Show cover of Mr. Watchlist’s DesigNation

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 the bigger picture in business (and geopolitics, too!). If you hunger for even more news about financial crime, you can always come over to - I’d love to see you there! Album art by Em Sohn (my youngest) - see


Third Time’s the Charm
Episode 46 (“Third Time’s the Charm”) Show Notes OFAC Chinese Military Companies Sanction Page Order 13959 Order 13974 Order 14032 Chinese Military Industrial Complex Companies (NS-CMIC) List Page
12:07 06/25/2021
OFAC Gets an E for… Egregious?
Episode 45 (“OFAC Gets an E for … Egregious?”) Show NotesOFAC Enforcement Guidelines SE Enforcement Action S.r.l. Enforcement Action
11:52 05/06/2021
Everything But the Kitchen Sink
Episode 44 (“Everything but the Kitchen Sink”) Show NotesExecutive Order on Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation (unnumbered as of April 15, 2021) 1 Under Executive Order of April 15, 2021 Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation Frequently Asked Questions Frequently Asked Questions Order 13883 (CBW Act-related sanctions) Act Directive Order 13661 Parliament report (“Energy as a tool of foreign policy of authoritarian states, in particular Russia”)
15:11 04/15/2021
The Other Shoe Drops
Episode 43 (“The Other Shoe Drops”) Show NotesNordgas OFAC Enforcement Action OFAC Enforcement Action 
09:40 04/07/2021
Out of Control
Episode 42 (“Out of Control”) Show NotesOFAC UniControl Enforcement Action Enforcement Guidelines Apollo Aviation Enforcement Action British Arab Commercial Bank Enforcement Action Clearstream Banking Enforcement Action
15:20 03/16/2021
Keep Your Friends Close...
Episode 41 (“Hold Your Friends Close...”) Show NotesTreasury Press Release of February 26, 2021 Department Press Release of February 26, 2021 and Nationality Act of State, Foreign Operations, and Related Programs Appropriations Act, 2020
11:50 02/28/2021
Withholding Judgment
Episode 40 (“Withholding Judgment”) Show NotesU.S Customs and Border Protection (CBP) Forced Labor Enforcement Fact Sheet Withhold Release Orders and Findings
13:25 02/25/2021
A Bit Much?
Episode 39 (“A Bit Much?”) Show NotesBitPay, Inc, Enforcement Action Enforcement Guidelines Enforcement Action
11:33 02/21/2021
Last Minute Reprieve
Episode 38 (“Last Minute Reprieve”) Show NotesExecutive Order 13959 Asked Question 857 Asked Question 858 Asked Question 859 Asked Question 860 Asked Question 864 Chinese Military Companies General License 1 Communist Chinese Military Companies List Scraps Plans to Delist Chinese Telecom Stocks Mobile website
14:20 01/11/2021
“Trust, but Verify”, Revisited
Episode 37 (“Trust, but Verify”, Revisited) Show NotesGeneral License INT/2020/059 Publication Notice License INT/2020/059 Russia (Sanctions) (EU Exit) Regulations 2019 Russia sanctions guidance Regulation (EU) 2017/1547 Regulation (EU) No 269/2014 Belarus General License 2G
16:12 01/04/2021
Sanctions Clause Says: Don’t Pass, BitGo!
