How the Sausage Gets Made looks at the new NS-CCMC List published Monday by OFAC as an example of how, when they are new and different from the vast majority of sanctions programs, OFAC has to course correct and fill in some of the blanks left by Executive Orders, legislation and guidance.
Honestly, some of the changes are pretty welcome… but also beg the question: why isn’t this kind of stuff (like listing securities issues) not done more broadly? And why is the list not part of the Consolidated Sanctions List?
Happy New Year, everyone! You name your podcast service, we’re there… hope you enjoy it!