Mr. Watchlist’s DesigNation Eric A. Sohn

I know it’s been a while… today’s episode is about the OFAC Chinese Military Companies Sanctions program, how it confused a whole lot of us, and how the new Executive Order (14032) makes it a lot easier to understand, and comply with.

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…

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.

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!

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.

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.