Sanctions enforcement and anti-money laundering controls44

0:00It's the tip of the spare in the epic battle to defend the United States of America. The National Security Hour exposes the wolves and sheep clothing and then a various plots to undermine and destroy US national security. Welcome to the National Security Hour on the Merck Adler Talk Radio Network on I Heart Radio where you're going to hear the voices of freedom, dot-law, truth, family and intel experts worldwide. And Merck Adler Talk Radio plays on I Heart Radio Network. You can also listen on our media player from any web browser anywhere in the world. We had the best in class apps available on Apple, Android and Alexa where we stream 24-7 and now you can also hear them on the podcast on those same apps.

1:01I'm your host with 10 Colonel Sorghissing here, US Army Retarded, CEO of the Near East Center for Strategic Engagement and also Board Member of the National Security Hour. Today is a dear guest of mine, a friend we haven't talked for a while but I'm glad we had a chance to catch up again. Nicky Kenyon who has more than 15 years of experience and intelligence community in private sector including in defense budgeting capabilities analysis, risk management and anti-money laundering sanctions and counterterrorism. I do want to apologize to the listens out there a little bit under the weather. The kids started school just last week. They ended up bringing some crud home which dad is dealing with. But as I said, Nicky's anti-money laundering and combating the financing of terrorism expert and I feel the refers to the policies and measures are designed to prevent and combat money laundering and the financing of terrorism insurance is the integrity and stability of

2:06the financial systems that we've worked through. Nicky is also a sanctions and AMLCFT expert content developer analyst and trainer. Nicky is good to have you here as a pleasure. It has been a while since we did an interview and I did an interview on my own podcast while I go with you on the Russian sanctions. But I do want to follow up especially with the new push on stronger sanctions against the Iranian government and take your perspective. Where are we with Russia and where are we with Iran? All right. Well, first of all, it's really, really great to see you and I had to feel freaky when somebody refers to me as an expert because I usually refer to myself as just a geek. But all of that being said, I do follow these issues super closely. So with every presidential administration and I've worked for Bush, I've worked in the

3:09Obama administration, I worked in the first Trump administration. So with every administration, there's always a pivot because every president has different priorities. Right? So with the second Trump administration, the government has kind of pivoted from Russia sanctions to Iran, to counter terrorism, to drug cartels. When Biden first came in, Russia launched its full-scale invasion of Ukraine within a year. So the Biden administration executed this major pivot to holding Russia accountable for its aggression. Thousands of sanctions. And I do mean thousands. And other restrictions were imposed on Russian individuals and entities.

4:10Those included a $60 per barrel price cap on Russian oil. Restrictions on exports of various goods and technologies critical to Russia's invasion. Designations on those who facilitate Russian sanctions of evasion. In December 2023, Biden signed this executive order, or EO14114, that gave Treasury new authorities to impose sanctions on foreign financial institutions that helped Russia build up its war machine. And their sanctions are a bit of a different beast. In 2024, Treasury declared that any entity designated pursuant to executive order 14024, which was the Russia-Maligned Foreign Activities designation, is part of Russia's pivot to

5:15a wartime economy and therefore subject to secondary sanctions. So any entity that sanctioned under 14024 is a secondary sanctions risk. So what does that mean? It basically means that sanctions, they cut off the designated entity from the US dollar, normal sanctions, right? For penalties to be imposed, the transactions have to have what's called the US nexus. So they have to use the US financial system. They have to involve a US person or legally permanent resident. It has to be on US soil. That kind of thing. Secondary sanctions don't have to involve the United States in any way and don't have to have a US nexus. So if we find a foreign financial institution that's transacting in, I don't know, euros or

6:16rubles or whatever. If we find that financial institution and it's actually transacting with Russia's military industrial sector, we can go ahead and designate that, cutting it off from the US financial system, from US markets, from US customers, right? So they don't have to involve the United States and we are prohibiting US persons from transacting with anyone who is helping Russia. Even if the transactions don't touch the US financial system. So that's a little bit of a background, right? The Biden administration relied heavily on sanctions, but with the second Trump administration, there's been what I call a pivot. The priorities of the second Trump administration are different and the Treasury pivoted to Iran,

7:18like I said, to terrorism, to cartels and very, very few Russia sanctions were imposed since President Trump took office. But there's still a lot of risk. So several cartels were designated as foreign terrorist organizations or FTOs. This means that if you transact with them, it's not just civil monetary penalties. You can be held criminally liable and prosecuted. Okay, with regular sanctions, like, oh, fact, we'll go after you. They'll say, okay, there was aggravating, you know, like aggravating factors, there's mitigating factors. Here's your civil monetary penalty. We have a finding of violation, whatever. With an FTO designation, you can be criminally prosecuted, right? So now, US persons need to be super careful when they're dealing with risky economic sectors.

