Sanctions Space ACAMS

‘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 Financial Sanctions Implementation. They discuss sanctions priorities for the UK government, the evolving enforcement landscape, and transatlantic cooperation between OFSI and OFAC

Giles Thomson has been Director of the Office for Financial Sanctions Implementation (OFSI) since November 2020. He is also the senior official in HM Treasury responsible for economic crime policy and is the UK’s Head of Delegation to the Financial Action Task Force. He has been working on sanctions and economic crime within HM Treasury since 2016. Prior to that, Giles held a range of positions across HM Treasury and the Foreign, Commonwealth and Development Office.

'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

‘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 at Carnegie Endowment for International Peace and attorney. They discuss recent and anticipated Russia sanctions developments (including EO 14114, increasing focus on third countries, and price cap developments), what may be in store for US-China relations and export controls, and priorities on Capitol Hill for 2024.

Peter E. Harrell is a nonresident fellow at the Carnegie Endowment for International Peace. He also serves as an attorney advising companies and investors on international legal, regulatory, and geopolitical risks. As a member of Carnegie’s American Statecraft program, Harrell’s research focuses on issues of U.S. domestic economic competitiveness, trade policy, and the use of economic tools in U.S. foreign policy. Among a number of previous senior roles, from January 2021 through 2022, Harrell served at the U.S. White House as Senior Director for International Economics, jointly appointed to the National Security Council and the National Economic Council.

Read Peter’s bio at https://carnegieendowment.org/experts/2357

‘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