Episode 36 (“Sanctions Clause Says: Do Not Pass, BitGo!”) Show NotesOFAC Enforcement Information for December 30, 2020
10:44 12/31/2020
How the Sausage Gets Made
Episode 35 (“How the Sausage Gets Made”) Show NotesExecutive Order 13959 Law 105-261 (NDAA FY1999) Law 106-398 (NDAA FY2001) Law 108-375 (NDAA FY2005) Communist Chinese Military Companies List PDF of December 28, 2020 Asked Question 857 Asked Question 858 Asked Question 859 Asked Question 860 Asked Question 861
15:19 12/30/2020
Opening the Presents
Episode 34 (“Opening the Presents”) Show Notes OFAC-based lists Specially Designated Nationals and Blocked Persons List (SDN List) Sanctions List State Department Lists Cuba Restricted List Prohibited Accommodations List Section 231 List Defense Department Lists Chinese Military Companies Lists Commerce Department Lists Denied Persons List List List End Users List Control List Munitions List
09:16 12/28/2020
Topping Off 2020 Hindsight
Episode 33 (“Topping Off 2020 Hindsight”) Show Notes OFAC Enforcement Information:Berkshire Hathaway Bank Trust Company Americas Encourages Persons to communicate compliance concerns related to COVID-19 Order 13959 (Chinese Military Companies) Order 13936 (Hong Kong-related Sanctions) 18 Entity List Additions Press Release by State Department OFAC Action Greek Shippers Threatened With Sanctions, Forced to Hand Over Iranian Oil Cargo to US, Report Says Sanctions Violation (Alleged) - Bunker Holding - story Enforcement Actions Page Westpac civil penalty media release
13:45 12/23/2020
2020 Hindsight: Bottoms Up
Episode 32 (“2020 Hindsight: Bottom’s Up”) Show NotesFinCEN Statement on Enforcement of the Bank Secrecy Act Assessment of Civil Monetary Penalty - Larry Dean Harmon Enforcement Page Standard Chartered Imposition of Monetary Penalty Enforcement Information:Berkshire Hathaway CAATSA 231 Action (Non-SDN Menu-Based Sanctions & SDN List designations) Defense Authorization Act for the Fiscal Year 2021 (NDAA FY21) Department Press Release on Sudan’s State Sponsor of Terrorism Designation of Justice 2020 FCPA Enforcement Actions Bridging Document Guidance
15:00 12/20/2020
Turkey on the Menu
Episode 31 (“Turkey on the Menu”) Show NotesMonday, December 13, 2020 OFAC Notice Department Fact Sheet Menu-Based Sanctions List page America’s Adversaries through Sanctions Act (CAATSA) Sections 231 and 235 Section 231(e) page: Freedom Support Act of 2014 (UFSA), Russia sign deal on supply of S-400 missiles (Reuters) Missile System Wikipedia page Defense Authorization Act for Fiscal Year 2021 (NDAA FY21)
14:48 12/15/2020
Bully Pulpit
Episode 30 (“Bully Pulpit”) Show NotesU.S. State Department Fact Sheet (“U.S. Investors are Funding Malign PRC Companies on Major Indices”) Order 13959 (“Addressing the Threat From Securities Investments That Finance Communist Chinese Military Companies”) State Department Press Releases of State Pompeo Speech at Georgia Tech (“The Chinese Communist Party on the American Campus”) State Department December 4, 2020 Press Release (“U.S. Imposes Sanctions on People’s Republic of China Officials Engaged in Coercive Influence Activities”) State Department December 3, 2020 Press Release (“On the Political Persecution of Hong Kong Democracy Advocates”)
13:01 12/10/2020
Mr. Watchlist’s Nightmare
Episode 29 (“Mr. Watchlist’s Nightmare”) Show NotesExecutive Order 13959 (“Addressing the Threat from Securities Investments That Finance Communist Chinese Military Companes”) of Defense December 3, 2020 Press Release 50 Percent Rule (“Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked”) FAQ 373 Order 13662 (“Blocking Property of Additional Persons Contributing to the Situation in Ukraine”) Order 13662 Directive 1  (as amended on September 29, 2017) Order 13808 (“Imposing Additional Sanctions with Respect to the Situation in Venezuela”)
10:37 12/06/2020
But You Can’t Stay Here
Episode 28 (“But You Can’t Stay Here”) Show NotesExecutive Order 13405 (Belarus Sanctions) Order 13667 (Central African Republic Sanctions( 8693 of July 24, 2011 and Nationality Act
10:33 12/02/2020
OFAC Sanctions from A to Z: Belarus
Episode 27 (“OFAC Sanctions from A to Z: Belarus”) Show NotesExecutive Order 13405 Sanctions Regulations General License 2-G
14:29 11/30/2020
Hup, Two, Three, Four!
