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
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
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)
Dire...
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
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...
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...
Episode 40 (“Withholding Judgment”) Show Notes
U.S Customs and Border Protection (CBP) Forced Labor Enforcement Fact Sheet
CBP Withhold Release Orders and Findings
https://www.cbp.gov/trade/programs-administration/forced-labor/withhold-release-orders-and-findings
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
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...
Episode 37 (“Trust, but Verify”, Revisited) Show Notes
General License INT/2020/059 Publication Notice
General License INT/2020/059
The Russia (Sanctions) (EU Ex...
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
Episode 35 (“How the Sausage Gets Made”) Show Notes
Executive Order 13959
Public Law 105-261 (NDAA FY1999)
https://www.govinfo.gov/content/pkg/PLAW-105publ261/html/PLAW-105publ261.htm
Public Law 106-398 (NDAA FY2001)
https://www.govinfo.gov/content/pkg/PLAW-106publ398/html/PLAW-106publ398....
Episode 34 (“Opening the Presents”) Show Notes
OFAC-based lists
Specially Designated Nationals and Blocked Persons List (SDN List)
Consolidated Sanctions List
https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list-data-files
State Department Lists
Cuba Restricted ...
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
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
OFSI Enforcement Page
Episode 31 (“Turkey on the Menu”) Show Notes
Monday, December 13, 2020 OFAC Notice
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20201214_33
State Department Fact Sheet
Non-SDN Menu-Based Sanctions List page
https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list/non-sd...
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...
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
OFAC 50 Pe...
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
Episode 27 (“OFAC Sanctions from A to Z: Belarus”) Show Notes
Executive Order 13405
https://home.treasury.gov/system/files/126/13405.pdf
Belarus Sanctions Regulations
Belarus General License 2-G
Episode 26 (“Hup, Two, Three, Four!”) Show Notes
Executive Order 13959
https://home.treasury.gov/system/files/126/13959.pdf
Chinese Military Companies Sanctions page
Executive Order 13936
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