New article out…

If you’re an ACAMS member, you can read it in ACAMS Today. If you’re not, a PDF is in the Publications page here.

The subject: comparing the standards of ownership in OFAC’s Barclays and Halliburton enforcement actions – and why it’s OK they’re so different.

The title? How Low Can You Go?

Would appreciate some feedback, of course.

Hope you find it educational.

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