8:25And these sectors can be pretty unexpected, right? We know about fuels, like cartels are heavily involved in fuels, whether it's smuggling or stealing or whatever. But what about real estate? What about agriculture, limes and avocados in Mexico? Those are big sectors in which cartels are involved. What about grocery stores? What about telecommunications? And listen, mining, they are so involved in different financial sectors and they are developing new ways every day about how, like, evade sanctions, move money, you know, still access to global financial system. They're now, you know, engaging with Chinese money, laundering organizations to, you know, wander drug proceeds. So any kind of financial institution or firm is going to have to protect itself from

9:26possible criminal prosecution. They're going to need to dig. They will need to find out whether there's any kind of cartel nexus, especially if they're located on the southwest border. So that's kind of in a nutshell about, like, what is going on right now with the different focus on different designations. You know, you mentioned, I mean, as a risk to America, as a friend of mine who actually did a lot of when it comes to compliance to ensuring that they're meaning the basic health, recreational requirements. And he has worked in Mexico before he's actually has gone there. And everybody knows that the cartel runs the, as you said, the avocados and, you know, one time he was actually called to go in and look at issues that they were having for some of their produce. And of course, you know, he's like, oh my God, you can't like defecate in the river and then wash the produce and just say what it is.

10:28So the problem is, you know, the question from an individual like him is, is that listen to that, am I going to be in trouble now because I'm giving advice, getting paid for basically simple issues that the agricultural system does because what do we like it or not? Because it even my kids are eating are still coming through Mexico and are actually being run through our borders, illegally by the cartels. So how does an individual in America like him who has a business not getting trouble because he's trying to meet the requirements of American FDA to ensure that, you know, what is coming through the borders actually meets the requirements at the beginning before it comes here for the help risks that may end up killing Americans. Well, I mean, so I'm not a lawyer, but what you're describing does not sound like a financial

11:29transaction, right? It sounds like, you know, he's working with, you know, specific farmers or, you know, cattle ranchers or whatever. You know, these FTOs and the risk of criminal prosecution has more to do with moving money for them, um, transacting with them. So if you're a financial institution, you know, you're going to be, you're, you're going to need to look at your counterparties. Who are these counterparties? You know, who are they linked to? I mean, these cartel guys, they're, you know, they're smart. They're much like the Russians. They will use different methodologies to hide behind, you know, to hide their assets, to hide cartel involvement. So, you know, you may have like a cartel member's mom, you know, you do your research on her and she's, you know, she seems like a nice lady. Um, okay. Yeah, no problem. But, you know, her son might be like a high level cartel guy and she's keeping money

12:35for him. So, you know, you really have to be careful when you're doing your research to make sure that, you know, there's not just a direct link, but there's also a, like, you know, an indirect several hops way link. And Nick, when you're doing like, I'll, I'll maybe use on that example. If you're doing, uh, know your customer, right? And there's a company out there that's legit in the company. Let's say just moving oil. And I know this was an issue where we're dealing with a couple of years ago. So the oil, you're purchasing it from, um, in this case, let's say Iraq, which is Somal oil and let's see, it's bus or light. Well, it, there's certain additives that you add. You could change where the oil's coming from. Right. If you have Iran and, and Iraq using basically the same field that they're collecting in oil from because, you know, the oil is on the ground and it crosses over the borders. It doesn't matter. And you send it to a certain refinery refinery refines it to the way it wants with certain

13:38additives and they're able to sell it on global market. How can you as an American or as a company and somebody who's involved in those type of transactions really know the details of whatever not. This is something that is Russian or Iranian, if it's sanctioned or not. I mean, it puts you in a position and say, well, maybe I shouldn't just do any business at all in that type of a sector. But the big companies are doing it all the time. You know, so the little guy sometimes gets squeezed out because he may not have the resources. How should a smaller company capability kind of address these issues? I mean, with a smaller company, it'll all depend on its first appetite, obviously. You know, but they need to do their due diligence. They need to examine the documents, right? The trade documents. They need to examine the trips that the vessels are making. You know, there's obviously no compliance measure is perfect.

