‘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...

‘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...

‘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...

‘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...

'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...

‘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...

‘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...

‘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...

‘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,...

‘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...

‘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...

‘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...

‘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...

‘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)...

‘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...

‘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'...

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...

“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...

‘’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...

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...

‘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...

‘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...

‘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,...