Mr. Sanctions

Category: This Old Blog

  • This Old Blog: Mr. S’ Pet Peeve #1: Overstuffed OFAC releases

    Yes, I am going to hop on my soapbox and whine about yesterday’s Iran-related release that I decomposed into three posts…

    But, first, I’m going to head some of you off at the pass as you ask: yeah, but doesn’t OFSI sometimes update multiple things at once? Yes, but… they provide a separate Sanctions Notice for every set of updates so, if I wanted to, I could post all 3 of them distinctly… easily.

    As you can tell, I’m not fond when an OFAC release contains multiple types of updates at once. Some of it I understand: a lot of the Iran designations also get the double-whammy of a counter-terror designation, and it makes sense to issue related General Licenses (e.g. wind-down GLs) with designations.

    But, I really wish that when there are designations from distinct OFAC programs, they’re issued separately – or, at least, broken up within the Recent Actions item (e.g. like those tables OFSI includes at the top of its emails). It makes it clearer what’s being done to whom; after all, you’re not loading that text into your screening system, are you?

    That, however, is not the worst offender – yesterday’s Iran-related release was. Not only were there designations and licensing updates, but they felt it necessary to include an enforcement action against an individual. For an individual, it was a pretty hefty settlement, but what was the reasoning for making the update even more bloated? It’s not like you’re going to issue a press release about it. How many of you out there are going to read that enforcement release in the service of informing your compliance program?

    IMHO, OFAC releases should be geared to make us in the sanctions world more effective and stuffing a lot into a single release that we then need to decompose does not accomplish that.

    As the Human Torch would say, flame off… till next time

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  • This Old Blog: How did you spend your Labor Day?

    I spent mine taking ACSS’ CSS-EU certification test (I’m a beta tester). Easily 2 levels of difficulty over ACAMS’ CGSS certification test (which I helped develop) – but I think that partly comes with focusing on the specifics of one program, instead of trying to test general knowledge.

    I now know way more about the EU anti-circumvention tool, what derogations are, and the vagaries of how the Council of the European Union (not to be confused with the European Council, which has a similar name but which is very, very different). And, not for nothing, I do prefer going to a testing center – I think the whole proctoring process, where they watched me through my iPhone camera, more than a little creepy.

    Is the test and the accompanying Study Guide ready for prime time? Of course not, silly rabbits – it’s why it’s called a beta. Just like my laptop running the public beta of Golden Gate.

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  • This Old Blog: Recent changes to OFSI and SECO updates

    Hi, all!

    As you know, I’ve had struggles processing OFSI and SECO updates to existing sanctions designations because of the differences between PDF and Markdown (MD) formats and capabilities. I did realize two things recently, however. Firstly, if I really wanted to reproduce the formatting, I actually could – Claude can also produce HTML as well as Markdown. Secondly, I needed Claude to recognize the formatting and act on its meaning (e.g. added text, deleted text).

    Long story short – while it took a while, posts for OFSI and SECO updates now largely mirror how OFAC updates are displayed – one line per field, with changed records pointing out what was deleted and what was added. Easier for you (and me) to understand, and easier to read, to be frank.

    I am still retaining the tables from the OFSI emails with the links to the FCDO designation pages, the link to the FINMA Notice, and the links to the various files supplied by SECO.

    Actually, I just realized that I didn’t retain the link to the OFSI sanctions notices… I’ll get that working by the time the next update hits.

    Hope this makes the site more useful to you.

    Mr. Sanctions

    P.S. yes, my next great project is figuring out a decent way to track EU changes – EUR-LEX is not particularly user-friendly.

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  • This Old Blog: So, what is your Burning Question?

    Half of the fun (and at least half of the challenge) is finding interesting things to investigate and develop. Today’s EU sanctions post came out of a desire for a single thread to follow, with some useful graphics – especially considering the challenges of herding 27 EU cats. Similar desires to put things into a manageable size box brought the Practitioners Guides and Plain Language Guides – and yesterday’s analysis of the risk implications of DHS’ UFLPA Entity List.

    But, as my wife enjoys reminding me – other people have good ideas, too. And, I assume, good questions as well.

    So, do you have a Burning Question for me (and Claude) to look into for you? It can be a summarization type task, a trend analysis task or… hey, I’m not going to limit what you ask about sanctions or export control.

    So, feel free to put your question to me in the comments, or use the Contact page.

    Thanks – looking forward to your ideas for new topics.

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  • This Old Blog: Corrections and enhancements

    If you read through LinkedIn or Bluesky auto-posting, you will not have noticed 2 recent changes to existing posts:

    • The post announcing the UN’s new DRC listings was updated to also include Canada’s adoption of the changes the same day
    • And the post that carried the US State Department about the FTO and SDGT designations of La Viagras and the Juarez Cartel mistakenly said it preceded changes by OFAC. In this case, on Wednesday at about 11:20 AM, OFAC did update those two designations, although the title of the Recent Actions post did not say that designations were being updated (yes, technically, an existing ILLICIT DRUGS E.O. was added to the FTO and SDGT programs making them “new” designations). And the State Department notice came out over 25 hours later, at about 12:30 PM yesterday (all times Eastern). My friend Yoshi tells me that this sort of delay, while much larger than typical post-designation PR by State, is typical. You live and you learn, I guess.

