Mr. Watchlist’s DesigNation
The home for financial crime analysis and commentary. Mostly focused on economic sanctions, with anti-money laundering, export control and anti-bribery and corruption sprinkled in from time to time - it’s 15 minutes or less of your day to get a fresh perspective on current events and how they impact… read more
All Episodes
OFAC Gets an E for… Egregious?
May 6th, 2021
Episode 45 (“OFAC Gets an E for … Egregious?”) Show Notes
OFAC Enforcement Guidelines
https://home.treasury.gov/system/files/126/fr74_57593.pdf
SAP SE Enforcement Action
Everything But the Kitchen Sink
April 15th, 2021
Episode 44 (“Everything but the Kitchen Sink”) Show Notes
Executive Order on Blocking Property with Respect to Specified Harmful Foreign Activities of …
The Other Shoe Drops
April 7th, 2021
Episode 43 (“The Other Shoe Drops”) Show Notes
Nordgas OFAC Enforcement Action
https://home.treasury.gov/system/files/126/20210326_nordgas.pdf
…
Out of Control
March 16th, 2021
Episode 42 (“Out of Control”) Show Notes
OFAC UniControl Enforcement Action
https://home.treasury.gov/system/files/126/20210315_uc.pdf
OFAC Enforcement …
Keep Your Friends Close...
February 28th, 2021
Episode 41 (“Hold Your Friends Close...”) Show Notes
Treasury Press Release of February 26, 2021
https://home.treasury.gov/news/press-releases/jy0038
…
Withholding Judgment
February 25th, 2021
Episode 40 (“Withholding Judgment”) Show Notes
U.S Customs and Border Protection (CBP) Forced Labor Enforcement Fact Sheet
A Bit Much?
February 21st, 2021
Episode 39 (“A Bit Much?”) Show Notes
BitPay, Inc, Enforcement Action
https://home.treasury.gov/system/files/126/20210218_bp.pdf
OFAC Enforcement Guidelines
https://home.treasury.gov/system/files/126/fr74_57593.pdf
BitGo …
Last Minute Reprieve
January 11th, 2021
Episode 38 (“Last Minute Reprieve”) Show Notes
Executive Order 13959
https://home.treasury.gov/system/files/126/13959.pdf
Frequently Asked Question 857
“Trust, but Verify”, Revisited
January 4th, 2021
Episode 37 (“Trust, but Verify”, Revisited) Show Notes
General License INT/2020/059 Publication Notice
Sanctions Clause Says: Don’t Pass, BitGo!
December 31st, 2020
Episode 36 (“Sanctions Clause Says: Do Not Pass, BitGo!”) Show Notes
OFAC Enforcement Information for December 30, 2020
https://home.treasury.gov/system/files/126/20201230_bitgo.pdf
Opening the Presents
December 28th, 2020
Episode 34 (“Opening the Presents”) Show Notes
OFAC-based lists
Specially Designated Nationals and Blocked Persons List (SDN List)
Topping Off 2020 Hindsight
December 23rd, 2020
Episode 33 (“Topping Off 2020 Hindsight”) Show Notes
OFAC Enforcement Information:
Berkshire Hathaway
https://home.treasury.gov/system/files/126/20201020_berkshire.pdf
Deutsche Bank Trust Company Americas
2020 Hindsight: Bottoms Up
December 20th, 2020
Episode 32 (“2020 Hindsight: Bottom’s Up”) Show Notes
FinCEN Statement on Enforcement of the Bank Secrecy Act
Bully Pulpit
December 10th, 2020
Episode 30 (“Bully Pulpit”) Show Notes
U.S. State Department Fact Sheet (“U.S. Investors are Funding Malign PRC Companies on Major Indices”)
Mr. Watchlist’s Nightmare
December 6th, 2020
Episode 29 (“Mr. Watchlist’s Nightmare”) Show Notes
Executive Order 13959 (“Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companes”)
But You Can’t Stay Here
December 2nd, 2020
Episode 28 (“But You Can’t Stay Here”) Show Notes
Executive Order 13405 (Belarus Sanctions)
https://home.treasury.gov/system/files/126/13405.pdf
Executive Order 13667 (Central African Republic Sanctions(
OFAC Sanctions from A to Z: Belarus
November 30th, 2020
Episode 27 (“OFAC Sanctions from A to Z: Belarus”) Show Notes
Executive Order 13405
https://home.treasury.gov/system/files/126/13405.pdf
Belarus …
Hup, Two, Three, Four!
