‘there’s never been a situation, of which I’m aware, in which an entity like the Taliban…are designated, and have long since been designated, and now are controlling an entire country’
 
In this episode, Justine is joined by Adam M. Smith, Partner, Gibson Dunn, to talk about the humanitarian situation in Afghanistan, including the implications from the Central Bank funds being frozen, to what extent sanctions in place affect the government, recently introduced Afghanistan General Licenses, and the options available to the international community to ensure the movement of permissible humanitarian funds.
 
Adam is a partner in the Washington, DC office of Gibson Dunn. He is an experienced international lawyer with a focus on international trade compliance and white collar investigations and has previously served as the Senior Advisor to the Director of OFAC and as the Director for Multilateral Affairs on the National Security Council. 
 
Adam also recently spoke to the US Senate Committee on Banking, Housing and Urban Affairs Committee at a hearing on ‘Afghanistan’s Future: Assessing the National Security, Humanitarian and Economic Implications of the Taliban Takeover’. You can view the hearing here: https://www.banking.senate.gov/hearings/afghanistans-future-assessing-the-national-security-humanitarian-and-economic-implications-of-the-taliban-takeover
 
Read Adam’s full bio at https://www.gibsondunn.com/lawyer/smith-adam-m/

Adam M. Smith on Afghanistan Humanitarian Considerations

‘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/

Matt Zweig on the Dynamics of US Congressional Sanctions Policy

‘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.

Craig Timm on the Role of the US Department of Justice in Strengthening Sanctions

‘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.

Jonathan Schnatz on the IRS:CI and Countering Sanctions Evasion

‘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

Jason Blazakis on the Future of the Wagner Group

‘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

Melissa Duffy on Strategic Trade and Export Controls

‘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

Peter Harrell on Global Sanctions in 2024

‘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

Edmund Fitton-Brown on Yemen and the Houthis

‘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

David Mortlock on Sanctions Enforcement and Asset Recovery

'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

Matthew S. Axelrod on the Critical Importance of Export Controls

‘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.

Adam M. Smith on Afghanistan Humanitarian Considerations

Sanctions Space

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