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Regulatory Ramblings

Regulatory Ramblings: Episode 73 – Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia

This episode focuses on geopolitical risk. In the initial spotlight segment, we speak with veteran journalist and Asia-watcher Christopher Cottrell about the military tensions in Thailand and their implications for the viability of the country’s newly proposed gaming law.

Following that, we chat with AML veteran Richard Butler of Dow Jones and data scientist Haider Mannan of BigTXN about the enforcement of the US Foreign Corrupt Practices Act, sanctions, and tariffs in the wake of recent actions by the Trump administration and the recent airstrikes on Iran.

Christopher Cottrell 

Christopher Cottrell resides in Thailand and has been covering the Indo-Pacific region since 1997, contributing to publications such as The Boston GlobeChristian Science MonitorCNNThe GuardianMacau BusinessThe New York Times, and the South China Morning Post.

He spent 18 years in China and has been reporting on geopolitics in the Pacific Islands and Southeast Asia for the past four years, having edited UK-based Winna Media’s white papers on the Thai Entertainment Complex bill since 2024.

 

 

 

Richard Butler

Richard Butler is the vice president and APAC head of risk and research for Dow Jones & Co. Based in Sydney, Australia, he is responsible for helping businesses with risk and compliance strategies offsetting various forms of regulatory and commercial risk – such as the provision of high-quality, accurate and comprehensive data for identifying, evaluating and monitoring varying types of risk.

Before joining Dow Jones, Richard was the AVP for Treasury Services for Australia and New Zealand at JPMorgan Chase, where he was responsible for ensuring that JPMorgan’s financial institutional and non-bank financial institution clients in Australia and New Zealand adhered to JPMorgan’s best-in-class Know-Your-Customer, compliance, due diligence, and counter-terrorist financing standards. He began his career at ABN AMRO Bank, where he served as both the CAAML (Client Awareness and Anti-Money Laundering) officer and sales manager for the ABN AMRO Treasury Solutions Group in Dublin, Ireland.

Richard is skilled in governance, risk management, and compliance (GRC), as well as team management, direct sales, relationship building, and financial analysis, particularly in the APAC region.

Haider Mannan

Haider Mannan is the CEO and founder of BigTXN, a risk intelligence data provider. He is a data scientist and subject matter expert in investment screening, specializing in ESG controversies, global sanctions, and investment restrictions. He sits on the UK board of the Association of Certified Sanctions Specialists and the membership committee of the UK Sustainable Investment and Finance Association. Haider is also a member of PRMIA‘s advisory expert group on investment risk.

Discussion:

The conversation begins with Chris recounting the threats to Thailand’s security and stability, including the ongoing land border closure and standoff with Cambodia. He recounts with Regulatory Ramblings host Ajay Shamdasani that, notwithstanding its 22 prior coups, military rule, and reputation as a fragile democracy, Thailand has long been the darling of the global investment community, which has long touted its positive long-term economic fundamentals.

He adds the country has curried favor with the West by opening up in ways that many would regard as progressive, such as permitting the sale of cannabis products and paraphernalia, permitting same-sex unions, and seeking to liberalize its gaming sector by tendering a recent bill.

Yet, given the July 1 suspension by the country’s Constitutional Court of Prime Minister Paetongtarn Shinawatra over ethics violations and the weekslong border spat with Cambodia, which has been roiling fears of Thailand’s 23rd coup d’état, the implementation of the new gaming law has been scuttled.

The discussion then shifts to Haider, who shares his thoughts on how data can help investment screening. He and Richard comment on how recent changes in the sanctions landscape, given the current geopolitical climate under the second Trump administration, pose a challenge for compliance and legal staff at banking and financial institutions, as well as multinational corporations.

Related to this are concerns about the implications for Asia regarding the extraterritorial enforcement of the much-dreaded US Foreign Corrupt Practices Act (FCPA) and the prospect of tariff imposition by the White House, as well as the potential for regulatory retaliation by other countries.

It’s worth noting that on June 9, Matthew Galeotti, head of the US Department of Justice’s (DOJ) criminal division, said that under new FCPA guidelines now in place, it would enforce the Act Firmly but fairly.” The comments followed President Trump’s announcement earlier this year that the DOJ would hold off on FCPA enforcement following a review of current standards, as it was believed the existing regulatory regime put US businesses at a disadvantage when competing abroad.

Haider and Richard also discuss why geopolitics matter and the need for lawyers and risk managers to go beyond merely tracking financial news. The conversation concludes with a discussion of a recent case in which the US DOJ’s Office of Foreign Asset Control (OFAC) sanctioned entities/companies in Hong Kong and mainland China that were involved in transferring Iranian oil to China.

Regulatory Ramblings podcasts is brought to you by The University of Hong Kong – Reg/Tech Lab, HKU-SCF Fintech Academy, Asia Global Institute, and HKU-edX Professional Certificate in Fintech, with support from the HKU Faculty of Law.

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Regulatory Ramblings

Regulatory Ramblings: Episode 68 – Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen

This episode focuses on how compliance and legal staff must incorporate geostrategic risk considerations into their advice and recommendations.