November 19th, 2020
Episode 26 (“Hup, Two, Three, Four!”) Show Notes
Executive Order 13959
https://home.treasury.gov/system/files/126/13959.pdf
Chinese Military Companies …
OFAC v the Oracle of Omaha
October 22nd, 2020
Episode 24 (“OFAC v the Oracle of Omaha”) Show Notes
Berkshire Hathaway Enforcement Information
https://home.treasury.gov/system/files/126/20201020_berkshire.pdf
Berkshire Hathaway Settlement Agreement
FinCEN, Files, Ho, Hum!
October 20th, 2020
Episode 23 (“FinCEN, Files, Ho, Hum!”) Show Notes
BuzzFeed News FinCEN Files page
https://www.buzzfeednews.com/fincen-files
BuzzFeed Source Documents page
Walking the Walk
September 29th, 2020
Episode 21 (“Walking the Walk”) Show Notes
Comtech Telecommunications OFAC Enforcement Settlement Agreement
https://home.treasury.gov/system/files/126/20200917_comtech_settlement.pdf
A Framework for OFAC Compliance …
Because I said so
September 22nd, 2020
Episode 19 (Because I said so) Show Notes
September 21, 2020 Executive Order (Iran conventional weapons)
https://home.treasury.gov/system/files/126/20200921_eo_iran-con-arms.pdf
September 19, 2020 State Department Press …
Crawling from the Wreckage
September 18th, 2020
Episode 18 (“Crawling from the Wreckage”) Show Notes
Comtech Telecommunications Enforcement Action
https://home.treasury.gov/system/files/126/20200917_comtech.pdf
Deutsche Bank Enforcement Action (“Actual Knowledge”)
Sprechen Sie Settlements?
September 15th, 2020
Episode 16 (“Sprechen Sie Settlements?”) Show Notes
Deutsche Bank Enforcement Action - 2020
https://home.treasury.gov/system/files/126/20200909_DBTCA.pdf
Deutsche Bank Enforcement Action - 2013
Better Left Unsaid
September 8th, 2020
Episode 15 (“Better Left Unsaid”) Show Notes
Multiagency North Korea Ballistic Missile Procurement Advisory
Vitamin K Deficiency
September 7th, 2020
Episode 14 (Vitamin K deficiency) Show Notes
Analysis of Iranian oil seizure
https://kobrekim.com/news/evelyn-sheehan-us-seizure-iranian-oil-venezuela-sandp-global-platts
Cuban Journalist Release Press Statement
A Guide for the Perplexed
September 2nd, 2020
Episode 13 (A Guide for the Perplexed) Show Notes
Multiagency North Korea Ballistic Missile Procurement Advisory
OFAC’s Framework, Part 1: Taking Responsibility
September 1st, 2020
Episode 12 (OFAC’s Framework, Part 1: Taking Responsibility) Show Notes
A Framework for OFAC Compliance Commitments
https://home.treasury.gov/system/files/126/framework_ofac_cc.pdf
OFAC Enforcement Guidelines
A sanction by any other name
August 28th, 2020
Episode 11 (“A sanction by any other name”) Show Notes
August 26, 2020 Commerce Department Press Release
The plane truth
August 25th, 2020
Episode 9 / The plane truth Show Notes
WSJ article (“Curtiss-Wright Discloses Possible Russia Sanctions Violations”)
Imitation is the sincerest form of flattery
August 19th, 2020
Show Notes for Episode 8 (Imitation is the sincerest form of flattery)
- FinCEN BSA Enforcement Statement
Why small fry?
August 17th, 2020
Episode 7 (why small fry?) Show Notes
OFSI Notice for North Korean sanctions amendments:
…
Do as I say...
August 14th, 2020
Episode 6 (“Do as I say...”) Show Notes
OFAC Humanitarian Aid Fact Sheet
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/covid19_factsheet_20200416.pdf
Swiss Humanitarian Trade Arrangement Press …
Taking It Personally
August 12th, 2020
Episode 5 Show Notes
OFAC Civil Penalties and Enforcement Information page:
https://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx
OFAC Enforcement Guidelines:
Pennsylvania Avenue Freeze Out
August 3rd, 2020
Show Notes Episode 3
OFAC Notice of 7/31/2020
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200731.aspx
and associated State Department press release
Non-Stick Sanctions
August 2nd, 2020
Show Notes for Episode 2
Resources for today’s show:
On the Russian oligarchs’ involvement in the art market
Congressional probe: Russian oligarchs …
Sanctions Ahoy!
July 30th, 2020
Show Notes for 7/28/2020 Mr. Watchlist’s DesigNation
Resources to go along with today’s episode:
March 2020 United Nations Panel of Experts Report (1718 Committee) -
Listen to Mr. Watchlist’s DesigNation
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