Patriot Act

Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program

To Build Leverage for Peace, Enforce Oil Sanctions on Russia

American and Ukrainian officials spent the weekend in Geneva revising a peace plan that initially tilted heavily in Russia’s favor. The real challenge now is getting the Kremlin to accept terms that...

U.S., Mexico Step Up Cooperation on Cartel Money Laundering

Drug traffickers cannot spend their piles of cash unless other criminals are willing to launder their money for them. Without access to clean cash, cartels can’t invest in luxury properties, buy businesses,...

From Oil to Oman: 10 Ways to Economically Cripple Iran’s War Machine

Now is the perfect time to tighten the financial thumbscrews on Iran. The clerical regime has been significantly weakened by the unprecedented Israeli and U.S. military attacks on the Islamic Republic...

U.S. Severs Ties With Mexican Banks Enabling China-Fueled Fentanyl Trade

The war on fentanyl is entering a new phase. The U.S. Treasury Department moved decisively on June 25 against several Mexican financial institutions accused of laundering drug money and fueling the fentanyl...

New Syria sanctions relief (and risks) explained

Firms relying on the recent wave of lifted sanctions and exceptive relief will face significant hurdles in verifying that transactions do not benefit excluded actors

Trump’s Russia Sanctions Toolkit

Options to Increase Leverage to End Putin’s War Against Ukraine

Potential Consequences of FinCEN’s Beneficial Ownership Rulemaking

China in Our Backyard: How Chinese Money Laundering Organizations Enrich the Cartels

More than 100,000 Americans died from drug overdoses in the 12-month period ending in November 2022.1 The Biden administration noted that “most of these deaths are caused by illicit synthetic drugs like clandestinely manufactured fentanyl and methamphetamine, often in combination with other drugs, including cocaine and heroin.”2 These deaths increased during the Trump administration and continue to increase today. This is simultaneously a national and local challenge. More Americans die every two weeks on average from overdose deaths than died as a result of the September 11 terror attacks, making this both a national security and a public health crisis that requires bipartisanship to meet the challenge. 

Ruble Rumble

Offensive and Defensive Measures to Defeat Russia in the Economic Domain

Strategy for a New Comprehensive U.S. Policy on Iran

Countering the Financing of Terrorism: Law and Policy

Foreword Since 9/11, countering the financing of terrorism (CFT) has been a focus of U.S. and international security policy, and an evolving feature of the regulatory and risk environment for authorities...

Top Russian Bank Launches Apparent Attempt to Evade Sanctions

Russian media reported last week that state-owned Sberbank, the country’s largest financial institution, had sold some of its assets to an obscure company established in March. The sale likely reflects...

Consider Designating Russia as a Jurisdiction of Primary Money Laundering Concern

Senator Steve Daines (R-MT) last week called on the Treasury Department to designate a Russian bank and two related entities as institutions of “primary money laundering concern” (PMLC) under Section...

Time to Sanction Russia’s Alternative to SWIFT

Per an agreement with Washington and other Western allies, the European Union last week prohibited the SWIFT financial messaging system from providing services to seven Russian banks sanctioned over Moscow’s...

Biden Administration Should Not Provide Sanctions Relief for Terrorism

As President Joe Biden looks to rejoin the 2015 Iran nuclear agreement, or Joint Comprehensive Plan of Action (JCPOA), Iran is likely to pressure the Biden administration to provide broad sanctions relief,...

Biden, Congress Should Defend Terrorism Sanctions Imposed on Iran

Hezbollah Finance in Lebanon

A Primary-Source Review

Crisis in Lebanon

Anatomy of a Financial Collapse

Credibility Gap: China’s FATF Presidency