‘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

‘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/