Sanctions Space

Marshall Billingslea, a Senior Fellow at the Hudson Institute and former U.S. government envoy, shares his insights on U.S. sanctions policy. He discusses the potential easing of sanctions on Russia amid negotiation hopes, but believes punitive measures may come first. The conversation highlights the shift towards tariffs and maximum pressure against Iran. Billingslea also touches on the administration's strategic focus on fentanyl trafficking and drug cartels, emphasizing the need for nuanced economic statecraft and global financial security.

‘We’re living in an age of economic warfare. Sanctions, export controls, tariffs – they’re now the primary way that states compete with one another.’ In the latest episode of the Sanctions Space Podcast, Justine is joined by Edward Fishman, author of Chokepoints: American Power in the Age of Economic Warfare and a senior research scholar at the Center on Global Energy Policy, among other roles. They discuss the latest U.S. - Russia negotiation headlines, the importance of leveraging sanctions relief as a diplomatic carrot, how the use of tariffs in economic warfare is evolving, plus what may be next for U.S. sanctions on China and Iran. Find out more about Edward’s new book here. https://www.penguinrandomhouse.com/books/726149/chokepoints-by-edward-fishman/

Elaine Dezenski, a senior director at the Foundation for Defense of Democracies, shares her insights on the future of U.S. sanctions and economic strategies. She delves into U.S.-China relations, geopolitical challenges, and the need for stronger global alliances to combat authoritarian influences. Additionally, she discusses the evolving landscape of anti-corruption efforts and how sanctions play a critical role in this new Cold War dynamic. Dezenski’s expertise sheds light on the complexities and opportunities that lie ahead.

‘I believe that it’s become very complex for financial institutions to actually comply. The ask by the Treasury to focus on sanctions evasion is really, in many ways, the bridge back to AML’ -Bill Fox on the global sanctions landscape and what it means for FIs ‘The only sector that really can enforce [sanctions] are the financial institutions sector. We are the police – even though we say all the time in the AML world that we’re not the police – I think we are the police when it comes to sanctions’ -Rick Small on the global sanctions landscape and what it means for FIs On the latest episode of the Sanctions Space Podcast, Justine sat down with AML legends Rick Small, Executive Vice President, Director Financial Crimes program at Truist and Bill Fox, former Managing Director Financial Crimes at Bank of America. They discuss the intersection and interlinkage between sanctions and AML, assessing sanctions risk in a complex environment, and how the effectiveness of sanctions frameworks could be improved.

‘Looking at KYE (know your ecosystem), you’re able to essentially review the transaction that is not directly with you, and so you can see where the tokens are landing before potentially they’re going towards some sort of illicit flow or to an illicit actor.’ -Jasleen Bains on how to mitigate CTF risks Recorded at ACAMS Las Vegas Assembly, in this latest episode of the Sanctions Space Podcast, Justine sat down with Jasleen Bains, Compliance Consultant, Ondo Finance and Founder, Bains Labs. They discuss the terrorism-financing landscape and how the illicit financial flows are evading sanctions, the evolution of crypto-related terrorist financing risks, and how regulations could be strengthened to make sanctions relating to crypto more effective.

‘We’re all going to be on this journey, I don’t think we’re going to be in a world where no one’s going to use AI because it’s too hard, we are going to use it, the question is how do we make sure to implement it and execute it so that it’s efficient and credible’. -Jessica Bartlett In the latest episode of the Sanctions Space Podcast, Justine is joined by Jessica Bartlett, Managing Director and Head of Global Financial Crime Legal at Barclays. They discuss how the global sanctions landscape has changed over the past decade, how to think about the interlinkage between sanctions and export controls, and how financial institutions need to undertake a mindset shift to strengthen sanctions compliance.

Gavin Coles, Global Sanctions Officer at OFX, and Kylie Oliver, Senior Manager of Enterprise Sanctions Compliance at ANZ, dive into Australia’s unique sanctions landscape. They explore how indirect risks are evolving as other markets tighten sanctions on Russia. Kylie highlights the growing complexities that Australian organizations face, while Gavin calls for a strategic approach to navigate the intricate risk landscape. The conversation emphasizes the need for effective data management and proactive compliance to avoid vulnerabilities connected to secondary sanctions.

‘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.

John Smith and Chloe Cina discuss the extended statute of limitations for sanctions violations, potential impacts for industry, and the upcoming US elections in the evolving sanctions enforcement landscape. They explore compliance strategies, EU enforcement harmonization, trade impacts, and the influence of future US presidencies on sanctions.

Giles Thomson, Director of OFSI, discusses the UK's sanctions priorities and enforcement landscape. They explore transatlantic cooperation, regulatory collaboration, preventing sanctions evasion, and the importance of public-private collaboration for effective sanctions compliance.