While major enforcement actions against foreign banks for U.S. sanctions violations appear to have subsided over the past few years, recent settlements of sanctions-related claims against three large foreign banks remind us that federal and state authorities continue to aggressively monitor compliance with, and enforce U.S. sanctions laws.
Manatt partners Andrew Zimmitti and Richard Hartunian wrote for Law360 on three recent U.S. sanctions enforcement actions against foreign banks that had engaged in unlawful practices to evade U.S. sanctions laws and lacked effective compliance programs.
In discussing these cases, the authors outline lessons learned and the need for foreign financial and nonfinancial institutions to be particularly vigilant in updating their U.S. sanctions compliance functions and in engaging in regular reassessments of their risk profiles.
You can read the full article here. Please get in touch if you’d like to discuss more.
