Just published on KYC360, The FinCEN Files: Asking the Right Questions tries to identify the questions we should be asking to move beyond the sensational headlines, and really identify what we should be concerned about, and how we might be able to address those issues. Mind you, I don’t have […]
My new article, Gaming Out Sanctions Risk, was published today on RegulationAsia.com. It’s also now on my Publications page. It was a slog to write (pretty dense subject), but I think it’s a good topic. Oh, what is that topic? Adapting the war gaming model to anticipate and plan responses […]
Render unto OFAC will appear in the September-November issue of ACAMS Today. Its focus is the Caesar Syria Civilian Protection Act. Enjoy – all feedback welcome, of course!
Published today on KYC360, Amazon: Prime Time for Penalties is my latest. It goes beyond the facial failures and tries to dig a little deeper – like, why did they not catch references to Yalta? Did they not have geographic place name data? Was the reference in a data element […]
It’s up in KYC360.com (aka RiskScreen.com) here – hope you like it!
That’s the subject of my new article for Regulation Asia – Humanitarian Trade with North Korea: A Matter of Trust. It’s not just finding a government that will provide a clearinghouse for the transactions and the associated due diligence and reporting – it’s navigating the geopolitics, too. Let me know […]
See my new article Are Sanctions Cruel? over at KYC360 – it’s about the current brouhaha over relaxing sanctions because sanctioned countries are apparently having difficulties receiving aid – and the available humanitarian mechanisms provided under US sanctions regulations. Hint: it’s more complicated than that.
So, I wrote (for our brand spanking-new blog) about the US’ Paycheck Protection Program (PPP) and why it favored larger firms. Also, maybe how it could be fixed for the next round of funding. Given that Shake Shack felt guilty about their $10MM and returned it (since they were able […]
You can read it here (requires you to sign up for their mailing list to read the whole thing) in their Risk & Compliance magazine. Yeah, it’s like some of my other articles… about the Framework document that OFAC published back in May. The focus is a little different, in […]
If so, you might be interested in my new KYC360 article Interested Parties: Understanding ‘Property’ in OFAC Compliance – which just got published this morning. It’s an area which doesn’t get written about much (“property and interests in property”)… hope you find it interesting!