‘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

‘Looking at KYE (know your ecosystem), you’re able to essentially review the transaction that is not directly with you, and so you can see where the tokens are landing before potentially they’re going towards some sort of illicit flow or to an illicit actor.’

-Jasleen Bains on how to mitigate CTF risks

Recorded at ACAMS Las Vegas Assembly, in this latest episode of the Sanctions Space Podcast, Justine sat down with Jasleen Bains, Compliance Consultant, Ondo Finance and Founder, Bains Labs. They discuss the terrorism-financing landscape and how the illicit financial flows are evading sanctions, the evolution of crypto-related terrorist financing risks, and how regulations could be strengthened to make sanctions relating to crypto more effective.

Jasleen Bains on the Terrorism-Crypto-Sanctions Nexus

‘I believe that it’s become very complex for financial institutions to actually comply. The ask by the Treasury to focus on sanctions evasion is really, in many ways, the bridge back to AML’
-Bill Fox on the global sanctions landscape and what it means for FIs
 
‘The only sector that really can enforce [sanctions] are the financial institutions sector. We are the police – even though we say all the time in the AML world that we’re not the police – I think we are the police when it comes to sanctions’
-Rick Small on the global sanctions landscape and what it means for FIs

On the latest episode of the Sanctions Space Podcast, Justine sat down with AML legends Rick Small, Executive Vice President, Director Financial Crimes program at Truist and Bill Fox, former Managing Director Financial Crimes at Bank of America. They discuss the intersection and interlinkage between sanctions and AML, assessing sanctions risk in a complex environment, and how the effectiveness of sanctions frameworks could be improved.

AML Legends Talk Sanctions

‘Navigating the fault lines between the U.S. and China and this accelerated convergence of economic statecraft – not just how sanctions might be deployed, or export controls, but also tariffs and investment review – all of which are going to figure into this new space.’

-Elaine Dezenski on key risks to be thinking about


In the latest episode of the Sanctions Space Podcast, Justine is joined by Elaine K. Dezenski, senior director and head of the Center on Economic and Financial Power at the Foundation for Defense of Democracies. They discuss predictions for U.S. sanctions in 2025 under the new administration, including how sanctions may be positioned within a broader set of economic tools and economic statecraft, how global alliances may evolve, as well as how the U.S. and its partners can combat transnational kleptocracy.

Read Elaine’s bio here: Elaine K. Dezenski
https://www.fdd.org/team/elaine-dezenski/

Elaine Dezenski on U.S. Sanctions and Economic Statecraft in 2025

‘We’re living in an age of economic warfare. Sanctions, export controls, tariffs – they’re now the primary way that states compete with one another.’

In the latest episode of the Sanctions Space Podcast, Justine is joined by Edward Fishman, author of Chokepoints: American Power in the Age of Economic Warfare and a senior research scholar at the Center on Global Energy Policy, among other roles. They discuss the latest U.S. - Russia negotiation headlines, the importance of leveraging sanctions relief as a diplomatic carrot, how the use of tariffs in economic warfare is evolving, plus what may be next for U.S. sanctions on China and Iran.

Find out more about Edward’s new book here.
https://www.penguinrandomhouse.com/books/726149/chokepoints-by-edward-fishman/


Edward Fishman on the Age of Economic Warfare

‘I think that the administration is prudently reviewing the sanctions to determine what measures could be eased, in what sequence, in the event that Russia does prove amenable to negotiations. I, for my part, believe that we will have to go down the path of additional punitive measures first.’

-Marshall Billingslea on potential sanctions easing on Russia 

In the latest episode of the Sanctions Space Podcast, Justine is joined by Marshall Billingslea, Senior Fellow at the Hudson Institute. They discuss how the second Trump administration may be thinking about the use of sanctions and economic statecraft and what listeners should be prepared for. This includes the potential for relief - or indeed intensification - of U.S. sanctions on Russia, the increased use of tariffs, the restoration of maximum pressure against Iran, and how the administrations' fentanyl strategy is likely to play out.

