Activists and politicians tout beneficial registries as a solution to the perceived abuse of anonymous company ownership. Stephen Baker and Charlie Sorensen of Baker & Partners contend that kleptocratic dictators and sophisticated fraudsters won’t be impeded by such registries. The authors explain how existing civil laws have proven effective in seizing ill-gotten gains. Recent high-profile […]

Europe has come up with a nifty plan to help Iran buy and sell stuff outside the reach of U.S. sanctions. The problem is that the plan is a fraud magnet. How do we know? The plan is known as the “Instrument in Support of Trade Exchanges,” or “INSTEX.” Lots of smart people have been […]

A 50% narrative sanctions applies to an entity not sanctioned by name or appearing on a blocked / restricted entity list but is covered by a narrative statement on a sanctions program extending such sanctions to such non-listed entity. Firms face the challenge of understanding to what extent they should screen their customers and key […]