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!
I just published an article on KYC360 (aka RiskScreen) about the Finding of Violation that OFAC issued to Aero Sky. I don’t take issue with the fact that the violation occurred or that a Finding of Violation was appropriate in the current environment (the company has since been dissolved) – […]
Read my latest piece on matching technologies here at Money Laundering Bulletin. It’ll be in the February print issue, but it’s online now. Mind you, I’m not the most technical when it comes to this, but I wasn’t trying to write a treatise – just trying to lay out the […]
He writes articles on adjacent topics… like how you can look at the recent flare-up in US-Iran relations as a study in chaos theory…. Read it here – and let me know what you think. It’s more about geopolitics writ large, of which sanctions is just a piece. But someone […]