Sanctions Space

Jessica Bartlett, Managing Director and Head of Global Financial Crime Legal at Barclays, shares her expertise on the rapidly changing sanctions landscape. She delves into how the sanctions environment has evolved over the last decade and the crucial connection between sanctions and export controls. Jessica emphasizes the need for a mindset shift in financial institutions to enhance compliance. She also discusses the role of technology in sanctions compliance, highlighting the need for collaboration between tech developers and compliance professionals.

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.

Toms Platacis, Head of the Financial Intelligence Unit (FIU) Latvia, and Paulis Iljenkovs, Deputy Head of FIU Latvia, share their expertise on sanctions enforcement in the EU. They emphasize the need for a strong deterrent against sanctions breaches, advocating for real convictions and hefty fines. The duo discusses Latvia's role as the national authority for sanctions, the complexities of compliance among industries, and the evolving landscape of financial intelligence units working together against sanctions evasion, particularly in the context of geopolitical tensions.

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.

'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

Peter Harrell, nonresident fellow specializing in US-China relations, discusses Russia sanctions, US-China relations in 2024, Capitol Hill priorities. Topics include potential frictions in US-China relations, Russia sanctions developments, and concerns about terrorism finance risks. The podcast explores efforts to prevent sanctions evasion, surprising responses to Russian sanctions, and upcoming events impacting the US-China relationship.

‘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