‘It’s one of the most important developments I think you’ll see coming out of the US in terms of sanctions enforcement, probably for years’
 
-John Smith on the extension of OFAC’s statute of limitations to 10 years for sanctions violations.


In the latest episode of the Sanctions Space Podcast, Justine is joined by John Smith, co-head of Morrison Foerster’s National Security practice and former Director of OFAC, and Chloe Cina, Partner at Morrison Foerster. They discuss the evolving sanctions enforcement landscape (across both the US and Europe), the extension to 10 years for statute of limitations for sanctions violations in the US and the resulting impact for industry, and the potential sanctions implications of the upcoming US elections.
 
John E. Smith, former Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), is co-head of Morrison Foerster’s National Security practice, and a member of the Crisis Management group and Investigations + White Collar group. After serving 11 years as a top official at OFAC and three years as its Director, Mr. Smith brings to the firm unmatched experience in economic sanctions, enforcement, and national security. Read John’s bio here:https://www.mofo.com/people/john-smith.
 
Chloe Cina is a partner in the London office of Morrison Foerster with unrivalled experience in EU and UK economic sanctions and export control measures. She has nearly two decades of experience in litigating and advising on complex national security issues, both within government and in-house at two leading global financial institutions. Read Chloe’s bio here:https://www.mofo.com/people/chloe-cina.

John Smith and Chloe Cina on the Sanctions Enforcement Landscape

‘there must a deterrent effect, that people must be afraid to breach sanctions, especially when it involves common high priority goods or items that generate a lot of revenue to the Russian government to wage war in Ukraine. By proper deterrent effect, I mean real convictions with proper jail times or very hefty fines levied against those who have been intentionally involved in breaching sanctions or have been grossly negligent’
 
-Paulis Iļjenkovs on strengthening sanctions enforcement in the EU

In the latest episode of the Sanctions Space Podcast, Justine is joined by Toms Platacis and Paulis Iljenkovs, Head and Deputy Head of Financial Intelligence Unit (FIU) Latvia respectively. They discuss the sanctions enforcement landscape in Latvia, including the recent development of the FIU becoming the national competent authority – a ‘one-stop shop’ - for sanctions. They also discuss the exposure to Russia sanctions in the Baltics, the importance of awareness raising among industry, and the potential role AMLA could play in strengthening enforcement.

Toms Platacis and Paulis Iljenkovs on Countering Sanctions Evasion

‘As the other core markets for Russia are closing down and tightening the grip, they’re looking for other mechanisms. And we may be seen as an easier mechanism because we haven’t had the benefit of the learnings of the European and the American banks, where they have been really having to grapple with this on a day-to-day basis. We’re now really having to turn our attention to that indirect risk.’
 
-Kylie Oliver on sanctions risks in Australia
 
‘We need to think about customers and markets that we may touch into from Australia. It’s a very different risk landscape - much more complex I’d suggest - than it may be in the Northern Hemisphere around this Russian sanctions issue.’
 
-Gavin Coles on sanctions risks in Australia

In the latest episode of the Sanctions Space Podcast, Justine is joined by Gavin Coles, Global Sanctions Officer at OFX and Kylie Oliver, Senior Manager Enterprise Sanctions Compliance at ANZ.  They discuss how industry in Australia is dealing with a complex global sanctions environment, how sanctions exposure can manifest itself in the region, and vulnerabilities to secondary sanctions risks.

Gavin Coles and Kylie Oliver on the Australian Sanctions Perspective

‘We’re all going to be on this journey, I don’t think we’re going to be in a world where no one’s going to use AI because it’s too hard, we are going to use it, the question is how do we make sure to implement it and execute it so that it’s efficient and credible’.

-Jessica Bartlett

In the latest episode of the Sanctions Space Podcast, Justine is joined by Jessica Bartlett, Managing Director and Head of Global Financial Crime Legal at Barclays. They discuss how the global sanctions landscape has changed over the past decade, how to think about the interlinkage between sanctions and export controls,  and how financial institutions need to undertake a mindset shift to strengthen sanctions compliance.

Jessica Bartlett on Adapting to Evolving Sanctions Risks

‘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

Sanctions Space

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