Brian O'Toole

  • The DETER Act Will Not Deter Russia. It Will Instead Hurt US, EU Economies

    With hints that the DETER Act [the Defending Elections from Threats by Establishing Redlines Act of 2018] may be under some consideration in the National Defense Authorization Act process going on in Congress, we would like to highlight our analysis from earlier this year for consideration by any involved in the negotiations and potentially affected parties.

    While we frequently advocate for tough action to deter Moscow from its many aggressions, our analysis in this piece still stands: the DETER Act is the wrong way to address concerns about Russian President Vladimir Putin’s aggression.

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  • Here’s Why OFAC’s New Russia Sanctions are Significant

    Set against the odd frame of US President Donald J. Trump wanting to invite Russia to govern the world as part of a reconstituted G8, the actions taken by the Office of Foreign Assets Control (OFAC) on June 11 to sanction Russian cyber actors were a welcome reminder that actions can speak louder than words and that credible, sustainable actions like these are (hopefully) what advance actual policy goals. Taken by itself, this set of sanctions is the important, if routine, work that dismantles networks of bad actors doing bad things. It was not escalatory, but it serves as a reminder of the threats posed by Russia and raises some interesting questions. 

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  • O'Toole Quoted in Bloomberg on Trump's Overtures to Putin


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  • Can the European Union’s Sanctions Blocking Regulation Save the Iran Nuclear Deal?

    The European Union (EU) on May 18 announced that it was beginning the process to activate its proposed blocking regulation, initially proposed in 1996 to try to counteract what the EU saw as the extraterritorial reach under the United States’ Iran-Libya Sanctions Act (ILSA) and Cuba sanctions program. Those disagreements were settled politically with the Clinton administration, but there has been renewed interest in the draft regulation in the wake of US President Donald J. Trump’s decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and reimpose US secondary sanctions on Iran.  

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  • O'Toole Joins i24 News to Discuss the EU's Move to Protect Iran Business Deals


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  • Can the European Union’s Sanctions Blocking Regulation Save the Iran Nuclear Deal?

    The European Union (EU) on May 18 announced that it was beginning the process to activate its proposed blocking regulation, initially proposed in 1996 to try to counteract what the EU saw as the extraterritorial reach under the United States’ Iran-Libya Sanctions Act (ILSA) and Cuba sanctions program. Those disagreements were settled politically with the Clinton administration, but there has been renewed interest in the draft regulation in the wake of US President Donald J. Trump’s decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and reimpose US secondary sanctions on Iran. 

    It is not clear that proponents of reviving the regulation fully appreciate just how different the global financial and compliance environments are now compared to the mid-1990s.

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  • Dropping the Hammer

    The Trump administration, acting through Treasury Department’s Office of Foreign Assets Control (OFAC), has wasted no time in setting a harried pace of Iran-related designations to up the pressure after the president announced the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) on May 8. In the seven business days following that fateful announcement, OFAC has issued four sets of Iran-related designations targeting Iran’s support for terrorism in what seems to be an attempt to replicate the maximum pressure campaign against North Korea that helped spur a leadership summit to negotiate denuclearization (albeit one that seems less certain than a week ago). These actions have come alongside a concerted effort by the administration to pressure foreign companies, especially in Europe, to cease business with Iran prior to the expiration of secondary sanctions waivers in August and November. 

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  • US Sanctions’ Global Impact - A Case Study of RUSAL’s Supply Chain

    On April 6, 2018, the Trump Administration imposed stiff economic sanctions on37 Russian oligarchs, oligarch-owned companies, Russian government officials, and state-owned companies.

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  • The Iran Deal: Withdrawal Symptoms

    US President Donald J. Trump’s May 8 announcement that he would withdraw from the Iran nuclear deal was broadly consistent with what many observers expected from the administration. However, because the sanctions component proved tougher than most predicted, the full scope of economic and political ramifications remains unknown.

    While the United States gears up for the reimposition of broad secondary and narrower primary US sanctions on Iran for its nuclear activity, there will be a wind-down period for ceasing business, allowing for at least some transition time.  

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  • O'Toole Quoted in i24 News on Trump's Nuclear Deal Pullout


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