Mr. Watchlist’s DesigNation

Mr. Watchlist’s DesigNation

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/

Episodes

May 6, 2021 11 min

Episode 45 (“OFAC Gets an E for … Egregious?”) Show Notes

OFAC Enforcement Guidelines

https://home.treasury.gov/system/files/126/fr74_57593.pdf

SAP SE Enforcement Action

https://home.treasury.gov/system/files/126/20210429_sap.pdf

Nordgas S.r.l. Enforcement Action

https://home.treasury.gov/system/files/126/20210326_nordgas.pdf

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Episode 44 (“Everything but the Kitchen Sink”) Show Notes

Executive Order on Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation (unnumbered as of April 15, 2021)

https://www.whitehouse.gov/briefing-room/presidential-actions/2021/04/15/executive-order-on-blocking-property-with-respect-to-specified-harmful-foreign-activities-of-the-government-of-the-russian-federation/

Dire...

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April 7, 2021 9 min

Episode 43 (“The Other Shoe Drops”) Show Notes

Nordgas OFAC Enforcement Action

https://home.treasury.gov/system/files/126/20210326_nordgas.pdf

UniControl OFAC Enforcement Action

https://home.treasury.gov/system/files/126/20210315_uc.pdf
 

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March 16, 2021 15 min

Episode 42 (“Out of Control”) Show Notes

OFAC UniControl Enforcement Action

https://home.treasury.gov/system/files/126/20210315_uc.pdf

OFAC Enforcement Guidelines

https://home.treasury.gov/system/files/126/fr74_57593.pdf

OFAC Apollo Aviation Enforcement Action

https://home.treasury.gov/system/files/126/20191107_apollo.pdf

OFAC British Arab Commercial Bank Enforcement Action

https://home.treasury.gov/system/files/126/20190917_bacb.pdf

OFAC C...

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February 28, 2021 11 min

Episode 41 (“Hold Your Friends Close...”) Show Notes

Treasury Press Release of February 26, 2021

https://home.treasury.gov/news/press-releases/jy0038

State Department Press Release of February 26, 2021

https://www.state.gov/accountability-for-the-murder-of-jamal-khashoggi/

Immigration and Nationality Act

https://www.uscis.gov/laws-and-policy/legislation/immigration-and-nationality-act

Department of State, Foreign Operations, and Related P...

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February 25, 2021 13 min

Episode 40 (“Withholding Judgment”) Show Notes

U.S Customs and Border Protection (CBP) Forced Labor Enforcement Fact Sheet

https://www.cbp.gov/sites/default/files/assets/documents/2016-Aug/Fact%20Sheet%20-%20Forced%20Labor%20Procedures.pdf

CBP Withhold Release Orders and Findings

https://www.cbp.gov/trade/programs-administration/forced-labor/withhold-release-orders-and-findings

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February 21, 2021 11 min

Episode 39 (“A Bit Much?”) Show Notes

BitPay, Inc, Enforcement Action

https://home.treasury.gov/system/files/126/20210218_bp.pdf

OFAC Enforcement Guidelines

https://home.treasury.gov/system/files/126/fr74_57593.pdf

BitGo Enforcement Action

https://home.treasury.gov/system/files/126/20201230_bitgo.pdf

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January 11, 2021 14 min

Episode 38 (“Last Minute Reprieve”) Show Notes

Executive Order 13959

https://home.treasury.gov/system/files/126/13959.pdf

Frequently Asked Question 857

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/857

Frequently Asked Question 858

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/858

Frequently Asked Question 859

https://home.treasury.gov/policy-issues/financial-sanctions/faqs/859

Frequently Asked Question...

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January 4, 2021 16 min
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Episode 36 (“Sanctions Clause Says: Do Not Pass, BitGo!”) Show Notes

OFAC Enforcement Information for December 30, 2020

https://home.treasury.gov/system/files/126/20201230_bitgo.pdf

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December 28, 2020 9 min

Episode 34 (“Opening the Presents”) Show Notes


 

OFAC-based lists
 

Specially Designated Nationals and Blocked Persons List (SDN List)

https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists

Consolidated Sanctions List

https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list-data-files
 

State Department Lists

 

Cuba Restricted ...

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December 23, 2020 13 min

Episode 33 (“Topping Off 2020 Hindsight”) Show Notes
 

OFAC Enforcement Information:

Berkshire Hathaway

https://home.treasury.gov/system/files/126/20201020_berkshire.pdf

Deutsche Bank Trust Company Americas

https://home.treasury.gov/system/files/126/20200909_DBTCA.pdf

Amazon.com

https://home.treasury.gov/system/files/126/20200708_amazon.pdf

OFAC Encourages Persons to communicate compliance concerns related to COVID-19

https://home.treasury.g...

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December 20, 2020 15 min

Episode 32 (“2020 Hindsight: Bottom’s Up”) Show Notes

FinCEN Statement on Enforcement of the Bank Secrecy Act

https://www.fincen.gov/sites/default/files/shared/FinCEN%20Enforcement%20Statement_FINAL%20508.pdf

FinCEN Assessment of Civil Monetary Penalty - Larry Dean Harmon

https://www.fincen.gov/sites/default/files/enforcement_action/2020-10-19/HarmonHelix%20Assessment%20and%20SoF_508_101920.pdf

OFSI Enforcement Page

https://www.gov.uk/go...

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December 15, 2020 14 min
December 10, 2020 13 min

Episode 30 (“Bully Pulpit”) Show Notes

U.S. State Department Fact Sheet (“U.S. Investors are Funding Malign PRC Companies on Major Indices”)

https://www.state.gov/u-s-investors-are-funding-malign-prc-companies-on-major-indices/

Executive Order 13959 (“Addressing the Threat From Securities Investments That Finance Communist Chinese Military Companies”)

https://www.federalregister.gov/documents/2020/11/17/2020-25459/addressing-the-threat...

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December 6, 2020 10 min

Episode 29 (“Mr. Watchlist’s Nightmare”) Show Notes

Executive Order 13959 (“Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companes”)

https://home.treasury.gov/system/files/126/13959.pdf

Department of Defense December 3, 2020 Press Release

https://www.defense.gov/Newsroom/Releases/Release/Article/2434513/dod-releases-list-of-additional-companies-in-accordance-with-section-1237-of-fy/

OFAC 50 Pe...

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December 2, 2020 10 min

Episode 28 (“But You Can’t Stay Here”) Show Notes

Executive Order 13405 (Belarus Sanctions)

https://home.treasury.gov/system/files/126/13405.pdf

Executive Order 13667 (Central African Republic Sanctions(

https://home.treasury.gov/system/files/126/car_eo.pdf

Proclamation 8693 of July 24, 2011

https://www.federalregister.gov/documents/2011/07/27/2011-19155/suspension-of-entry-of-aliens-subject-to-united-nations-security-council-travel-bans...

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November 30, 2020 14 min
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