This Week in AML

When Sanctions and Election Influencing Meet

This week, Executive Vice President John Byrne, and Creative Director Elliot Berman of the AML RightSource staff talk about the announcement from the Department of Justice of the seizure of 27 domain names being used by the Iranian Revolutionary Guard Corps – a designated terrorist organization. The websites were being used to manipulate public opinion in many countries including the United States.


When Sanctions and Election Influencing Meet Transcript

Elliot Berman: Hi, John, how are you this week?

John Byrne: Oh yeah, Elliot, on the edge of my seat, like everybody else, but doing okay.

Elliot Berman: Good! This being election week with all the other things we're concerned about and paying attention to, I noticed that, yesterday, DOJ announced they had seized 27 domain names that were being used by Iran's Islamic revolutionary guard Corps. It was interesting because this had some election influence and some sanctions issues in it. I don't know if you saw that one?

John Byrne: Yeah. I think, I know our audience does this, but if you don't already monitor the FBI's website, DOJ's, as you do the banking agencies and FinCEN's to see news releases and speeches, it's pretty valuable. And like you say, it's a connection to a space that we're very familiar with in the AML community and sanctions. So I did see that and I think it's just another example that, sanctions violations go far beyond, the traditional issues and this is something that was reflective of a violation of the foreign agents registration act. So I thought that was pretty interesting. And like you say, given its election, we relevant to what we're paying attention to.

Elliot Berman: Yeah - apparently the, the revolutionary guard has had a cyber effort to influence, U S public policy and potentially elections, and they do it through among other things, websites that they set up, which have a, kind of a color of being, news information websites. But when you dig a little deeper, they're quite a bit more than that. And, this was, as I mentioned, 27 domains apparently - the release also mentions that 92 others were recently seized. The sanctions component, while it does relate to FARA, there are several Iran-related, executive orders and other things targeting the revolutionary guard as a terrorist organization. So that's how it all gets tied together.

What did you see when you think about how the investigation was actually described?

John Byrne: Yeah, like I said, it was on the FBI website and so they were pretty instrumental in investigating this as they've been doing as director Ray has been talking about election security and foreign influence for quite a while - they mentioned in the release that in addition to the FBI being involved and leading the investigation, that they were able to do this with what they could call it, ongoing collaboration with Google, Facebook, and Twitter. And I think that is important to these social media platforms obviously have been misused in some instances in the past. And like you said, some of these domain names made it look like they were, news outlets and, unfortunately people get kind of pulled into this and will believe things without sometimes doing their own research. So I think by having law enforcement work on cases like this and using, using OFAC, using the FARA issue, in addition to sanctions violations, it just shows us a lot of excellent tools that the government can use here.

And they've been very active in doing this, throughout this election season. So I think that should give us some comfort as citizens here.

Elliot Berman: I agree. one of the things in the announcement that caught my eyes, if you were to go to any one of the seized websites now, you would actually see an image, that says right at the top, white letters across, a blazing red background, "this website has been seized". And then it goes on to talk about being seen under what authority with the seals of the department of justice and the FBI. So, it's not as if they disappeared. There really is some messaging effort there as well - if you've been using the site, you should know that it was not a good site.

John Byrne: Yeah, exactly. And the fact that they are so transparent in how all this transpired, I think is pretty important. And they end the release by talking about the seizure and that the prosecution section and asset forfeiture section of the us attorney's office, this is the one in the Northern district, California, and part of DOJ they're prosecuting the seizure as well.

So again, a nice collaboration with private sector, public sector, and as I mentioned, so many various tools that help in these sorts of situations.

Elliot Berman: Yeah - have a good week, stay safe. try not to look at everything on every website about the election only because it will drive you crazy.

John Byrne: That's true. Say safe to talk to you next week.

Elliot Berman: Yep - bye bye.