In Focus: Sanctions Watch – March 2025

Nathanael Kurcab is a member of Morrison Foerster’s National Security Group, and his practice focuses on economic sanctions and foreign direct investment issues. He advises clients on a range of international trade and national security issues, including the scope and implications of U.S. laws and regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control and the U.S. Department of Commerce’s Bureau of Industry and Security, as well as representing clients in matters before the Committee of Foreign Investment in the United States. His practice includes advisory, diligence, internal investigations, compliance, and enforcement matters.

Representative matters from both Morrison Foerster and his previous firm include:

• Representing a multinational financial institution in an internal investigation and resulting recent settlement with OFAC;
• Advising a state-owned oil company on all aspects of U.S. sanctions compliance;
• Assessing the policies and procedures of a major luxury goods provider; and
• Investigating and disclosing to the government allegations of diversion to sanctioned parties received anonymously by a U.S. company in the metallurgical sector.
• Nathanael has also represented a range of nonprofits on a pro bono basis on regulatory compliance matters.

Prior to joining Morrison Foerster, Nathanael was an associate in the Washington, D.C., office of a prominent international law firm, where he focused on economic sanctions advising, complex commercial transactions, foreign direct investment reviews, and anti-money laundering compliance. Previously, Nathanael served in the Intelligence Branch of the Federal Bureau of Investigation and at the Afghanistan-Pakistan Task Force on behalf of the Office of Analysis of the Defense Intelligence Agency.

Nathanael graduated cum laude from Georgetown University Law Center, where he served as executive director for Barrister’s Council and research assistant for Professor Peter Edelman. He was a member of the Georgetown Journal of International Law.

Nathanael received his B.A. in Strategic Intelligence from Patrick Henry College.

Sam is the Anti-Financial Crime and Sanctions Research Lead at ACAMS, responsible for driving research across the breadth of global financial crime risks. His role includes co-authoring and leading the data analysis behind ACAMS flagship annual Global AFC Threats Report, as well as other research initiatives. Sam also delivers sanctions masterclasses and webinars, including the monthly sanctions watch series, and regularly speaks at conferences, helping institutions strengthen their AFC and sanctions controls and capabilities.

Prior to ACAMS, Sam worked on the Sanctions Policy team at UK Finance - the trade association for the UK banking sector, as well as at NATO’s Center of Excellence for Defence Against Terrorism.

Justine draws on a diverse global career, working across government, regulatory, private sector, and international organisations. As an expert on sanctions, counterterrorism, and financial crime she has held specialist positions within the UK’s Financial Conduct Authority, HM Treasury, the United Nations Office on Drugs and Crime (Central Asia), the British Bankers’ Association, and UK Finance. In addition, Justine was formerly part of the UK delegation to the Financial Action Task Force, chaired the European Banking Federation’s Sanctions Expert Group, co-chaired the UK Joint Money Laundering Intelligence Taskforce’s counterterrorist financing group and served as an International Monetary Fund advisor to Nigeria. She has acted as an independent Syria sanctions-humanitarian expert to the United Nations, and previously served as a national expert on the financing of weapons of mass destruction (WMD)/counter proliferation financing matters. 
 
In her role within ACAMS, the world’s leading membership organization with a presence in over 180 jurisdictions, Justine oversees the subject-matter-expert division. A regular contributor to media publications covering financial-crime issues, she has addressed UN expert groupings, given evidence to parliamentary hearings, and authored numerous publications. Justine also holds a Ph.D. from the University of St. Andrews and an M.Sc. from the University of Edinburgh.