Geoeconomics, economic sanctions, and illicit finance
Adjunct Professor, Georgetown University
Adjunct Senior Fellow, Center for a New American Security
Thank you to @el72champs + @nytimes for including my analysis on sanctions and frozen assets in the context of ongoing U.S.-Iranian negotiations
https://t.co/VtTu0dCwjr
.@USTreasury OFAC enforcement action announced today against international consulting and advisory firm FTI Consulting for prohibited debt dealings with Russia's VTB Bank https://t.co/VGm5esEkkh
@USTreasury OFAC enforcement action announced today against international consulting and advisory firm FTI Consulting for prohibited debt dealings with Russia's VTB Bank https://t.co/VGm5esEkkh
Smart move by @USTreasury on the use of strategic delisting as part of sanctions modernization efforts.
Much more is needed in this space but glad to see follow-through from Sec. Bessent's speech in Paris on May 19 previewing this initiative.
I look forward to publishing a more detailed report on this and related issues over the summer.
https://t.co/BAujWNyKuD
“Iran will likely profit from these sales, thereby providing more money to fund its regime, the war and its proxies,” said @AlexZerden, the founder of Capitol Peak Strategies and a former official in the Treasury Department’s Office of Terrorism and Financial Intelligence. “I don’t think this stopgap measure will provide the market with assurance.”
https://t.co/OSICZiLMZY
Alex Zerden, a former Treasury official, said the US government historically takes so few enforcement actions that lawyers and compliance experts carefully study each one to understand the implications, particularly given the agency appears to be keeping up its focus on Kerimov.
Sharing my latest analysis with @S_R_Anders in @lawfare to understand the recent decision by the Trump administration to protect certain Venezuelan oil assets and the policy rationale behind moving funds to Qatar https://t.co/WXp0d9PtUV
After removing dictator Nicolas Maduro from power, President Trump issued an executive order setting up a mechanism for managing Venezuelan oil revenue. @S_R_Anders and @AlexZerden explore why the administration is channeling the revenue from the first oil deal through Qatar.
Now up on @lawfaremedia: my extraordinarily deep dive with @alexzerden into how the Trump administration is handling Venezuela's oil revenue.
Long story short, the scheme they've set-up—and the short-term fix they pursued through Qatar—both make more sense than they might seem.
“Unprecedented sanctions and related relief will help the Syrian people and fulfill President Trump’s May 13, 2025 commitment for the ‘cessation” of ‘sanctions.’”
Read more from senior fellow @AlexZerden⬇️
https://t.co/PgExhktaqQ
Good piece @AlexZerden on current state of play re Syria sanctions in US. Section on steps USG could/should take to continue on this path particularly useful. key signposts re potential legal guidance on continuing designations and positive statecraft
https://t.co/7EU5eDjddM
Reading @alexzerden on all things #sanctions is always worth it - including and especially on #Syria with the seemingly daily pace of progress in implementing post-Riyadh changes.
@AtlanticCouncil@ACGeoEcon 6/6 Develop a policy for using and supporting partners with positive economic statecraft tools such as technical assistance to rehabilitate the financial sector, in addition to licensing, waiving, and removing restrictive economic measures.
@AtlanticCouncil@ACGeoEcon 5/ Provide guidance, including frequently asked questions, for the Caesar Act waiver and the FinCEN Section 311 exceptive relief, as well as interagency policy guidance on the roadmap for further relief.