When Geopolitics Hits the Balance Sheet with Cari Stinebower

Welcome to RIMScast. Your host is Justin Smulison, Business Content Manager at RIMS, the Risk and Insurance Management Society.   In this episode, Justin interviews Cari Stinebower about sanctions as an enterprise risk management issue. They discuss the holistic view of the maritime space and enterprise risk. They cover aspects of the Terrorism Risk Insurance Act (TRIA) and how insurance companies, brokers, and reinsurers work with the U.S. Government to mitigate terrorism risk.   Listen for advice on keeping your organization compliant with respect to sanctions and terrorism risk.   Key Takeaways: [:01] About RIMS and RIMScast. [:16] About this episode of RIMScast. We will discuss geopolitical risk, sanctions, and TRIA with Cari Stinebower, a partner in the Washington, D.C. office of Steptoe. But first… [:42] RIMS-CRMP Virtual Workshops. RIMS will partner with PARIMA for the RIMS-CRMP on September 1st and 2nd for a two-day virtual workshop. Registration links are in this episode's show notes. [:55] Also on the webinars page, you will see a two-part series hosted by the RIMS Membership Department. The "Classroom to Career" webinar series highlights how RIMS equips students with the knowledge, skills, and connections needed to thrive in risk management careers. [1:10] Participants will gain insights into industry trends, career pathways, and practical tools that help them confidently step into the evolving world of risk management after graduation. These sessions will be hosted on September 1st and 9th. [1:24] These sessions are member exclusives and are complimentary for RIMS members, of course. So, if you are interested in becoming a member, this would be the time. Visit RIMS.org/membership. [1:34] Webinars: On September 17th, AXA XL returns to present the session, "Beyond the Loss Count: What Property Claims Reveal About Frequency, Severity, and Resilience." [1:46] On October 1st, Brown and Brown will make their RIMS Webinar debut with "The Future of Captives: What Risk Managers Should Think About Now." Visit RIMS.org/Webinars to register. [1:59] RIMS is back on YouTube. Our handle is @RIMSOfficialChannel. We've got plenty of videos there, including RIMScast, RIMScast Canada video podcasts, and other informative and entertaining content from RIMS. Subscribe to the channel today! [2:17] On with the Show! Our guest today is Cari Stinebower. She is a partner at Steptoe in Washington, D.C., and a former U.S. Department of the Treasury and Office of Foreign Assets Control (OFAC) Attorney-Adviser. [2:32] Cari focuses her practice on regulatory risk where U.S. National Security and Foreign Policy objectives intersect with cross-border business. [2:39] We will talk about fraud, money laundering detection, and cybersecurity, and how this can be connected to the Terrorism Risk Insurance Act (TRIA). [2:50] We'll also talk about how international sanctions can impact any organization, and why risk managers should be strategizing now, if they haven't already. There is so much to discuss!  Let's get to it! [3:04] Interview! Cari Stinebower, welcome to RIMScast! [3:24] Cari says she was at OFAC at an interesting time. She came in after a Hill job doing the campaign finance cleanup for the Democrats for three years, from 1996 to 1999. [3:38] Cari says that OFAC sank their teeth into anti-money laundering and the detection of fraud and corruption. When Cari joined Treasury as an analyst within OFAC, they slotted her into a position focused on counter-narcotics work, and also on the Milošević tribunal. [4:03] Cari says there was lots of work to do and not enough staff to do it. Everyone ot OFAC had then, and still has, multiple portfolios. Cari was splitting between Milošević and counter-narcotics work. [4:20] Cari says she spent a lot of time in Colombia working with banks and the Colombian government on anti-money laundering, focused on the cartels. The drug dealers were very sophisticated and were spectacular at establishing front companies and money laundering. [4:54] Cari says it was a very good lesson for what was to come through the counter-terrorism work. The Colombian narcotics traffickers and their front companies were light-years ahead on money laundering techniques and sanctions evasion. [5:44] Cari says in Colombia, at that time, the narcotics traffickers were excellent businessmen. It was such a lucrative career that they had to find ways to wash the cash. They were buying agricultural businesses, tourism businesses, pharmacies; anything they could to launder cash. [6:18] Cari says they could have been fabulous businessmen if they had gone legitimate. She says some of them tried. [6:32] Cari says 9/11 happened, so the world changed overnight. Cari switched from a counter-narcotics focus to a counter-terrorism focus. [6:44] They started chasing the money. Who was the source of the funds? Where was it