A remarkable read. Stop what you’re doing and take it in.
thefp.com/p/freedom-figh…
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Brian O'Toole
5.8K posts
Brian O'Toole
@brianoftoole
Nonresident senior fellow at @atlanticcouncil; former Treasury/OFAC and IC. Opinions my own.
Beigetreten Ocak 2017
1.9K Folgt3.1K Follower
Brian O'Toole retweetet
A blank space on today’s WSJ A1 where Evan Gershkovich’s reporting should be, one year after his arrest on patently false charges. Russia should free him now
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Been waiting a while for this to land on my stoop from @SalehaMohsin. Can’t wait to dive in!
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I had expected more third country targets that are less fungible and would have had greater deterrent effect. This is more of the same approach, rather than any new ground in sanctions on Russia.
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Big numbers but not big impact on the 2nd anniversary of Russia’s brutal war against Ukraine. Russia can easily replace these targets and the US will then have to find those new names to sanction, a game of whack a mole that is hard to win.
reuters.com/world/biden-an….
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Brian O'Toole retweetet
Big Russia sanctions list out. Broad but not as impactful as run-up rhetoric suggested. Lots of Russian companies in lots of relevant industrial sectors; some smaller Russian banks & the Russian payment card system; and some evasion targets (China, Serbia, UAE, others). @ACGeoEcon @brianoftoole 1/2
home.treasury.gov/news/press-rel…
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They took years to kill Navalny hoping you would be desensitized when they finally did. Their tactic in Ukraine is no different. Except we can do something about it.
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@brianoftoole @dantannNYC @jp_koning No, in this case JP is right, which I am happy to admit. Sure it's hard to clear a dollar transaction without touching the US financial system but it is doable.
I was under the wrong impression that dollar transactions outside the US system are subject to primary sanctions!
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Does transacting with non-USD local currency mean that new U.S. secondary sanctions don't apply?
OFAC: Nope.
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@dantannNYC @yarbatman @jp_koning Everyone’s right! Dan is spot on the clearing piece being the issue. In practical terms though, very, very hard to do much book transfer volume without clearing in US.
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@yarbatman @jp_koning @brianoftoole JP is right here. The nexus isn't the actual dollar, the nexus is the touchpoint with the physical US or US persons. That scenario of handling a USD book transfer in offshore accounts wouldn't subject it to US jurisdiction if it didn't clear through a US bank.
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@m_mosier_ Knowledge is a factor for determining significance but no longer the formal bar (or, defense from sanctions) it used to be
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@brianoftoole Good point. Typical 2ndary sanctions require "*knowingly* facilitate significant financial transactions on behalf." New EO: "conducted or facilitated any significant transaction for/on behalf." "Knowingly" often circumstantially shown, but now not even engage in that analysis.
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Sneaky big deal. OFAC removed the typical knowledge threshold required to impose sanctions. Means OFAC doesn’t have to prove someone knew the transaction was problematic. Flip it around: people may have to worry about unknown unknowns re Russia payments.
Daniel Fried@AmbDanFried
Stand by for additional US financial sanctions against Russia. This would be the third significant sanctions tranche this month (others include new sectoral sanctions and tightening of oil price cap enforcement).
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This is a novel action and goes beyond similar sanctions imposed on Iran, North Korea, and terrorists. Predicting impact is hard since we haven’t seen this before. Opens OFAC’s aperture if they choose to use it. Will watch with great interest.
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Among a litany of other reasons this idea doesn’t work: this is not legal for the US to do. It flies against all sorts of other legislation.
washingtonpost.com/opinions/2023/…
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@BrewerEricM It’s already restricted and can’t be formally “frozen” cause it’s not in the US. The US can simply refuse to allow any transactions on it by threatening to enforce existing sanctions, which would immobilize the funds.
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Would love to hear from OFAC experts (@brianoftoole ?) about what would be required to “freeze” the $6 billion, and what the implications might be for similar arrangements with other countries in the future.
Andrew Desiderio@AndrewDesiderio
McConnell & Cotton announce they’ll seek unanimous consent to pass legislation to freeze the $6 billion in Iranian assets that were released as part of a prisoner swap Comes as in-cycle Dems call for the funds to be frozen cotton.senate.gov/imo/media/doc/…
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Anyone defending this as justified needs to have a serious rethink of their own humanity
Joe Truzman@JoeTruzman
An Israel Defense Forces source provided FDD's @LongWarJournal with a photograph of a child's blood-soaked bed in Kibbutz Kerem Shalom following a Hamas-led attack on the home.
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Dusting off my writing brain after a while. @AmbDanFried and I examine avenues for increased Russia sanctions that may exist.
atlanticcouncil.org/blogs/new-atla…
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Data don’t worry about alarmist articles on the inevitable demise of the dollar
Tracy Shuchart (𝒞𝒽𝒾 )@chigrl
Dollar Usage in Global Payments in July Rises to Record, Swift Says The figures show greenback-related trades rose to a record 46% in July, compared with slightly more than one-third a decade ago. The dollar was the top currency as measured by transaction count, followed by the euro, pound, yen, and yuan. bloomberg.com/news/articles/…
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Brian O'Toole retweetet
Treasury Targets Individuals Involved in Poisoning of Aleksey Navalny content.govdelivery.com/accounts/USTRE…
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Seconded. Andrea and Brad are commensurate civil servants. And lovely people to boot. This is a big win for TFI.
Michael Mosier@m_mosier_
The Admin is rightly prioritizing technical expertise & nonpartisan public service in both appointments. Not to be lost is the elevation of Brad Smith to Director of OFAC, fmr Chief Counsel + DOJ OLC, who brings apolitical integrity & commitment to rule of law & due process.
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Brian O'Toole retweetet
100 Days of Injustice. Russia, Free @evangershkovich. Our colleague and friend, who committed no crime other than doing his job. #IstandwithEvan
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