From rule to workflow
A practical decision record for regulatory ambiguity
A framework for converting an unclear compliance question into a documented decision, an operational control, and a review loop
Selected writing
Briefs
Occasional pieces on how sanctions and financial-crime rules become operational decisions, several of them on Russia and Central Asia. Each makes a single argument and ends with what it changes operationally.
One person, several spellings
Transliteration variance as a screening control problem
Sanctions screening matches strings rather than people, and when those strings cross alphabets the quality of the match stops being a vendor default and becomes a design decision
From recurring question to durable control
Designing a compliance knowledge system
How repeated questions and exceptions reveal policy ambiguity, training gaps, process defects, and opportunities for better controls
A human in the loop needs a job description
Specifying review as a control, rather than naming one
Putting a person in front of an automated decision controls nothing until somebody defines what that person is looking for, what evidence they hold, and what their disagreement is worth