Episode 26 (“Hup, Two, Three, Four!”) Show NotesExecutive Order 13959 Military Companies Sanctions page Order 13936 Law 105-261 (NDAA FY1999) Law 106-398 (NDAA FY 2001) Law 108-375 (NDAA FY 2005)
14:37 11/19/2020
Mixa, Mixa, Mixa
Episode 25 (“Mixa Mixa Mixa”) Show NotesFinCEN October 19, 2020 Assessment of Monetary Penalty August 18, 2020 BSA Enforcement Statement
13:47 10/28/2020
OFAC v the Oracle of Omaha
Episode 24 (“OFAC v the Oracle of Omaha”) Show NotesBerkshire Hathaway Enforcement Information Hathaway Settlement Agreement CFR 560.204 (part of the Iranian Transactions and Sanctions Regulations) Corporation Enforcement Action
13:19 10/22/2020
FinCEN, Files, Ho, Hum!
Episode 23 (“FinCEN, Files, Ho, Hum!”) Show NotesBuzzFeed News FinCEN Files page Source Documents page FinCEN Files page Data Visualization page 
14:59 10/20/2020
Shootout at the OFAC Corral
Episode 22 (“Shootout at the OFAC Corral”) Show NotesOctober 8, 2020 OFAC Iran-related Notice Iran General License L Order 13902 Transactions and Sanctions Regulations (ITSR) Program Tags page Sky Finding of Violation CFR Chapter V    
13:28 10/15/2020
Walking the Walk
Episode 21 (“Walking the Walk”) Show NotesComtech Telecommunications OFAC Enforcement Settlement Agreement Framework for OFAC Compliance Commitments
15:39 09/29/2020
If you like pina coladas
Episode 20 (“If you like pina coladas”) Show NotesTreasury Department Final Rule Press Release Prohibited Accomodations List Initial Publication Cuba Sanctions FAQs Department Press Release Security Presidential Memorandum 5 (NSPM-5) story
11:47 09/28/2020
Because I said so
Episode 19 (Because I said so) Show NotesSeptember 21, 2020 Executive Order (Iran conventional weapons) 19, 2020 State Department Press Release Order 13936 (Hong Kong related sanctions) 2018 Presidential Memorandum 2018 Presidential Remarks
09:10 09/22/2020
Crawling from the Wreckage
Episode 18 (“Crawling from the Wreckage”) Show NotesComtech Telecommunications Enforcement Action Bank Enforcement Action (“Actual Knowledge”) Worldwide Enforcement Action (“Economic Benefit”, “Indirect Shipment”) FZE Enforcement Action (“Actual Knowledge, Significant Harm/Economic Benefit, “Commercial Sophistication”) Inc. Enforcement Action (“Lack of Due Caution or Care”) America Enforcement Action (“Reckless”, “Indirect Shipment”, ”Management Involvement”, ”Commercial Sophistication”) Shipping International Enforcement Action (“Reckless Disregard”, “Management Involvement”, “Economic Benefit”, “Commercially Sophisticated”) USA Enforcement Action (“moving part of transaction outside of US”) Corporation Enforcement Action (“Obstructing Investigation”) Jereh Oilfield Services Group Enforcement Action (“Obstructing OFAC Investigation”) White Birch Investment Enforcement Action (“Lack of Cooperation”) Aviation Group Enforcement Action (Customer sends engines to Sudan) Cosmetics Enforcement Action (gets North Korean goods through supply chain)
11:25 09/18/2020
The Case of the Missing Email
Episode 17 (“The case of the missing email”) Show NotesState Department Press Release Department Press Release Department Press Release (South China Seas Military Island Construction)
07:49 09/17/2020