14:41But we're looking at where is it coming from? Is it a known hub to refine illicit oil? Are there been specific evasions such as like turning off your automatic identification system or ship to ship transfers? All of these guys learn from each other. This is something to North Koreans have been doing for years. So these are well known methodologies. So you know, the big thing is do what you can to trace where the origin of the oil is and who is involved? Yeah, that's all you could do. And hopefully you've done your job and there's nobody knocking your door at the bit of a little bit. So, you know, it is a risky business, but it is what it is. Well, there is something called safe harbor. So if they did their due diligence and if they did everything possible to make sure that they weren't transacting with illicit oil, you know, obviously regulators are going to

15:44look at that too, right? So it's kind of a mitigating factor. They're just saying, okay, well, you did all you could. You know, so nobody's going to toss you in prison. It's a mitigating factor, but you have to show that you did your due diligence, that you tried, that you got documents, that you examined all the records. And I do want to concentrate when we come back for the second segment on really what are the current status of the Russian sanctions? Those sanctions regime still exist and what do the general licenses and waivers mean, which is important for us? I do want to remind our audience as I mentioned this section, the, you know, Iran sanction bill that was recently passed aimed to strengthen U.S. sanctions against Iran targeting its illicit oil trade and financing of terrorism. And then it's supposed to include enhanced Iran sanctions acts and so we'll fight Iran

16:48sanction acts specifically, but we will be back again for our discussion on really the sanctions, which is being pushed by both Trump against Iran cartel critically and has been in the past pushed by Trump Biden and others when it comes to Russia specifically. We'll be back for our discussion with Nikki Kenyon, who is a sanctions and AML CFT expert kind of develop an analyst and train. One in three people will face cancer and most never see it coming. I'm Dr. Kelly Victory with the wellness company and I know this personally. I exercised daily, avoided processed foods and had no symptoms when a routine mammogram resulted in a cancer diagnosis. And modern medicine is often reactive instead of preventative. That's why I formulated shield, a two-part system designed to support immune health and antioxidant defense. A chemical-free cocoa mix and soft gels prevention is power. Visit TWC.health slash out loud and use code out loud for an exclusive discount.

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18:54Go to chemicalfreebody.com, forward slash out loud for an exclusive discount. That's chemicalfreebody.com, forward slash out loud. And I quote, you and I have a rendezvous with destiny. We will preserve for our children this the last best hope of man on earth. Or we will sentence them to take the first step into a thousand years of darkness. Those are the words of number 40. Ronald Reagan shined right as America approaches 250 years. America out loud.news is that place to awaken your heart, soul and mind to the out loud truth. Welcome back to the National Security Hour in America and Outlaw Talk Radio Network on the IHard Radio. I do want to remind everybody that all the shows that we do go to podcasts typically

19:55one or two days after the broadcast has heard on the talk radio. You can also hear them on Spotify, Stitcher, Pandora and IHard Podcast. And many more. Be sure you subscribe and rate the shows on Apple Podcasts for us. Also be sure to make America out loud.com. You daily stop for the latest news and happenings. We almost do our part and share the stories. There are articles of the videos so that we can help secure America's future. My discussion continues with a dear friend, Nikki Kenyon, who has managed teams responsible for sanctions, compliance, customer due diligence and enhanced due diligence and know your customer KYC. As I mentioned in the last segment, she's written numerous articles and reports and conducted webinars on financial integrity and developed in person an online instruction for divers,

20:55audiences and realm of illicit financing. Her passion is protecting the global financial system from abuse by illicit actors, by providing training, research and analysis as well as identifying and assessing potential illicit financial transactions, sanctioned evasion, money laundering and reputation risk management. Nikki, I do want to come back and take a look at where we are currently with the status of the Russian sanctions. I do know that we're really pivoting on the cartels in Iran and those sanctions regimes still exist. Yes, there are numerous different executive orders on Russia. I mentioned previously Executive Order 14024, which is the Russian-Maligned Foreign Activities Executive Order. I mentioned 1414, which is the Secondary Sanctions EO.