    Humblest apologies,

    Mr. Sanctions

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  • This Old Blog: Recent Updates

    Hi –

    All the Practitioners and Plain Language Guides are now available on the Resources pages. I’ve also added links to the US Export Controls Guides on the main Resources page – since it cuts across multiple regulators, it didn’t really fit into the US Resources page, which is AI created and maintained.

    Also, all the Resources pages have been refreshed.

    And the Industry Events Calendar now reflects all events for the next 6 months.

    To be honest, the amount of work I need to do to keep these up to date is so minor (comparatively) means I can do this every 4-8 weeks so the content doesn’t get too staie. Mind you, there is always going to be little glitches in the AI processing – the important thing is to get the errors or other failings addressed, and to update the master prompts appropriately.

    For example, in this last pass to make my first major update pass on the events calendar, I found that Claude was inferring URLs and not directly fetching them to confirm they work. That led to some broken links … and when I tried to address it, we found some sites where fetching was blocked by the site. Claude made some suggestions about how to address these failings, and now the spreadsheet Claude produces now has a new sheet that lists events it had errors in fetching but which I could try fetching myself (which I successfully did, actually).

    Now, if it could only write to the Google Calendar… that would save me a lot of time and effort…. a guy can dream, can’t I?

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  • This Old Blog: editing of Claude responses

    My editing of Claude’s responses is pretty minimal, and I want to explain it, in the service of full transparency.

    What I do edit out is basically three things:

    • In a chatbot, any process-type discussion (couldn’t access this document, now fetching this) appears as part of the response block – and gets picked up if you hit the Copy button. The process of how a chatbot tries to gather information, as a general matter, doesn’t add that much value, IMHO, to most of my intended audience – even the more AI-curious. So, I leave these out. Ditto for any discussion as it refines its thinking – what we largely care about is the final response. A good example is the (upcoming) Burning Questions post on the “secondary risk” wording in OFAC listings, where Claude prefixes the final response with this (none of which appears in my post):
      • This is the sharper version of the “Burning Questions” angle from before — whether the field is being read as a rating rather than a citation, and whether that misreading clusters anywhere. Let me search for evidence rather than reason from priors, because the honest answer may be that this specific behavior is under-documented.
      • That gave me adjacent material (screening mechanics, one vendor that tags secondary sanctions as a labeling feature) but not direct evidence of firms misreading the field as a rating. Let me look specifically at the de-risking / over-compliance pattern, which is where any geographic or asset-class clustering would show up.
      • I now have solid material on the de-risking pattern and where it clusters, but I want to be honest about a distinction: the question asks specifically whether firms treat the wording as a rating, and most of what I’ve found is about firms reacting to the underlying risk. Those aren’t the same thing, and I don’t want to conflate them. Let me do one more targeted search on the data-field-as-signal angle.
      • I have enough to give an honest, well-bounded answer.
    • Sometimes, as part of its source checking, Claude will point out things where the difference between its initial drafting and its checking – semantically and in a practical sense – is not worth correcting, or where the discussion of the review itself doesn’t illuminate the response. Those I remove. If there is a real difference, by the way, I have Claude correct it – so I don’t post the original response.
    • Often, Claude will propose I ask a follow-up question. These I remove.

    Now, I do leave in some of Claude’s commentary from time to time. I do that for a number of reasons:

    • I think the reasoning, and the natural language production of the “conversation”, is fascinating
    • I think the back and forth of postulating something, posting a caveat and then proceeding, is more nuanced and informative to the audience (and, to be perfectly frank, to me as well)
    • As much as this is a sanctions blog, it’s also a “AI in sanctions” blog. Some of these peeks behind the curtain inform us as we make decisions about how to use AI in our field

    As always, I invite your comments, criticisms and suggestions.

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  • This Old Blog: Some New Links

    Hi –

    The Plain Language Guides and Practitioners Guides pages have been expanded to include the OFAC North Korean guides, as well as the thematic guides to OFAC and Canadian sanctions.

    I’ve got one more in the hopper I will add after I post the guides later this week – US export control.

    For my readers in the US, enjoy the Independence Day holiday this week – better to say Independence Day since the “observed” holiday, the one we get the day off from work, is on Friday, July 3rd this year because we’re not giving up our paid day off without a fight, am I right?

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  • This Old Blog: Born in the USA, but…

    I decided to take a break from OFAC sanctions guides, so I asked Claude to evaluate the breadth, depth and sophistication of sanctions in the UK, EU, Switzerland, Singapore, New Zealand, Canada and Australia. It recommended that the EU and UK were most worthy, with Canada and Australia being the next tier of regulatory output.

    So, now the Resources pages now have the following Practitioners and Plain Language guides for both the EU and UK:

    • A thematic guide to how all the sanctions programs are organized, with overviews of each sanctions program, and
    • A specialized guide for Russian sanctions

    I will post the thematic guides, since they’re a different kind of animal from the others we’ve posted. If you want the Russia guides, well… click on that Resources page link and go get it, OK?

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  • This Old Blog: Things you learn along the way…

    Hi –

    Working on the Russia Sanctions Guides, I realized I ought to add CAATSA to the Iran Sanctions Guides… so I did. Not going to waste time and space with extra posts, but the Guides on the Plain Language Guides and Practitioners Guides have been replaced with the updated versions. And, yes, both in English and Farsi.

    Will I do a Guide for all the sanctions programs? Probably not, because the complexity just isn’t there. I’ll probably do North Korea next and then I might call it a day. Even the counter-terror and counter-narcotics programs aren’t that complicated, so what’d be the value to you, the reader?

    We shall see…

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