The home for financial crime analysis and commentary. Mostly focused on economic sanctions, with anti-money laundering, export control and anti-bribery and corruption sprinkled in from time to time - it’s 15 minutes or less of your day to get a fresh perspective on current events and how they impact the bigger picture in business (and geopolitics, too!).
If you hunger for even more news about financial crime, you can always come over to MrWatchlist.com - I’d love to see you there!
Album art by Em Sohn (my youngest) - see https://www.sohnillustration.com/
OFAC Gets an E for… Egregious?
So, SAP got slapped on the wrist with a $2.1 million dollar fine for some pretty reckless behavior. And it was larger than the $1.3 million base penalty - but OFAC called the violations non-egregious. Huh?
Turns out that OFAC defines what makes a violation egregious - so, let’s look at it, and compare what SAP did to, say, Nordgas S.r.l. did. Here’s a hint: Nordgas’ violations were considered egregious.
As always, I have thoughts on all this…
Everything But the Kitchen Sink
Today, an extensive Executive Order greatly expanded the potential sanctions on the Russian government, its companies and its people. The E.O. also centralized sanctions that had existed elsewhere, like the cyber sanctions and the foreign election interference sanctions. And that has some real advantages.
Listen to what was in today’s action, and what I think about it.
The Other Shoe Drops
We now know who one of UniControl’s European trade partners were... and they were bad, bad partners (at least from a compliance perspective). But, we can now reconsider the UniControl enforcement action in a fresh light - and actually learn something useful!
Out of Control
Monday’s OFAC enforcement action against UniControl? Good idea, poor execution. Would a reasonable person have connected the dots the way OFAC seems to expect? Hmmm... listen and decide for yourself.
Keep Your Friends Close...
The US released a report on the 2018 murder of Jamal Khashoggi by Saudi Arabian operatives on Friday, blaming “MBS”, the Crown Prince. And visa restrictions under the Immigration and Nationality Act were imposed on 76 Saudis, and a former official and the Rapid Intervention Force were sanctioned by OFAC - but no actions were taken against MBS himself. What’s up with that? Listen to this episode to hear what I think of it.
Something a little off the beaten path today... welcome to Withhold Release Orders, or WROs, something that the US does to bar certain imports from entering the country. They were in the news last year because some were issued for goods coming from the Xinjiang region of China ... maybe that will give you a hint what WROs are used for...
Excellent commentary by Eric! Really enjpy his insights on the complex topic of sanctions.
Saskia Rietbroek, Executive Director, Association of Certified Sanctions Specialists.