22:01There's the ones that were implemented during the Obama term when Russia first invaded and illegally annexed Crimea. Yes, Russia sanctions still exist. We have the Mognitsky Act, which is human rights violation and corruption sanctions. There are still thousands of individuals and vessels listed under that regime and pursuant to these numerous executive orders. Then there's hundreds of vessels and aircraft that are still listed as blocked property in addition to these individuals and entities. As always, enforcement is an issue. Officials cannot be effective if they are not enforced. I recently wrote this article about whether the Trump administration was going to finally get tough on Russia.

23:02All indications say no. They have not been enforced since the president returned to the White House. There were threats, sure, but there were only really a handful of sanctions imposed. I haven't seen really a whole lot of settlements on the OFAC website that indicate otherwise. Nicky, if I could drop in here. Because I know that you mentioned the 14-024 Executive Order, established April 15th of 2021, a new national emergency that allows us to impose blocked sanctions on individuals and entities. I know that the current poll does not be pushing it, but if you look at what the definition of executive orders is, they still remain in force until it's canceled or evoked or adjudicated lawfully. Trump hasn't come in and said, okay, bye-bye to the Biden executive orders, correct? The right.

24:03Correct. It's just an effort. Go ahead. But he has begun delisting some of the individuals and entities that are on the list, on the SDN list, the specially designated nationals list, under EO 1424. Right? I mean, there are threats. And again, I mentioned the OFAC website, the enforcement actions that have been published. Violations appear to have taken place years before Trump's return to office. But yes, there are still thousands of individuals and entities listed under 1424. And other executive orders. But look, in July 2025, President Trump issued a 50-day deadline for a ceasefire or a peace deal, threatening secondary tariffs targeting third-party nations that continued to buy Russian exports.

25:04Does anything happen? No. In August 2025, Trump warned of very severe consequences and devastating financial penalties if Moscow blocked peace efforts. Did anything happen? No. In September 2025, Trump posted on Truth Social that he was ready to sanction in Terra Frussia and nations that supported claiming that Moscow would never have attacked Ukraine, had he been president and demanding that all NATO nations stop buying Russian oil. We haven't seen any enforcement of that. Not even of the oil price cap. The UK did say recently, or a few months ago, that it helped the US seize a falsely flagged sanctioned vessel, the Bella one marinara.

26:04That sounds like food. It sounds like food. It sounds like food. Yet the US action was based on counter-Iran sanctions to stop the shadow fleet confirming the Trump administration's pivot away from Russia and toward Iran. And we've seen some sanctions relief via waivers for Russia to sell its oil that's already en route. Because of the price shocks of the Iran War, the waivers were issued. They were renewed twice and finally allowed to expire in June like a month and a half ago. Or wait, it's September already. So two months ago. We've also seen removals from the SDN list, the OFAX sanctions list, right? So Treasury claims these removals are not an indicator of a broader change in US policy toward Russia. But again, I have a butt.

27:05Our tone is considerably softer. We've imposed almost no new designations against Russia, and our allies are noticing, especially after last year when we withdrew from efforts to investigate Russian war crimes and hold Russia responsible for its aggression. So yeah. You know, the one thing I think people have to understand too, and you have me understand it, but executive orders in themselves give flexibility to adapt policies that needed while maintaining check and balance to traditional oversight. Who's going to be a traditional oversight on these executive orders? So the way these particular executive orders work, right? The White House issues them. And obviously they're coordinated throughout government. So agencies that are stakeholders will have a say, they will take a chop.

28:05They'll do that. But really, I mean, OFAX will implement the executive order. It will designate specific individuals and entities under an appropriate executive order. And it can remove them too. This past April, there were three Russian vessels that were removed. The Nikolai, which was implicated in transporting stolen Ukrainian grain, the Fesco monoron, or I'm totally butchering these names, and Fesco Magadan linked to shipments of military or dual use goods. In March, we delisted the husband and wife team Yuri and Lydia Krasnodin. They were first designated in May 2024 because of their links to the Russian Transport and

