Sanctions Space ACAMS

‘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/