going? Which financial institutions were involved? Were they doing it knowingly? Were they being used by governments? Were they being used by "charities"? How is it flowing? [7:03] Cari says that became her focus at OFAC for the next five years after 0/11, before she hopped into the private sector. [7:39] Justin asks about sanctions against nations. Cari says the old way Treasury used to do sanctions was by jurisdiction. A jurisdiction would be identified as prohibited, off-limits for U.S persons, meaning individuals and entities. [8:01] Any funds, transactions, or contracts that came into the possession or control of the U.S. person or entity would, by operation of law, be blocked or frozen; the title remained with the sanctioned party, but the U.S. person or entity had to freeze it and report it to the Treasury. [6:26] The original sanctions on Iran were jurisdictional, based on the government, based on persons located within the jurisdiction of Iran. The Department of the Treasury was aggressive in pursuing enforcement actions. [8:44] Financial institutions were sanctioned with multi-million-dollar penalties. The world started to voluntarily comply. It was U.S. driven initially, but European financial institutions and some of the Emirati financial institutions got on board and complied with the sanctions. [9:20] The Departments of the Treasury and Justice used a clause within the underlying statute for the Iran sanctions that allowed penalties to be imposed on non-U.S. financial institutions that were causing a U.S. bank to process transactions on behalf of the sanctioned party. [9:43] That was the line of the European banking cases that came out. Cari says banks were penalized from 2005 through 2015, which pretty much swept in everyone. [9:56] That was the modern buildout of the compliance program where the U.S. established it was applying its sanctions requirements not only to U.S. persons but to non-US. persons where they could also identify a nexus. [10:12] The favorite nexus was the use of U.S. dollars through the clearing system. Sanctions exploded. It was identifying ways to reach non-U.S. parties through the use of dollars, servers located in the U.S., call centers, approvals, or whatever they could, as a hook to get U.S. nexus. [10:51] Justin asks about sanctions against Russia, Iran, and North Korea. Cari says North Korea has sort of fallen off. There's a big focus on North Korea's use of forced labor. They've also been active in cyberspace and ransomware. [11:20] Cari says we don't see North Korea as often as we see Iran, Russia, and, to a certain degree, Cuba. It depends on the administration. For a while, Venezuela was really hot, from an anti-corruption, anti-money-laundering perspective, rather than a sanctioned invasion. [11:46] Justin speaks of the latest AML bill, passed in 2023. Cari says the big overhaul was under the Patriot Act, which updated and modernized the Bank Secrecy Act. It also updated and modernized the International Emergency Economic Powers Act (IEEPA), OPEC's big statute. [12:09] Cari says there have been updates since. When you hear M&A partners or private equity guys talking, they often refer back to the Patriot Act. The Patriot Act becomes this overarching term for updates to the AML laws and regulations. [12:48] Cari says there has been a growing evolution of the anti-corruption, anti-bribery statutes, the anti-money-laundering statutes, the sanctions world, and the adjacents like the whistleblower protections and the Terrorism Risk Insurance Act. [13:09] Cari says all of these components are part of this growing collective focus on upgrading U.S. Government abilities to protect against threats to national security and the economy. [13:32] Justin says risk managers are accustomed to thinking about operational and financial risks, but sanctions can feel like a legal issue. Part of the problem is you may have a legal officer who is not a risk manager or a risk manager who is not a legal officer. [13:48] Justin asks, When should sanctions become an Enterprise Risk Management issue? Cari says, looking at OFAC's enforcement actions, sanctions should always be an Enterprise Risk Management focus. [14:04] It's very easy for the bad guys to take advantage of a business if it's siloed. The easiest way to detect a problem, whether it's financial sanctions evasion or exposure to corruption, is if the enterprise is looking holistically at its business, its counterparties, and its transactions. [14:26] Cari says, when we're working with clients on building a global compliance policy or procedure, we keep telling them that it's better to have a holistic view of the business, customers, and geography. [14:43] Not only geographic risk, customer risk, or service risk, but also across the regulatory schemes. If you have sanctions exposure somewhere in your enterprise, you're also likely going to have an anti-money-laundering issue, a corruption issue, and/or an export controls issue.  [15:06] Cari says when you're building out compliance, you want to have a 1,000-foot view of the business units, your customers, your geographies, and the regulatory components, so that you can take advantage of what you may be seeing in one area. It's silos that cause the problems. [15:26] A Quick Break! Many fantastic RIMS events are coming up in 2026. The 11th Annual Chicagoland Risk Forum will return to the Old Post Office on Thursday, September 24th, 2026. Visit ChicagolandRiskForum.org for more information. [15:42] The RIMS Western Regional Conference will be held from October 4th through the 7th in Seattle, Washington. The agenda is live, and registration is open. Visit RIMSWesternRegional.com and the link in this episode's show notes for more information. [15:59] Save the dates: October 18th through the 21st. In Quebec City, we will be hosting the 50th Annual RIMS Canada Conference. Booth sales are open, and sponsorship opportunities are still available. Visit RIMSCanadaConference.ca for more information. [16:16] Also, remember to check out RIMS.org/Canada for our spinoff show, RIMScast Canada, hosted by National Conference Committee Chair, Aaron Lukoni. [16:27] The RIMS ERM Conference 2026 will be held on November 19th and 20th in Columbus, Ohio. Registration is open. Visit RIMS.org/ERM2026. [16:40] We're already looking to RISKWORLD 2027, which will be held over four days in New Orleans, Louisiana, from April 18th through the 21st! [16:50] RIMS members can exclusively register by September 4th for the best rate. And get first access to the hotel block. Hotel reservations open on October 28th, ahead of public registration. Sitting this out is the real risk! The link to registration is in this episode's show notes. [17:10] Let's Return to Our Interview with Cari Stinebower! [17:26] Cari says an example of sanctions risk is Iranian oil or Venezuelan oil. Typically, the pattern is you have a Greek shipment manager under charter to deliver oil and gas to China.  The Bill of Lading says the cargo is of Omani origin or Malaysian blend. [18:08] It looks clean. They have all the sanctions exclusions language in the Charter Agreement; the insurers, the reinsurers, and the P&I quotes have all established that the vessel cannot carry Iranian cargo. The documents say it's Omani or Malaysian, and off you go. [18:28] Then you get a call from the U.S. State Department or the Treasury Department saying you've got Iranian cargo on board. The U.S. Government typically knows that because they're using satellite tracking software. They know that the cargo was loaded by ship-to-ship transfer. [18:58] If you go back through the satellite imagery, you can see that it's happened probably two or three times, and when the vessel called on the Omani port that was supposed to be the source of the cargo, it came in at the same draft as it left. Calling on the port was clearly a ruse. [19:34] When you get to the financial payments, that's where you have the money laundering side, and you can see that the Omani seller of the cargo is just a front company with a brand new website, secretly run by the Revolutionary Guard. [19:56] Cari says that when we start talking about the compliance policies and procedures, it's not good enough just to rely on the Bill of Lading. The expectation is that you're going to be doing something a little deeper. [20:11] In 2019, the Department of Justice started to pursue a lot of ship owners and ship managers for carrying Iranian cargo. Sometimes it was Iranian cargo going to Venezuela or going to China. [20:32] In a decent batch of those cases, the ship owners or ship managers would be contacted by the U.S. Government and agree that the Government was right and ask what they could do not to get sanctioned. [20:51] Cari says there were a series of cases where the ships were brought to the U.S. and the cargo was sold by the U.S. Government, with the proceeds going to the Victims of Terrorism Fund, for parties who registered with the Special Master and were entitled to a pro rata share. [21:20] That was the U.S. Government's solution to what to do with all this cargo that they can seize, and they had been seizing, under the Foreign Terrorist Organization Statute. We're now seeing the same focus on the narcotics trafficking cartels in Mexico, Brazil, and Venezuela. [21:46] Cari says, You see the evolution of the U.S. Government's thinking over the years, how the Iranian oil cases are now relevant to countering narcotics trafficking caused by the cartels in South America. [22:00] Justin asks about supply chain risk and sanctions-related risks companies may overlook when they evaluate suppliers. Cari says the supply chain, particularly when you're dealing with raw materials or manufacturers coming out of China, has been an issue for a long time. [22:29] Cari says it's not difficult for a U.S. importer who's