29:05Logistics Company, L4TL. OFAX sanctioned that company in December 2023. OFAX last year removed one of the rotten birds, or wives. The Trina Rotenberg, the wife of sanctioned Russian oligarch Boris Rotenberg, she was delisted. Anyone who follows illicit finance knows and understands that sanctioned actors use proxies, family members, close associates, two of age sanctions, transfer their assets to the wives, and we're good, right? So delisting Karina Rotenberg opens up a doorway for her husband to really just be followed by the US financial system. So do these EOS still exist? Yes. Are they being used barely? And a lot of times, you know, people are getting delisted. No, I mean, yeah, one of the ships that initially measured that the British forces had intercepted

30:11in June, 14 of this year, the MV Symmetros. So I guess if you get tagged on sanctions, are you doing, are you that bad of evader? Your entire ship is getting captured? Or I mean, is it because finding somebody has done their job to ensure that, hey, you know what, you might look at this particular ship that falls onto that shadow fleet. If you could give us a little bit of explanation about the shadow fleets are for those listeners who may not know how they operate, especially when it comes to the violation of sanctions, you know, regarding Russian aggressions into Ukraine. So these methodologies are really similar. The shadow fleet is used by Russia. It's used by Iran. Basically, they flag hop. They use really sketchy insurance companies, if any at all.

31:13And you know ships need to be insured, right? Tangled ownership and control structures that make identifying the owners of these shadow fleet vessels difficult. These are not like modern vessels, right? I mean, the Russians basically go to like a nation like Greece and say, hey, you got any junk ships we can borrow or buy? And then they buy the ship. You know, they flag it, they register it with like some kind of jurisdiction that doesn't even have like a port, but they offer ship registration. You know, and they move through international waters. They turn off their automatic identification systems or AIS. They move the oil, you know, they'll turn it off. They'll go somewhere. They'll transfer to another ship. They'll turn their identification their AIS on again. And boom, done. You know, it's very, very common.

32:17And that's how they kind of, you know, they move their stuff around. Yeah. And if I can go up in here, Nicky, I don't think a lot of people don't even know. I mean, there's a lot of stuff you can buy in cash. I mean, private citizens, there's C-130s, they're in mutball. And when you can't, you can't move oil. Well, you can't move oil and C-130, but I'm using as an example that you can move other stuff because when we were looking at what was happening in Afghanistan, and we just, you know, passed another anniversary of the Afghanistan issue, we were literally looking at buying a C-130 out of mutballs, flying it, and we had our own pilot to pick up folks and get them out of there. So I mean, it's possible. I mean, if individual private individuals can do it, you know, countries with nuclear weapons of money, you know, stash the way some work can do it. I guess my only question would be here.

33:19Is it possible for companies to be used by the Russians and others to evade sanctions where the company doesn't even know it's being used? Yeah, of course. There are a ton of firms and entities that are unwitting facilitators, right? And it's kind of scary because, again, the Russians are, you know, they're pretty smart about how they use different, you know, different entities, right? And yes, a lot of times you don't even know it, and they won't know it because maybe they don't have the resources to do counterparty research, or maybe they don't understand how to do research properly, or how to research whom they're really doing business with. It does happen.

34:21You know, the biggest thing I can say to smaller companies with fewer resources is you need to know who you're doing business with, you need to know who you're transacting with because guess what, OFAT has a strict liability principle, which means you don't have to know that you're violating sanctions. You don't have to know it. You will still be penalized. You just have to do it, okay? So like, it can be winning or unwitting, but you need to make sure that you are at least doing the best you can to present that from happening. How about five or once you trees into national organizations? I mean, could they have laundered money without knowing that they're laundering money? Yeah, of course. They're being used all the time. You know, a lot of, like we've noted a lot of nonprofits and charities being used in terrorism financing. You know, some of them are winning.

