In Focus Sanctions Watch: Anticipated Priorities of the Next U.S. Administration

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.

Sam Cousins is a Senior Associate at ACAMS, where his work includes supporting public-private partnerships and strengthening ACAMS thought leadership pillar through the development of content on sanctions and risk, particularly the Sanctions Masterclass program and Global Monthly Update. Sam's work also focuses on countering ransomware financing, which includes enhancing industry awareness of the anti-financial crime risks associated with ransomware attacks and supporting the mitigation of those risks through policies, training and public-private dialogue.

Prior to ACAMS, Sam worked on the Sanctions Policy team at UK Finance - the trade association for the UK banking sector.

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.

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 partner of the Global Risk + Crisis Management group and Investigations + White Collar group. After serving 11 years as a top official at OFAC and three years as its Director, John brings to the firm unmatched experience in economic sanctions, enforcement, and national security.

Both in the United States and globally, clients turn to John 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, John 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. John 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.

John 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.

Matt Zweig is Senior Director of Policy at FDD Action. Previously, Matt served as Senior Fellow at the Foundation for Defense of Democracies. From July 2019 to December 2020, Matt served as the Senior Sanctions Advisor in the Office of the Special Representative for Syria Engagement. He worked with bureaus across the State Department, interagency partners, multinational counterparts, and others to help implement the anti-Assad economic pressure elements of the administration’s Syria strategy.

From 2001 to 2018, Matt served on the House Foreign Affairs Committee, including for more than 10 years as Senior Professional Staff, where he was responsible for sanctions and illicit finance policy. Matt managed the successful negotiation of multiple pieces of legislation including the North Korea Policy and Sanctions Enforcement Act of 2016 (including 2017 revisions); the Hizballah International Financing Prevention Act of 2015 (including 2018 revisions); the Caesar Syria Civilian Protection Act of 2019, and the Iran Threat Reduction and Syria Human Rights Act of 2012. He also managed negotiations regarding hundreds of foreign policy provisions within successive National Defense Authorization Act reauthorizations. Matt holds a BA in History from the College of Charleston, an MA from the University of London King’s College, and an Executive MBA from George Mason University.