bringing in parts and components for widgets to know that their manufacturer or warehouse in China is who they say they are. That's easy enough. [22:48] Where we see issues is when the Chinese manufacturer subcontracts to second or third parties, who ostensibly are also compliant, but it becomes difficult in a more opaque jurisdiction like China to do the tracing down to the actual mine or source of the raw materials. [23:14] That leads up to the Uyghur Forced Labor Prevention Act (UFLPA), which has forced companies to look at supply chains where there's a Chinese component, for several years. [23:31] Where are the raw materials coming from? Do you know where all of the raw materials are coming from, or do you just know where some are? Under the UFLPA, companies were particularly focused on identifying those risks in China. [23:50] Cari says, under the first Trump Administration, and under the Biden Administration, you started to see a lot of companies moving away from sole-sourcing goods from China, specifically because of that risk. [24:02] The National Drug Control Strategy Report that came out in May 2026 is digging deep into supply chain issues. [24:13] It says two things: first, that the U.S. Government needs to act as a whole. The Departments of Justice, Treasury, and Homeland Security need to work together on tackling supply chain issues and addressing where the gaps are. [24:35] Supply chains are being exploited, not only by narcotics traffickers, but across the board. [24:41] The report is also telling businesses that it's not enough to have an OFAC sanctions compliance program where you screen your counterparties against the SDN list. [24:54] There's an expectation for businesses to go deeper, using analytics and AI, looking at their records, and knowing who the suppliers of their suppliers are. [25:17] The expectation is for businesses to step up their game, but also for the U.S. Government to partner with businesses to figure out how to do that. [25:35] Cari says we've also been telling other jurisdictions, like those in the Caribbean and South America, that this is a really good opportunity. [26:44] The first Trump Administration, the Biden Administration, and the second Trump Administration have said to stop sole-sourcing in China. Let's near-shore and friend-shore, and let's bring business and infrastructure back to the Western Hemisphere. [26:00] Cari says we're starting to see jurisdictions offer tax incentives for setting up manufacturing spaces, or finding ways to invest in the United States to bring back manufacturing. [26:14] Cari says the big issue of late has been how to bring shipbuilding back to the United States. Is there a way to do it in Latin America without relying on China as the major shipyard? [26:29] Those issues are interesting because they trigger a series of other questions: cost of labor, sourcing raw materials, and more. It's a longer-term problem. If you're building out your supply chain nose-to-tail, it's going to require a more transparent jurisdiction than China. [26:52] One more Quick Break! RIMS, The Foundation for Risk ManagementTM, is dedicated to shaping the future of the profession. By making a contribution, you are strengthening the global risk management community and investing in the future of the industry. [27:11] The Foundation also supports the Spencer Educational Foundation but has a different mission. The Foundation focuses on providing opportunities for those professionals who have already decided to enter risk management and are just getting started. [27:26] You can learn more about the Foundation by visiting www.RIMS.org/FRM.  While you're there, be sure to check out information about the Susan Meltzer Scholarship Fund, which was established to honor Ms. Meltzer, who was RIMS President in 1999 and 2000. [27:44] Susan Meltzer was a cherished RIMS President and contributed so much to RIMS and the greater risk community. Learn more at RIMS.org/FRM. [27:53] Let's return to our interview with Cari Stinebower! [28:14] Justin asks if other countries sanction the United States or U.S. companies. Cari says it has become a new trend. The jurisdictions doing it are China, with the National Security Law; Russia, identifying Hostile Jurisdictions that have imposed sanctions against Russia. [29:12] Cari says it's a quid pro quo. Ukraine has a sanctions program against entities that do business with Russia. Canada and Europe are well-known for their Blocking Statutes. [29:48] They have Antidote Sanctions that prohibit their nationals from complying with the U.S.'s Cuba Sanctions. Those jurisdictions see the U.S. sanctions on Cuba as territorial. There is a quid pro quo. [30:08] Sometimes it triggers conflict-of-law issues, and companies have to decide how and when they're going to comply with which set of sanctions. [30:46] Cari says, if you don't have a holistic view of which jurisdictions you're operating in, and