35:21Some of them are like front companies and we're established specifically to move terrorist funds, but others, you know, they're asking for help. They're asking for money. And then they don't know where that money is going or how it's being used on the other side. The donations are absolutely legal. And that's the biggest difference between money laundering and terrorism financing is that money laundering hides illicit origins of money. And terrorism financing really, the origins are legal, but they're going to an entity that may use a for terrorist organizations. So, I mean, you know, I'm just good information. I hope our listeners are understanding how complicated it is. The lowest level really everybody has to do their job. It's like as we say, right? If you see something that doesn't look right, report it. And, you know, it takes all of us to be able to at least kind of focus and try to protect ourselves

36:27at the same time protect the organizations we're working with. And the financial system. Yeah, and the financial system. And then that way we were able to at least put pressures on the countries needed. I do want to come back and the final segment and really kind of look at, you know, what is needed maybe for the sanctions to be more effective. And then the biggest piece I'm going to understand is the so-called new approach on Iranian sanctions. Is there anything different than what has happened in the past or how we do anti-money laundering and also looking at the financing of terrorism? Is there something that has is different than what we've seen in the past? But we'll come back for the final segment of our discussion with Nikki Kenyon. Nikki is also a US Army veteran. But I served both in active duty in the National Guard. She has a Master's of Arts degree in National Security Studies from the American

37:31Multi University and a Bachelor of Arts in International Relations for and John Hopkins University. We'll be back for our final discussion on the sanction. Have you been looking for a healthy snack from the go? Well, not all energy bars are soft and sugary. Bear bars are a crunchy, savory bar made from just six simple natural ingredients. Bear bars are plant-based organic gluten-free, contained six grams of protein in a low temperature dried for a unique crunch. Most energy bars are based on chocolate or fruit and are held together with surps or sweeteners. To learn more, just visit bearbar.com slash out loud. In a world of rising prices, you can still grow abundance. I'm Doug Evans, author of the National Best Seller, The Sprout Book. Sprouts grow in three to five days without soil, sunshine or fertilizer on your kitchen countertop for under a dollar serving.

38:33Take control of your food and your future. Visit thesproutingcompany.com slash out loud and use the code out loud for an exclusive offer. Grow food not fear. Welcome back to the National Security Hour and American Adelaide Talk Radio Network on iHeard Radio. I do want to remind everybody that you can find out more about this show and get all the latest podcasts if you go to the menu navigation bar at americaadelaud.com under our show or schedule, you will be in the know. My discussion continues with Nikki Kenyon, who has multiple certification in elicit financial matters from ACAMs, ACFCS, UN office on drugs and crime, the institution for financial integrity. And we've been looking and talking specifically on the Russia and the Iran sanctions.

39:33And in this final segment, I do want to concentrate on what is needed for sanctions, re-effective enforcement, secondary sanction threats, exposure to the US dollar, etc. But I do want to kind of have us maybe explain to the audience out there. What is it that Trump might be doing that is different when it comes to the Iranian sanction currently than it has been done on any other country in the past? So, this administration appears to prefer tariffs versus sanctions. So, compared to the Biden administration, which for example made Russia almost impossible to do business with after the full-scale invasion of Ukraine, treasuries now, as you said, focusing on Iran. But here's the problem. Iran is already in bargoed. So, any extra sanctions on the country are basically superfluous. Okay, we cannot do business with Iran. The international community has been imposing sanctions,

40:38trade embargoes, asset freezes, you name it against Iran for decades, for anything from its nuclear activities to human rights violations, and support and exploitation of proxy terrorist groups to wage war against its enemies. So, treasury has done one thing. They're focusing on the facilitators. Okay, great. But here's the thing. Again, Iran is already in bargoed. So, in fact, recently designated 10 individuals who are part of a network that's responsible for transferring cash to hisvola. Iran's most powerful terrorist ally. But the treasury press release said hisvola is being re-designated, right? It's already sanctioned, as especially designated global terrorist, pursuant to executive order 13224 by the State Department. State in 97 also designated hisvola

41:42as a foreign terrorist organization or FTO. So, re-designating it under the same authorities, like what is the purpose here? You know, we're re-designating it now for service to the Iranian regime. And it seems like more messaging than actual effective action. So, they've started sanctioning these Chinese teapot refineries, right? These like tiny little mushrooms that pop up to refine Iranian oil. But here's the thing. Again, most of them don't have exposure to the US dollar. So, sanctioning them does nothing. They don't care. They wouldn't care because they have zero dollar exposure. So, we're kind of playing whack-mole here. You know, by the time we designate the bad actors, the facilitators, the small banks, the underground networks that facilitate Iranian money movements, they're already on to the next best thing, right? So,