In our initial Regulatory Ramblings Spotlight segment, we chat with Chad Olsen of KPMG China about what professionals in Hong Kong, Greater China, and the region need to know about such considerations.

Following that, we speak with Mark Nuttall, an executive advisor and strategic deal facilitator in Dubai, for a more Middle Eastern perspective.

Chad Olsen

Chad Olsen is based in Hong Kong, where he is the head of forensic services for KPMG China. In that capacity, he oversees matters involving white-collar investigations, anti-money laundering, sanctions and trade controls, fraud, and disputes and arbitration.

Before his current role, Chad was a partner at Deloitte and the head of financial crime. He was also the head of the financial crime intelligence unit at Standard Chartered Bank.

Professionally, he is a Chartered Accountant in Australia and New Zealand. Chad also holds two undergraduate degrees from Curtin University. Relevant to today’s discussion, his focus areas were accounting, finance, political science, and sociology.

 

Mark Nuttal

Mark Nuttal is an executive, geopolitical advisor, and strategic deal facilitator in Dubai. With over 25 years of experience in strategic leadership, risk management, and business development, he has held roles at the London Metropolitan Police Service, Thomson Reuters, INTERPOL, and Hill & Associates. He also founded the Faustus Consultancy.

He offers executive advisory services across Asia-Pacific, MENA, and Europe, aiming to drive growth, optimize operations, generate deals, and enhance governance.

When it comes to risk management and governance, Mark has implemented plans focused on risk mitigation and resilience while improving governance standards. He has also managed complex investigations and multi-agency operations.

Regarding subject matter expertise, he has delivered advisory services on governance, compliance, risk reduction, finance, leadership, geopolitics, AML, resilience, security, and ESG. Mark has also provided keynote speeches and mentorship to C-suite and geopolitical audiences.

Discussion:

The hasty U.S. withdrawal from Afghanistan in August 2021 under the Biden administration—and the fallout that followed—along with the Russian invasion of Ukraine in February 2022 and the ongoing war, have created inflationary pressures in international oil, gas, and food prices, roiled global markets, and deeply hurt the economies of Western Europe, deprived of cheap Russian fuel.

One thing is certain—it has spurred a deep interest in concepts such as geostrategy, also known as geopolitics. What in an earlier age might have been called political and economic risk analysis and regarded as the remit of social scientists—economists, political scientists, and international relations specialists—is now relevant to a wider range of professions.

Most professions and organizations are increasingly finding the need to adopt an interdisciplinary approach to problem-solving because, in the modern world, myopia and compartmentalization can be fatal. In-house general counsel and compliance staff at banking and financial institutions and multinational corporations need to be cognizant of geostrategic risk factors when advising those they report to.

With that backdrop, Chad speaks with Regulatory Ramblings host Ajay Shamdasani on why geostrategic and political risk analysis should matter to the modern compliance officer and lawyer—and, ultimately, their clients. It’s no longer just about giving advice based on rules and regulations; at most multinational corporations and financial institutions, a more interdisciplinary approach is required to keep pace with broader world developments.

The conversation covers what professionals can do to become more knowledgeable about geopolitical risk, what types of remedial education may be needed, and whether it might make sense to hire a political scientist, international relations specialist, or war/security/strategic studies specialist and place them in a compliance or legal department.

“Keep up with the news from multiple reputable sources” is Chad’s key advice.

Similarly, Mark stresses greater awareness of world events by compliance, legal, and risk professionals. Given his law enforcement background, he places a great deal of emphasis on total situational awareness.

Mark also shares his personal, professional, and educational journey—recounting a time when he was homeless and had absolutely nothing. That experience made him keenly aware of the risks people are willing to take to survive—a lesson today’s political and business leaders would do well to learn.

Coming from a humble background—and never forgetting where he came from—Mark explains how geostrategic and political risk analysis enters the equation when advising family offices in Asia and the Middle East.

Regulatory Ramblings podcasts is brought to you by The University of Hong Kong—Reg/Tech Lab, HKU-SCF Fintech Academy, Asia Global Institute, and HKU-edX Professional Certificate in Fintech, with support from the HKU Faculty of Law.

Useful links in this episode:

You might also be interested in:

Connect with RR Podcast at:

LinkedIn: https://hk.linkedin.com/company/hkufintech 
Facebook: https://www.facebook.com/hkufintech.fb/
Instagram: https://www.instagram.com/hkufintech/ 
Twitter: https://twitter.com/HKUFinTech 
Threads: https://www.threads.net/@hkufintech
Website: https://www.hkufintech.com/regulatoryramblings 

Connect with the Compliance Podcast Network at:

LinkedIn: https://www.linkedin.com/company/compliance-podcast-network/
Facebook: https://www.facebook.com/compliancepodcastnetwork/
YouTube: https://www.youtube.com/@CompliancePodcastNetwork
Twitter: https://twitter.com/tfoxlaw
Instagram: https://www.instagram.com/voiceofcompliance/
Website: https://compliancepodcastnetwork.net