Mr. Watchlist’s DesigNation

OFAC issued a guidance document about the sanctions on Sudan last week - wouldn’t most of us know what those are? Then why did they issue it? Today’s episode talks about government statements and documents that seem to have a common theme: addressing how firms operate in the real world, where large-value fines grab attention and headlines.

We’re talking enforcement today - why did “An Individual” agree to a $5,000 penalty from OFAC? Wasn’t his disciplining by the US Army punishment enough? And what is General Factor J, and why is it important in this case?

Today the topic is secondary sanctions - what are they, and are the benefits outweighed by the downsides? Not such a simple question - sometimes, they achieve the objective and other times, they are counterproductive.

Today’s we’re using last week’s designations of the Xinjiang Production and Construction Corps (XPCC) (among others) by OFAC as the basis of a discussion about the use of asset freezes (as opposed to rejects or prohibitions) as an effective tool. I also muse about the kind of sanctions programs I’d like to see to replace the primary sanctions programs currently in place.

Today, I’ll discuss what we can learn from this week’s OFAC enforcement action against Whitford Worldwide.... plus ask you to think about the Congressional Report showing the sanctioned Rotenbergs buying 10s of millions in art.

Today we’re talking about the recent OFSI maritime shipping guidance, and why it would have been more useful had it incorporated more detailed information about evasion from real-world cases. And how it could have leveraged some of the detail from the March multiagency guidance issued in the US.