42:45you know, messaging is nice. And yeah, you know, we're getting tough on Iran. You know, great. But are we really doing anything differently than we have before? Yeah, the US re-designation and Hezbollah as a terror group basically states that they're an other terror group and service to the Iranian regime. So, they've been its terrorist groups since like 97. Well, they want quote that the state of Barbara says, well, they are not a Lebanese resistance movement. So, I, like you said, it's probably more political messaging. I don't know how they change things are illegal, definition wise, but it doesn't. You know, Iranian proxy not a stand-alone operation has implied, but a previous designation. I mean, we've always said that it's not a political movement and it's always been like really, really hard to kind of impose sanctions on it because

43:47a lot of our allies were like, well, it's a political party, but it's also like it's got an operational arm, you know, but therefore it's really, really hard to sanction them. There's another piece too. You know, we're looking at it says, you know, tariffs on the Iran are additional taxes and polls on goods imported from countries that create with Iran as President Trump, while sanctions are broader restrictions that limit trade and financial transactions with Iran to pressure its government. So, what is for the layman here who's listening to the broadcast, what does that even mean? Well, okay, look, you know, we've, we've seen reports, China buys more than 80% of a broad-shiped oil and Chinese independent refineries, these little teapot refineries, account for quarter of Chinese refinery capacity, operating with narrow and sometimes negative profit margins.

44:53They don't care. So they have negligible exposure to the US dollar. Would they care probably not? You know, what about Chinese banks? Trump has already threatened bigger Chinese financial institutions that they could face secondary sanctions. If Iranian funds were found moving through their systems, but have they been designated? No, they haven't. And I would wager that the need for China's minerals that are critical for like technology production will probably prevent that threat from becoming a reality, right? So, you know, it's, we're playing whack-a-mo, like I said. If I could kind of pivot to Ukraine real quick, I mean, one of the, one of the discussions I had, you had, you know, you're trying to get Ukraine and Russia to come to some kind of an agreement from this war, the EU sends weapons to Ukraine to fight against the Russians and kill, of course,

46:02the Russians, soldiers and bushels, but then turns around and buys oil from Russia. I know. These Russia uses to create an army to go and continue the invasion of Ukraine. I mean, it sanctions, it sanctions ever get a work in this type of a process or. So, so here's the thing, right? Like the UK just imposed a record fine on city for transacting with Russia. A lot of these, a lot of these purchases come from like long-term contracts and then there's, you know, the problem of like certain EU members who are like, well, we can't get oil from anywhere else. So, we're going to block any kind of action. But, you know, it makes me nuts. They're working on it, but it's like this gradual reduction. You know, will they ever actually remove their dependence on Russian oil? One can only hope.

47:09You know, the Trump administration is focused on tariffs. So, will they, you know, impose massive tariffs on China, especially given our need for these critical minerals? I doubt it. Okay, yeah, they can impose tariffs on Iran. Like, how much trade do we have with Iran? Yeah, it's a, how much, okay, my question here would be then as we're looking at it, from all the years and experiences that you've had as we're looking at closing off the segment. What is a couple of things you learn? You said, you know what, if there was a change made by Congress and a lot of us pass, or a approach that would help us really give more oomph behind not just the executive orders, but also the approach to sanctions. And of course, then my other question

48:11also would be how does new technologies with, you know, artificial intelligence give us a much better means and ways of it does to be able to address these issues. Okay, so we can talk about AI and sanctions probably all day. To give you a bottom line is AI is making sanctions of Asian and trade control of Asian and trade based money laundering a lot easier because it's easier. It creates very realistic documents. It creates synthetic identities. It creates very complicated and very involved ownership and control structures. And so you can use AI to fight AI, but you're going to need experts because experts can take a look at language in the documents. They can take a look at, you know, and see if the passport card looks fake, stuff like that. So, I mean, this is a whole other thing. What can we do? What can Congress do?