Marshall Billingslea is a Senior Fellow at the Hudson Institute, prior to which he was the special presidential envoy for arms control at the US Department of State, holding the rank of ambassador. Before joining the State Department, Mr. Billingslea served as the assistant secretary for terrorist financing at the US Department of the Treasury, and in 2018, he was selected as president of the Financial Action Task Force (FATF).

You can read more about Marshall’s background here.
https://www.hudson.org/experts/1358-marshall-billingslea

Marshall Billingslea on U.S. Sanctions Policy and Priorities

‘As we start to piece this all together, we found that there were certain trends and typologies that were very similar in terms of how China was working with Russia, as well as how China was working with Iran, and then just kind of shaping out this broader network of actors.’

In the latest episode of the Sanctions Space Podcast – recorded at the ACAMS Hollywood Assembly - Justine is joined by Kimberly Donovan, director of the Economic Statecraft Initiative within the Atlantic Council’s GeoEconomics Center. They discuss geopolitical trends and the interrelation with sanctions compliance - including the emergence of an ‘axis of evasion’ network utilizing techniques such as barter trade to circumvent sanctions restrictions - and how modern financial crime fighters need to increase their understanding of the evolving geopolitical environment in order to build it into their programs.

Prior to joining the Atlantic Council, Kimberly served in the federal government for fifteen years, most recently as the acting associate director of the Financial Crimes Enforcement Network’s (FinCEN) Intelligence Division and FinCEN’s chief of staff and senior advisor to the director. 

Read Kimberly’s full bio here.
https://www.atlanticcouncil.org/expert/kimberly-donovan/

Kimberly Donovan on Geopolitics and the Emerging Axis of Evasion

On the margins of the ACAMS Hollywood Assembly, Justine sat down with Laura Ferris, The Sentry, to discuss illicit financial flows linked to environmental crime. Their discussion includes assessing the distinct overlap between environmental crime, sanctions, and corruption, as well as a spotlight on the illegal logging trade – including how funds are laundered, the current state of global action to address the trade, and how organizations should think about their related supply chain risk.

Laura Ferris is Senior Policy Advisor, Illegal Logging at The Sentry. Find out more here.
https://thesentry.org/about/

Laura Ferris on Sanctions, Corruption, and Illegal Logging

At the ACAMS Europe Assembly in Paris, Justine sat down with Stephanie Baker, Senior Writer, Bloomberg. Their discussion includes how Russia has exploited loopholes to circumvent sanctions and export controls and continue financing its war, how Russia’s wartime economy may impact peace negotiations, and how the new economic tool of ‘secondary tariffs’ could potentially play out.

Stephanie recently published a book titled ‘Punishing Putin: Inside the Global Economic War to Bring Down Russia’. You can find further details here: Punishing Putin — Stephanie Baker | Writer & Journalist https://stephaniebakerwriter.com/punishing-putin

Stephanie Baker on Punishing Putin

At the ACAMS Las Vegas Assembly, Justine sat down with Alex Zerden, Capitol Peak Strategies. Their discussion covers a range of U.S. sanctions priorities, including significant action undertaken on both drug cartels and Iran, easing measures on Syria, and the implications of a U.S.-backed stablecoin.

Alex Zerden is the Founder and Principal of Capitol Peak Strategies, a risk advisory firm based in Washington, DC. Capitol Peak works with leading financial institutions, companies and organizations to navigate emerging technologies, financial regulation, and economic crisis. 

Alex Zerden on the Middle East, Crypto, Cartels and Changing U.S. Priorities

At the ACAMS Las Vegas Assembly, Justine sat down with Carole House, Senior Distinguished Fellow, ACAMS. Their discussion includes the AFC implications of generative artificial intelligence, including increasing sophistication of deepfakes and the resulting  ‘authenticity crisis’, how we can build resilience to the threat, and trends in cyber-enabled sanctions evasion.

Carole House recently joined ACAMS as a Senior Distinguished Fellow. Among Carole’s many prominent and senior roles, she previously served as the White House National Security Council (NSC) special advisor for cybersecurity and critical infrastructure policy.

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

Sanctions Space

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