Compliance Blog

Written by Shari R. Pogach, Regulatory Paralegal

Foreign banks are under serious scrutiny by federal and state authorities and regulators for dealing with countries blacklisted by the United States.  Almost $9 billion is what it’s costing BNP Paribas S.A. (BNP) for not obeying U.S. economic sanctions against Sudan, Iran and Cuba.  The $8.9 billion penalty was to settle U.S. Department of Justice charges that BNP willfully continued to do business with nations and entities on the U.S. sanctions list.  While a record fine, BNP is simply the latest among foreign banks that have collectively paid billions in settlements since 2009: 

01/09/09 - Lloyds TSB Bank Plc Agrees to Forfeit $350 Million in Connection with Violations of the International Emergency Economic Powers Act;

12/16/09 - Credit Suisse Agrees to Forfeit $536 Million in Connection with Violations of the International Emergency Economic Powers Act and New York State Law;

05/10/10 - Former ABN Amro Bank N.V. Agrees to Forfeit $500 Million in Connection with Conspiracy to Defraud the United States and with Violation of the Bank Secrecy Act;

08/18/10 - Barclays Bank PLC Agrees to Forfeit $298 Million in Connection with Violations of the International Emergency Economic Powers Act and the Trading with the Enemy Act;

06/12/12 - ING Bank N.V. Agrees to Forfeit $619 Million for Illegal Transactions with Cuban and Iranian Entities;

12/10/12 - Standard Chartered Bank Agrees to Forfeit $227 Million for Illegal Transactions with Iran, Sudan, Libya, and Burma; and

12/11/12 - HSBC Holdings Plc. And HSBC Bank USA N.A. Admit to Anti-money Laundering and Sanctions Violations, Forfeit $1.256 Billion in Deferred Prosecution Agreement.  

According to news sources, U.S. authorities have also begun initial settlement talks with Germany’s Commerzbank and Deutsche Bank over sanctions violations.  There are reports of at least six banks in Germany, France, Italy or Japan that are under long-running investigations and could face fines or forfeitures for processing transactions with countries or entities the U.S. has designated.

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BSA Blast – NAFCU members can read all about BNP’s settlement and penalty in the July issue of NAFCU’s BSA Blast.  And, this issue also includes a new BSA quiz that’s oriented to Bank Secrecy Act (BSA) training for credit union board and volunteer members.   Let us know what you think. Happy BSA reading!