Sorry for the long layoff - I’m baaaack! The question of the day: why was the settlement that BitPay Inc. made with OFAC was so large compared to the amount of business involved? I have a guess - see if you agree with me...

First, the good news.. the backing track during the monologue is gone, and I’ve tweaked a few things to improve the audio quality. Now, the bad news: OFAC issued a General License late Friday for the Chinese Military Companies sanctions program, and it’s worth talking about, since it largely fixes a problem they created with a recent Frequently Asked Question that contradicted other regulation and guidance. So, while the point of the episode the importance of reviewing what’s issued and providing feedback so people fix their mistakes.... it does mean we’re covering this program again. Sorry... maybe if they leave it alone for a few months, I’ll stop talking about it so much....

OK... I cheated just a tad. This one’s a little over 16 minutes. My apologies... but I think it’s worth it. OFSI, the UK’s sanctions administrator (and enforcer) has issued its very first General License under its post-Brexit Russia Regulations. I go over the license, which has some neat features, and the Regulations - I think it raises some questions but, in general. Is really nice in terms of details and documentation of license usage (which is OFAC only does on a relatively limited basis). Happy 2021, everyone - enjoy! Promise to get back to my 15 minute self-imposed limit next episode.

Short one to close out the year (yes, I thought I was done) - about yesterday’s enforcement action against BitGo. Despite its small size (about US $98,000), it has lessons for us to learn. So, let’s learn them before we go off and say good riddance to 2020....

The release Monday of OFAC of the Non-SDN Communist Chinese Military Companies List (NS-CCMC) is an apt example of how, in some cases, sanctions programs have to adapt to fill in the gaps left by legislation or Executive Order. Remember the Venezuela General License that exempted transactions in all the Venezuelan government securities issues - except one? Well, this is another case... And Mr. Watchlist hopes that this is just a good first effort... that Sanctions Clause brings more usable sanctions lists in the coming year, so that firms that don’t have core competencies in company research don’t have to identify as many parties sanctioned because they fall under a descriptive title in an Executive Order, a piece of legislation, or a guidance document. Mr. Watchlist can dream, can’t he? Happy New Year, everyone - and good riddance to 2020!

Happy Holidays! It may be a little kitschy, but today we’re going to run through all the US sanctions and sanctions-like lists as if I was a little kid on Christmas morning opening my presents. Sounds like a fun way to do a compendium, with some snark on the side. Happy New Year to all... good riddance to 2020! Eric (aka Mr. Watchlist)

This is the 2nd half of our year-in-review Top 10 list (with 165 items actually in it) for financial crime in 2020. Yeah, mostly, but not all, sanctions... Happy Holidays, everyone - thanks for listening this year. Be safe, wear a mask - and party responsibly. Mr. Watchlist

It’s time for the end of year review - this is my top 10 list (slightly bloated from some honorable mentions) of the most notable (IMHO, of course) doings in financial crime this year. As you might imagine, this is the bottom half of my list... stay tuned for the 2nd bit in a day or two.

Ripped from the headlines... yesterday’s headlines, that is. Turkey’s defense ministry, and 4 of their top officials, were sanctioned yesterday under Section 231 of CAATSA for their purchase of Russian S-400 missiles - that they contracted for in 2017, and received last year. What took so long? We’ll talk about that, plus the mechanics of what OFAC did (there’s a new list!), and some of the weirdness Mr. Watchlist sees in menu-based sanctions. Yum! Pass the gravy! (I know Thanksgiving was a few weeks ago, but roll with it, OK?).

The U.S. State Department’s recent Fact Sheet about U.S. investor’s exposure to Chinese securities issues - was it more China-bashing, or was it a shrewd use of the bully pulpit? I have to tell you - I originally thought it was more jawboning... until I read through the whole thing. The episode goes through the Fact Sheet, showing you my initial thought process - and whether or not there were actual regulatory risks exposed in each section of the Fact Sheet (and why or why not). And we end up on the very last section, which is where the scales fall from our collective eyes, and we understand the whole thing and why it was issued (and reissued a few days later).