where your U.S. nationals are located, there's no way to build out a robust, comprehensive sanctions program. [31:01] If you have a U.S. person located in or in a business position in Canada, you wouldn't want them dealing with the Canadian company's Cuba business. You need to know where they are located in advance so you can protect the U.S. person. [31:27] Justin notes that RIMS is a global society. Canada is the second-largest RIMS membership base. [31:40] Justin says there's so much due diligence to be done. You have to vet the company you're going to be doing business with and do your second- and third-tier supply chain risk management deep dive to make sure that everything is above board. [32:02] Cari says there are many examples where the Canadian Government has aggressively stepped up its sanctions components. The Canadian sanctions on Russian targets may be more aggressive than the U.S. or EU sanctions on Russia. [32:19] If you have a financial institution or insurance company based in Canada, but operating in the U.S. and the EU, because they're complying with the Canadian sanctions, they're blocking transactions that a U.S. party wouldn't have to block. [32:44] You want to know what the entire web of sanctions regulations is before you figure out who your business parties are and how you're going to navigate something. [32:55] Justin surmises that a small company without a dedicated risk professional would need to reach out to a company like Steptoe. Cari agrees; a lot of people will use a law firm and a consultant to build out their compliance programs or to do the risk analysis. [33:13] Cari says, then they will either find someone in-house or outsource it to a consultant or a specialist to keep costs down. [33:23]  Cari says, we also see this pop up in Mergers & Acquisitions. One of the things that is often difficult is that they will see the compliance function either as redundant or as a cost center, and not as a profit center. [33:47] The guidance is always: Don't save costs by getting rid of your Compliance function, because it will cost you money in the long run. But often, that is what you will see. [34:00] Justin brings up the Terrorism Risk Insurance Act (TRIA), a legislative priority for RIMS. RIMS sends an External Affairs Team to Capitol Hill every year to talk about TRIA with their Representatives in Congress. [34:19] Justin says RIMS helped lead the charge, over 20 years ago, to get TRIA passed into law. [34:30] The nature of terrorism risk has evolved since TRIA's enactment. Justin asks how risk managers should be thinking about terrorism exposure today, compared to when the program was established. [34:44] Cari says terrorism, like the narcotics traffickers, evolves. It's cash-intensive. There's more you can do now through technology, AI, cybersecurity, and cryptocurrency. [35:01] You can sit completely offshore and wreak havoc on the electrical grid or a utilities provider, or a financial institution, through cyberattacks or cybercrimes. It can be crippling if terrorists go after the grid. [35:28] Cari says we have seen an overlap between what could be a terrorist attack and what is more likely a ransomware grab, when they're going after smaller utilities located somewhere in the Midwest. That seems to be a trend. [35:45] They're not always sophisticated. You don't always know who the counterparties are. Going back to the Drug Control Strategy report, the Government is saying that there has to be a holistic approach to ransomware and cyberattacks. [36:03] A couple of years ago, the FBI and Homeland Security set up a task force to work with the utilities or other U.S. businesses that see themselves faced with a ransomware attack that is either just for the money or is something more nefarious. [36:24] Cari says, if the question is, is it terrorism or is it something else, but the way you would attack it would be the same if you're the utilities manager; it doesn't matter if it's terrorism or cybercrime. [36:48] You've got to work with law enforcement to protect your infrastructure, to figure out whether you're going to pay the ransom or not, so that you can protect your customers' data. [37:02] It's up to the Government to figure out who the illicit party was. Is it a hacker group sitting in Russia? Is it a terrorist group? Why were they doing it, and how do you stop it from happening in the future? [37:18] If you're the Business Manager or the Compliance Officer, you need to build in your risks, your risk mitigation strategies, redundancies, and backup servers that are not connected. The problem for you isn't: Is this a hacker or a terrorist doing this to me? [37:53] Cari says there are many insurance working groups. We've worked with clients, some of these groups, and the U.S. Government to come up with language that makes sense. We see it in the context of Iran or Russia, or with respect to language for War Risk in the Strait