Published Articles

The new article is about the OFAC enforcement action against Kollmorgen Corporation, why the settlement amount was so large compared to the base penalty amount, and what more Kollmorgen could have done.

And I threw in a little snide remark at the end about the AppliChem action – although that was before I figured out that the EU Blocking Statute probably was part of the calculus in that case….

Let me know if you like that one, too…


OFAC Settlements: When Good Intentions Aren’t Enough

The article, which went up today at Regulation Asia’s website, talks about the COSL Singapore and CSE TransTel enforcement actions, as well as the recent designation of persons, companies and cargo vessels involved in trade with North Korea.

Amusingly enough, the title they originally used (which I did not provide) was “OFAC Highlights Chinks in Singapore’s Sanctions Regime” – really. 

The article, in PDF form, is on the Publications page – a web link is below.


OFAC Highlights Potential Gap in Singapore’s Sanctions Regime

Yesterday, the first of a 2-part series I wrote on the latest FATF/APG report on financial flows in human trafficking was published here on Originally, I wrote it as one longer piece, but KYC360 liked the idea of two shorter pieces better. You can get to the article also on the Publications page – and I’ll post when the 2nd part comes out.

Appreciate any feedback, of course.