Welcome back to the podcast. Today we're going to get a primer on international sanctions from a widely recognized expert in this field.

Our guest is the former U.S. Commerce Department Assistant Secretary for Export Control,

and she now leads the International Trade Department at

Hughes, Hubbard, and Reed. Amanda DeBusk, thank you for joining me.

Thank you. I'm glad to be here.

The goal of this podcast is to cover the whole range of financial crimes and sanctions violations

are certainly one of the more esoteric of these, and we're looking to you to make sense of this for us.

Perhaps we could start with the punchline, if you like.

How serious is this offense?

How much trouble can somebody get into?

It's a very serious offense, and someone can get into a heap of trouble, including jail time.

Just to put the legal parameters around it.

For criminal violations, the fines are up to a million dollars per violation, and also 20 years

in prison. Criminal means that you have to have some sort of willful intent to violate the law.

And what's more common, of course, is civil violations where people violated the law, but they didn't do it with the criminal intent.

And in that case, the fines are around $284,000 per violation or twice the value of the transaction.

So it's a lot of money. And one of the other clubs that the U.S. government has in this area is the

bad guys list. One of the things that folks most fear is being put on the bad guys list. To back up for a

second on civil penalties, that sounds a little bit like a strict liability. If you did it but didn't

mean to do it and you can still get into trouble, how does that dynamic work? Well, your example is a

really good one. It is strict liability. And so if you send something

that went to someone on the bad guys list, you have committed a violation, even if you never

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