Brian and Tim kick off this episode by digging in to the implications of the newly announced U.S. sanctions targeting the Nord Stream 2 project and why they may amount to an admission of defeat. Next, we check in on the seemingly imminent JCPOA 2.0, the latest court challenge to the CCMC List, and a recent report issued pursuant to the Hong Kong Autonomy Act. Finally, in the Lightning Round, we consider OFAC’s ransomware guidance following recent high profile attacks and share our initial thoughts on the possible fallout from the diversion of a Ryanair flight by Belarus to arrest an opposition journalist.

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0:10 Introduction and Roadmap

The Rundown
4:27 SAP NPA and OFAC Settlement
21:38 MoneyGram OFAC Settlement
28:28 Alliance Steel OFAC Settlement
33:25 Honeywell DDTC Settlement
40:46 Luokung Takes Another Bite Out of the CCMC List

58:00 Lightning Round
58:12 JCPOA 2.0
1:11:26 Signals on Venezuela and Cuba
1:16:43 Belarus GL 2H

1:20:52 Final Thoughts

***Stay sanctions free.***