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The US, European and UK Sanctions Enforcement Landscape

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The extension of OFAC’s statute of limitations for sanctions violations is recognized as “one of the most important developments… coming out of the US in terms of sanctions enforcement”. Join John Smith and Chloe Cina alongside Justine Walker from ACAMS, on the Sanctions Space podcast, where they discuss the evolving sanctions enforcement landscape, across the US, Europe, and the UK.

The extension of OFAC’s statute of limitations for sanctions violations is recognized as “one of the most important developments… coming out of the US in terms of sanctions enforcement”. Join John Smith and Chloe Cina alongside Justine Walker from ACAMS, on the Sanctions Space podcast, where they discuss the evolving sanctions enforcement landscape, across the US, Europe, and the UK.Recorded live at the ACAMS Europe Conference in Amsterdam, John, Chloe, and Justine also share their views on the extension to 10 years for statute of limitations for sanctions violations in the US and the resulting impact on industry. Recorded before the UK Prime Minister’s announcement that a General Election will be held on 4 July 2024, this podcast explores the potential impact the upcoming US elections could have on sanctions and export controls.Listen on <a href="https://soundcloud.com/sanctionsspace/john-smith-and-chloe-cina?utm_source=clipboard&utm_medium=text&utm_campaign=social_sharing" target="_blank">Soundcloud</a>, <a href="https://open.spotify.com/show/7piHmX23zhEDI7iWxjWflN" target="_blank">Spotify</a>, <a href="https://podcasts.apple.com/nz/podcast/sanctions-space/id1532723728" target="_blank">Apple</a> or <a href="https://music.amazon.com/podcasts/57db44ac-4bc5-4696-bc1f-5c99573f7594/sanctions-space" target="_blank">Amazon</a>.

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<div class="videoWrapper"><iframe class="sticky-video" allowfullscreen="1" allow="autoplay; encrypted-media" frameborder="0" src="https://www.youtube-nocookie.com/embed/JqKSMBInKJ0?rel=0" title="Meet John Smith" title="iframe"></iframe></div>John E. Smith, former Director of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), is co-head of Morrison Foerster’s National Security practice, and a member of the Crisis Management group and Investigations + White Collar group. After serving 11 years as a top official at OFAC and three years as its Director, Mr. Smith brings to the firm unmatched experience in <a href="/capabilities/national-security.html#SanctionsEmbargoes">economic sanctions</a>, enforcement, and national security.Both in the United States and globally, clients turn to Mr. Smith for his deep experience and unique perspective on the complexities and escalating risk of U.S. and multilateral sanctions. He is a trusted advisor for clients navigating significant civil and criminal enforcement actions by U.S. and other government prosecutors and regulators.While serving as a top official at OFAC, Mr. Smith was centrally involved in all aspects of developing, implementing, and enforcing U.S. government sanctions requirements. As OFAC Director, he oversaw every OFAC enforcement case against financial institutions and global operating companies.  Mr. Smith played a pivotal role as OFAC moved to the center of our nation’s response to the world’s most complex and challenging national security and foreign policy crises, working closely with other governments and multilateral agencies and the private sector.Mr. Smith has leading expertise on U.S. sanctions, anti-money laundering (AML), and export controls cases and policies. While serving at OFAC, he worked closely with the U.S. Department of Justice (DOJ) to pursue major sanctions and export controls enforcement matters, including significant civil and criminal penalties against major global actors and noteworthy cases against malicious cyber actors. He has overseen the U.S. government’s economic sanctions efforts, imposing sanctions on heads of state, countries, and illicit actors, conducting enforcement actions against dozens of major financial institutions and companies around the world, and developing innovative sanctions enforcement policies to address evolving U.S. national security priorities.Under his leadership as a top official at OFAC, Mr Smith:<ul><li>Supervised the investigation, preparation, strategy, and settlement of dozens of major enforcement cases for hundreds of millions of dollars involving apparent sanctions and export control violations by global financial institutions and corporations; </li><li>Led the development and imposition of some of the most significant sanctions ever involving Iran, Russia, North Korea, Syria, supporters of terrorism, weapons of mass destruction proliferators, malicious cyber actors, transnational criminal organizations, and narcotics traffickers; and</li><li>Acted for a period as the Treasury Under Secretary for Terrorism and Financial Intelligence (TFI), overseeing economic sanctions, illicit finance, and AML efforts by OFAC and other TFI components, including the Financial Crimes Enforcement Network (FinCEN). </li></ul>Prior to Mr. Smith’s 11-year tenure at OFAC, he served as the only American on a Security Council panel of experts charged with monitoring the implementation of UN-mandated sanctions on Al-Qaida and the Taliban. In this role, he led assessment visits to more than 20 countries in Africa, Asia, Europe, and the Gulf, meeting with top-ranking government officials, central banks, customs and export control offices, and intelligence agencies, as well as many of their financial institutions.Mr. Smith also served as a trial attorney in the Civil Division of the DOJ for five years. During his tenure, he defended U.S. agencies including OFAC in challenges to significant government programs and statutes, including the USA PATRIOT Act, the 2000 Census, and other matters involving highly sensitive and classified information. Mr. Smith acted as the lead trial counsel in defending the first legal challenges to the terrorist asset freezing program implemented by OFAC following September 11, 2001.Mr. Smith has received numerous noteworthy accolades throughout his career, including the Alexander Hamilton Award, the top award given by the U.S. Department of the Treasury (2018); and the Special Commendation for Outstanding Service (Anti-Terrorism), awarded by the DOJ (2002).Before joining the DOJ, Mr. Smith was a litigation attorney at a major international law firm. He also served as a law clerk for The Honorable Anthony J. Scirica on the U.S. Court of Appeals for the Third Circuit.Mr. Smith received his J.D. from Columbia University School of Law as a Harlan Fiske Stone scholar, where he served as Editor-in-Chief of the Columbia Journal of Law and Social Problems. He graduated cum laude from the University of Missouri-Columbia, with dual degrees of a Bachelor of Arts in political science and a Bachelor of Journalism.