Sanctions and Crypto
Sanctions Enforcement and Compliance in the Digital Age
Streaming here on:
May 20, 2021 at 3PM EST / 12 PM PT
For decades, policymakers across the globe have increasingly used economic sanctions to disrupt terror networks, limit the spread of weapons of mass destruction, punish human rights violations, deter election interference, and isolate rouge regimes. While the United States, the European Union and the United Nations deploy sanctions differently, all three focus on one common goal - cutting off illicit actors from the traditional financial system to prevent them from moving money and buying goods.
However, as we move from the fiat world of hawalas and shell companies to the digital world of programmatic money laundering in cryptocurrencies, what is the impact to economic sanctions? How do cryptocurrencies, with their promise of speed, pseudo anonymity, and borderless reach, impact nation states' ability to enforce sanctions? How can cryptocurrency businesses and financial institutions build a sanctions compliance response to thwart sanctioned actors and conform with regulatory expectations? TRM Talks Crypto and Sanctions with two people that have the answers: OFAC’s Head of Enforcement Lawrence Scheinert and former treasury official and sanctions expert Eric Lorber of K2 Integrity.
Head of Legal and Government Affairs at TRM Labs
Ari Redbord is Head of Legal and Government Affairs at TRM Labs, a blockchain analytics company that helps organizations detect, assess and investigate crypto-related fraud and financial crime. Prior to his role at TRM, Ari was the Senior Advisor to the Deputy Secretary and the Undersecretary for Terrorism and Financial Intelligence at the United States Treasury. In that position, he worked with teams from the Office of Foreign Assets Control (OFAC), the Financial Crimes Enforcement Network (FinCEN), and other Treasury components to deploy sanctions and other regulatory tools against threat actors, including terrorist financiers, weapons of mass destruction proliferators, drug kingpins, and other rogue actors, including Iran, Syria, North Korea and Venezuela. In addition, Ari worked closely with regulators, the Hill and the interagency on issues related to the Bank Secrecy Act, cryptocurrency, and anti-money laundering strategies.
Prior to Treasury, Ari was an Assistant United States Attorney for the District of Columbia for eleven years where he investigated and prosecuted terrorism, espionage, threat finance, cryptocurrency, export control, child exploitation and human trafficking cases.
Eric Lorber, Managing Director, K2 Integrity
Eric B. Lorber is a managing director at K2 Integrity, based in Washington, D.C. With nearly a decade of experience advising financial institutions, corporate clients, and law firms on economic sanctions, regulatory enforcement matters, and Anti-Money Laundering/Combating the Finance of Terrorism (AML/CFT) compliance, Eric helps financial institutions and multinational companies navigate compliance regimes. He assists C-suite officers in identifying regulatory risk and works with shipping companies, energy companies, insurance firms, manufacturers, and financial institutions to limit and mitigate economic sanctions exposure, including conducting complex investigations and interfacing with regulatory and enforcement authorities on their behalf.
Eric regularly helps clients develop and implement their AML and sanctions policies and procedures. He also plays a key role in training compliance officers on sanctions and AML requirements, helping establish and implement industry-leading AML and sanctions training programs for global banks, corporates, and jurisdictional clients such as central banks and financial intelligence units.
In addition, Eric is the senior director of the Center of Economic and Financial Power at the Foundation for Defense of Democracies, where he speaks and writes regularly about key developments in economic sanctions, AML/CFT initiatives, and other regulatory matters.
Prior to joining K2 Integrity, Eric was a senior advisor to the Under Secretary for Terrorism and Financial Intelligence (TFI) at the U.S. Department of the Treasury, where he provided strategic guidance on U.S. sanctions and AML/CFT policies. Earlier in his career, he was an attorney at Gibson, Dunn & Crutcher, where he advised clients in the areas of international trade regulation, compliance, and anti-corruption.
His articles and commentary on sanctions and related issues have appeared widely in the press and academic journals, including The Washington Post, The Wall Street Journal, The New York Times, and Foreign Affairs. He regularly testifies on sanctions-related issues before Congress, including before the Senate Banking Committee, the Senate Judiciary Committee, the House Financial Services Committee, and the House Permanent Select Committee on Intelligence, and is a term member at the Council on Foreign Relations.
Eric has a J.D. from the University of Pennsylvania Law School, where he received the Noyes E. Leech Award for highest achievement in international law, and a B.A. in political science, magna cum laude and with departmental honors, from Columbia University, where he was awarded the Charles Beard Prize for academic achievement.
OFAC Associate Director for Compliance and Enforcement
Lawrence Scheinert is the Associate Director for Compliance and Enforcement at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). In this role, he oversees OFAC’s enforcement, compliance, and private sector outreach programs. Mr. Scheinert previously served as a Senior Advisor to the Treasury Department’s Under Secretary for Terrorism and Financial Intelligence, and before that as the Director of the Office of Special Measures at the U.S. Financial Crimes Enforcement Network. Mr. Scheinert also previously worked as a corporate and securities associate at the international law firm of White & Case LLP. Mr. Scheinert has a degree in finance from Lehigh University, a law degree from University of Florida, and an LL.M. in Securities and Financial Regulation from Georgetown Law.