Foreign Banks Should Remain Wary Of US Sanctions Laws

Law360 (May 10, 2019, 4:02 PM EDT) -- 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.

With the issuance of new sanctions relating to Russia in April 2018, the “snap back” of secondary sanctions against Iran last November and widening sanctions against Venezuelan government-owned businesses this year, the pace and magnitude of U.S. sanctions enforcement actions against foreign banks lacking robust, updated compliance programs will likely increase.

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