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 - I’d love to see you there! Album art by Em Sohn (my youngest) - see


June 25, 2021 12 mins
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Episode 45 (“OFAC Gets an E for … Egregious?”) Show Notes

OFAC Enforcement Guidelines

SAP SE Enforcement Action

Nordgas S.r.l. Enforcement Action

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April 15, 2021 15 mins

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)


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April 7, 2021 9 mins

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

Nordgas OFAC Enforcement Action

UniControl OFAC Enforcement Action

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March 16, 2021 15 mins

Episode 42 (“Out of Control”) Show Notes

OFAC UniControl Enforcement Action

OFAC Enforcement Guidelines

OFAC Apollo Aviation Enforcement Action

OFAC British Arab Commercial Bank Enforcement Action


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February 28, 2021 11 mins

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

Treasury Press Release of February 26, 2021

State Department Press Release of February 26, 2021

Immigration and Nationality Act

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

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February 25, 2021 13 mins

Episode 40 (“Withholding Judgment”) Show Notes

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

CBP Withhold Release Orders and Findings

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February 21, 2021 11 mins

Episode 39 (“A Bit Much?”) Show Notes

BitPay, Inc, Enforcement Action

OFAC Enforcement Guidelines

BitGo Enforcement Action

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January 11, 2021 14 mins

Episode 38 (“Last Minute Reprieve”) Show Notes

Executive Order 13959

Frequently Asked Question 857

Frequently Asked Question 858

Frequently Asked Question 859

Frequently Asked Question...

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January 4, 2021 16 mins
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December 31, 2020 10 mins

Episode 36 (“Sanctions Clause Says: Do Not Pass, BitGo!”) Show Notes

OFAC Enforcement Information for December 30, 2020

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December 28, 2020 9 mins

Episode 34 (“Opening the Presents”) Show Notes


OFAC-based lists

Specially Designated Nationals and Blocked Persons List (SDN List)

Consolidated Sanctions List

State Department Lists


Cuba Restricted ...

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December 23, 2020 13 mins

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

OFAC Enforcement Information:

Berkshire Hathaway

Deutsche Bank Trust Company Americas

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


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December 20, 2020 15 mins

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

FinCEN Statement on Enforcement of the Bank Secrecy Act

FinCEN Assessment of Civil Monetary Penalty - Larry Dean Harmon

OFSI Enforcement Page

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December 15, 2020 14 mins
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December 10, 2020 13 mins

Episode 30 (“Bully Pulpit”) Show Notes

U.S. State Department Fact Sheet (“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”)

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December 6, 2020 10 mins

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

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

Department of Defense December 3, 2020 Press Release

OFAC 50 Pe...

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December 2, 2020 10 mins

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

Executive Order 13405 (Belarus Sanctions)

Executive Order 13667 (Central African Republic Sanctions(

Proclamation 8693 of July 24, 2011

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November 30, 2020 14 mins
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