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After a brief hiatus…

Welcome to the “Shootout at the OFAC Corral”, the latest episode of Mr. Watchlist’s DesigNation. The new show is focused on last week’s designation of the Iranian financial services sector under Executive Order 13902, and the designation of 18 Iranian banks (which had already been sanctioned under the Iranian Transactions […]

Walking the walk

New episode of Mr. Watchlist’s DesigNation revolves around the Comtech Telecommunications enforcement action and, in particular, the Compliance Commitments section of the Settlement Agreement. Normally, OFAC only publicizes the Enforcement Information document – it’s pretty rare that the Recent Actions notification includes a link to the actual settlement. But, this […]

If you like piña coladas…

You may like the newest episode of Mr. Watchlist’s DesigNation – all about the latest changes to the US Cuban sanctions regime, and whether or not it’s substantive in nature or just a way to troll for votes in Florida (look at the calendar)… We’re on Apple Podcasts, Google Podcasts, […]

“Because I said so” – the podcast

New episode of Mr. Watchlist’s DesigNation was just published. Yes, it’s about the “return of UN sanctions” pronounced by the US State Department, and yesterday’s E.O. Did you notice the change in wording in the designation authorities in the Executive Order? I did… although not the first time. It’s a […]

Crawling from the Wreckage

The newly-posted episode of Mr. Watchlist’s DesigNation is about yesterday’s OFAC enforcement action against Comtech Telecommunications and Comtech EF Data. All you need to know: egregious violations, settlement larger than the base penalty, and only 1 mitigating General Factor… Hoo boy! What fun!

The Case of the Missing Email

Today’s episode of Mr. Watchlist’s DesigNation is about the OFAC designation of the Chinese state-owned company Union Development Group, and why the State Department press release, which is available on their website, did not go out by email. And my friends tell me they didn’t get Treasury’s PR in their […]

Mr. Watchlist’s DesigNation: Episode 14

This episode’s a bit different – it’s about balancing incentives and coercive measures. It was effective in terminating the Myanmar sanctions, and bringing about the JCPOA, whether you like that or not. But recent stuff coming out the State Department seems to have forgotten about all that… at least the […]