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 […]
Editors always make your titles too long so that everyone knows what it’s about. Original title: Hold on a Second(ary) Final title: Hold on a Second(ary): Rethinking OFAC”s Expanded Sanctions Powers You can find it here… hope you like it.
You’d think I wouldn’t have to write about how, if you don’t want to run afoul of US laws and regulations, you actually have to read them… but I did. I can’t tell you how many times, when I go overseas, I get complaints about how complex it all is. […]
Check out my new article Rooting for OFAC: A Sanctions Compliance To-Don’t List on KYC360. It looks at all the 2019 actions and identifies which of the 10 root causes from OFAC’s “A Framework for OFAC Compliance Commitments” correspond to each one. Hint: nine of the ten are referenced in […]
Read it here on KYC360.com. Feedback always welcome!
My article Anarchy in the UK’s Sanctions Regime (yes, they modified the original title slightly – guess they don’t know who the Sex Pistols were) is now online at RegulationAsia.com – what do folks think of my analysis?
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 […]