49:18I mean, they pass this, you know, the new Graham sanctions bill that's in the House right now. You know, the problem is that number one, there's a section in there, section 115, that basically gives the White House authority to wave sanctions. Why are we passing this bill? That's supposedly this really tough bill. If we can just tell the White House, hey, you know, if you certify that, you know, they're not engaged in bad activities anymore, you can just wave sanctions. No, that's not the way any of this is supposed to work. If that wasn't in the bill, is the bill effective in itself? Would it be effective, more effective? Is it based on lessons learned from, you know, years of dealing with sanction invasion? It's got a few good things in it, right? But it's also got like a lot of,

50:24it's got a lot of loopholes. You know, like in this current one, the sanctions will become automatic as soon as the bill is enacted. Great, okay? It includes some measures against Russia's shadow fleet. Great. You know, it includes tariffs on Russian origin goods. You know, and so, so that's okay. There are some things in this new bill that weren't in the old bill. But now, again, you know, the president has authorized to end sanctions if he certifies that a peace agreement between Russia and Ukraine happened. Well, you know, they're pressuring Ukraine to basically give up its territory. It's like, you know, you have a home invader who goes in there and you're fighting him and you're shooting, you're having a shootout. And the cops come and they say,

51:27hey, you know, if you give them part of your house, it'll all be good. Now, that's not the way this works. You know? So there's a couple of things. There's some loopholes. Like that, that section 115 that I mentioned, also section 110c, the financial messaging system waiver. So if the White House decides that it's in the interest of national security, Russia's SPFS, which is it's alternative to Swift because its banks were kicked out of the Swift messaging system when they first invaded Ukraine. It could be spirit sanctions if the White House decides we need it. What a heck! Would we need a Russian financial messaging system? Come on now, right? It's got a bunch of exceptions that are built in. You know, it can adjust the tariffs. There's more flexibility and there's

52:34less flexibility. So there's some trade-offs in that bill. It seems I think it goes back to those executive orders, right? I mean, I don't know, Trump's approach on using tariffs and sanctions. You know, blockades. I mean, how long are we looking at if there's going to be an effect or change? How long are we looking at being able to study what might be the effects on what the voters are trying to do and best of this trying to do when it comes to Iran? Is it going to be immediate issue? No, it's not going to be immediate. I mean, you've seen this. He kept saying, oh, it's going to be a couple of weeks. And then Iran's life, no, it's not. We're going to, you know, we're going to attack you here. We're going to attack you there. And it's, it's everything in government, especially with the country's largest hours with our huge bureaucracy. It's going to take a while. Everything is going to take a while. You know, I've always said,

53:40and I think I've said this on your show before, sanctions are a long game. Russia is the 11th largest economy in the world. So to say that, hey, you know, we're going to impose sanctions on you and cut you off from the global financial system. Well, you know, there's going to be different means that they use to evade that. It's going to take a while. And we're seeing these effects now in Russia where, you know, people get it by food. They can't buy gas. They're, they're going to be feral. They're literally like fighting each other and, and slashing each other's tires, standing in line for two days just to fill up their car. I mean, it's, it's a little nuts over there, right? Well, the people are always going to, you know, take the brunt of it, but the guy that is causing all the problems, still in, in play and power. So, I mean, yeah, I mean, you know, unless

54:44we send in an assassination team, I don't think that's going to impact her. I'm sure there's a bullet that says you can't do that either. Yeah. Pretty sure we can't be doing that. We can't, we can't do that. But look, every, we still have to try. It doesn't mean that we shouldn't. And I guess the lesson learned from, from this discussion to everybody is just do your diligence, know your customer and try to do your best to be able to help the government and the sanctioned process move forward so that you don't become a burden on the process itself. Nicky, I wish we had more time, but unfortunately, come to the end of the segment. I do want to remind everybody that you could take a look at Nicky's work. If you go to Irene Kenyon dot sub stack dot commas are another place that they could go. No, that's it for now. The site is called into the void. And I write on illicit finance issues are right on foreign policy. I write on sanctions policy.

55:46Sometimes I have guest authors that open on various things. So there's a little bit for everybody. Nicky, we are going to have you back again in the future. Hopefully, things calm down a bit. Hopefully things have calm down and then we'll see. You know, you never know, maybe a meteor will land and end all the sanctions. And kill all the dinosaurs. Yes. Nicky, it was a pleasure. Again, I do want to thank you for joining me in our discussion. I don't want to thank all our listens out there for joining us on the mission, the National Security hours. It's a tip of the spear in the epic battle to defend it. United States of America, the Liberty and Justice for all. I'm your host, Lieutenant Colonel Sargis and Gideon. You're a summary retired. So you have the Near East Center for strategic engagement and a board member of the National Security Hour. We will talk to you next week. God bless you all. Take care.