the Security Council on the global terrorism threat and was responsible for the development of global counter terrorism sanctions. You can read Hans’s full bio at https://www.linkedin.com/in/hansjakobschindler.