of Hormuz. [38:32] Cari says, The partnership between the insurers, reinsurers, brokers, and Government is pretty deep. [38:41] These working groups have been around for a long time because insurers, brokers, and reinsurers need buy-in from the Government to get assurances that the language they're putting out there is enough to get them out of trouble if they're acting in good faith. [39:00] Generally, everyone is, but you want that nod from the Government that what you've done is sufficient from the Government's perspective. [39:37] Cari's advice to risk professionals in August 2026: The most important thing is that the risk professionals and the business units know and trust each other. [39:47] Cari continues: A risk professional isn't going to be able to build out a compliance program that works unless they know what the business units are up to and what the business priorities are, and they have the trust of the business professionals. [40:05] Some critics warn that you don't want the compliance person to become a captive of the business units, driven by profit rather than compliance. Cari says the business compliance person needs the business unit and the compliance unit to work hand in glove. She explains it. [40:46] Cari says we've seen this a lot with all of these businesses jumping into the Venezuela market. There's a lot of business upside but also a lot of risk. It may not be that there's a sanctions risk, but the longer-term risks are the money-laundering and corruption risks. [41:26] Cari asks what happens ten years from now? If you're a compliance officer, you need to understand the upside to the business, which is lots of profit, but when you're drafting contracts and working with the business unit, how are you mitigating the risk that's five or 10 years out? [41:44] Cari says the only way you do that is if the compliance and business units have a certain amount of trust and respect for each other. [41:57] Cari says the Compliance Officer is not always the Risk Manager. Some businesses will have it siloed; some will have someone embedded. In some cases, there's no compliance person. They throw it onto a legal officer, and the legal officer can be spread fairly thin. [42:13] Cari says you can work through trade associations to understand industry risk. You can hire consultants. You can hire law firms. The benchmarking is incredibly important to understand not only the opportunity but also the appropriate risk. [42:49] Justin says this has been one of the most informative RIMScasts we've had in a while. I'm so glad we got a chance to tackle this topic. Cari, thank you so much for joining us here on RIMScast! [42:45] Special thanks again to Cari Stinebower of Steptoe for joining us here on RIMScast! A link to her LinkedIn profile is in this episode's show notes. [42:58] I have links on this episode's show notes to other RIMS coverage on sanctions, geopolitical tensions, and related supply chain risk. Also visit RMMagazine.com. [43:08] Plug Time! Become a RIMS member and get access to the tools, thought leadership, and network you need to succeed. Visit RIMS.org/membership or email [email protected] for more information. [43:26] Risk Knowledge is the RIMS searchable content library that provides relevant information for today's risk professionals. Materials include RIMS executive reports, survey findings, contributed articles, industry research, benchmarking data, and more. [43:42] For the best reporting on the profession of risk management, read Risk Management Magazine at RMMagazine.com. It is written and published by the best minds in risk management. [43:56] Justin Smulison is the Business Content Manager at RIMS. Please remember to subscribe to RIMScast on your favorite podcasting app. You can email us at [email protected]. [44:08] Practice good risk management, stay safe, and thank you again for your continued support!   Links: Spencer Educational Foundation's 2026 Funding Their Future Gala | Sept. 17, 2026 ChicagoLand Risk Forum | Sept. 24, 2026 RIMS Certification Week: Sept. 21‒24 | Complimentary For All RIMS Western Regional Conference — Oct. 4‒7, 2026 | Seattle, WA | Register Today. 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RIMS Virtual Workshops On-Demand Webinars RIMS-Certified Risk Management Professional (RIMS-CRMP) RISK PAC | RIMS Advocacy RIMS Strategic & Enterprise Risk Center RIMS-CRMP Stories — Featuring RIMS President Manny Padilla!   RIMS Events, Education, and Services: RIMS Risk Maturity Model®   Sponsor RIMScast: Contact [email protected] or [email protected] for more information.   Want to Learn More? Keep up with the podcast on RIMS.org, and listen on Spotify and Apple Podcasts.   Have a question or suggestion? Email: [email protected].   Join the Conversation! Follow @RIMSorg on Facebook, Twitter, and LinkedIn.   About our guest: Cari Stinebower, Partner, Steptoe   Production and engineering provided by Podfly.