Brian O'Toole

  • Trump Administration’s ‘Solid’ Guidance on Russia Sanctions

    A potentially significant Russia sanctions action flew under the radar and escaped broad notice in the wake of the fallout from special prosecutor Robert Mueller’s investigation last week.  

    The US Treasury’s Office of Foreign Assets Control (OFAC) and the US State Department released guidance on implementation of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA).  These went beyond the Obama administration’s actions to implement congressional sanctions on Russia in 2014, by creating significant risk for anyone seeking to do business with designated Russians or in Russian frontier energy projects (shale, Arctic offshore or deep-sea oil). 

    Our initial take is that the administration’s guidance is solid and strong.  Despite being forward-leaning, the guidance provided by OFAC and the State Department was carefully crafted to preserve sanctions unity with the European Union (EU), arguably the most critical factor in...

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  • Trump Administration's Significant Action on Russia Sanctions

    The Trump administration on October 26 issued a robust list of Russian defense and intelligence sector entities plus public guidance, which together seem to indicate its intention to robustly implement the new Russia sanctions. Although the list does not itself impose sanctions, it is a significant action, which, if implemented carefully, could impose new restrictions on Russian military and intelligence apparatus. 

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  • Trump and the Art of the [Iran Nuclear] Deal

    As expected, US President Donald J. Trump on October 13 announced that he will not certify Iran’s compliance with the terms of a multilateral nuclear deal, accusing the Islamic Republic of “not living up to the spirit” of the agreement.

    While Trump did not take the United States out of the deal, he asserted the right to do so and warned that he would if the US Congress does not make amendments to the agreement.

    At the top of the list of amendments Trump would like is for Congress to address the issue of the “sunset clauses” in the deal. These clauses lift certain restrictions placed on Iran ten to fifteen years after the agreement took effect in January of 2016. However, even at that...

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  • What are the Implications of Decertification of the Iran Nuclear Deal?

    The expectation that US President Donald J. Trump will decertify the nuclear deal with Iran this week raises the question: what would be the implications of decertification?

    Trump faces an October 15 deadline to certify to the US Congress that Iran is complying with the terms of the nuclear agreement that the Islamic Republic struck with the five permanent members of the United Nations (UN) Security Council plus Germany in 2015. The deal cuts off Iran’s path to a nuclear weapon.

    Despite criticizing the agreement as “terrible,” Trump has twice...

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  • O'Toole Quoted in The Hill on Russia Sanctions


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  • O’Toole Quoted in The Hill on Russia Sanctions


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  • Brian O'Toole Joins Atlantic Council as Nonresident Senior Fellow with the Global Business & Economics Program

    WASHINGTON, DC - The Atlantic Council today announced that senior vice president and anti-money laundering (AML) executive for sanctions at BB&T Bank, Brian O'Toole, has been appointed as a nonresident senior fellow with the Global Business & Economics Program. Brian is an accomplished expert on economic sanctions, with substantial experience in both the public and private sectors.

    “Brian joins us at an exciting time as we take our Economic Sanctions Initiative to the next level,” said Andrea Montanino, Director of the Global Business and Economics Program. “He brings with him a wealth of experience from both the public and private sectors and we look forward to working with Brian to forge a path toward more effective economic sanctions.”

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