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New Atlanticist

Jan 24, 2018

Deterring Russian Hacking

By Brian O'Toole and Daniel Fried

The apparent lack of US preparation and defense nearly eighteen months after Russia’s interference in the presidential elections, especially given numerous media reports that Russia aims to interfere in the 2018 US midterm elections, is deeply troubling. We are heartened that Congress has taken up leadership to defend the US electoral process. But notwithstanding its […]

Russia

New Atlanticist

Nov 6, 2017

Trump Administration’s ‘Solid’ Guidance on Russia Sanctions

By Brian O'Toole and Daniel Fried

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 […]

New Atlanticist

Oct 27, 2017

Trump Administration’s Significant Action on Russia Sanctions

By Daniel Fried and Brian O'Toole

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 […]

Russia

Brian O’Toole is a nonresident senior fellow with the Atlantic Council’s GeoEconomics Center and global head of sanctions at Wells Fargo, where he oversees sanctions compliance and list-based screening efforts across the enterprise. He is an expert on economic sanctions and foreign policy with experience across public and private sectors.

Previously, O’Toole was senior vice president and director of sanctions and screening at Truist Financial Corporation, the sixth-largest bank in the United States formed from the merger of BB&T and SunTrust. In that capacity, he oversaw the corporation’s sanctions compliance efforts and politically exposed persons screening across the bank and its subsidiary businesses.

O’Toole worked at the US Department of the Treasury from 2009 to 2017. As senior adviser to the director of the Office of Foreign Assets Control (OFAC), he helped manage the implementation of all OFAC-administered economic and financial sanctions programs, and provided strategic direction of the internal management of the agency. He played a central role in designing the US sanctions regime in response to Russia’s aggression in Ukraine and negotiating the multilateral sanctions imposed by the European Union and Group of Seven in coordination with the United States. O’Toole also helped to manage implementation of US government commitments under the Joint Comprehensive Plan of Action with Iran.

Prior to joining OFAC, O’Tool served as an illicit finance analyst for both the Treasury Department’s Office of Intelligence and Analysis and at the Central Intelligence Agency, and was an anticorruption specialist in the forensic services practice at PwC.

O’Toole holds a BA from Princeton University in economics, with a certificate in finance, and an MA from Johns Hopkins University Paul H. Nitze School of Advanced International Studies in international economics and strategic studies. O’Toole lives and works in Raleigh, North Carolina.