Compliance Lessons From OFAC Case Studies – Part II
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Part I of this article analyzed the regulatory and law enforcement actions taken against ABN AMRO Bank N.V., Lloyds TSB Bank plc, Credit Suisse AG, and Barclays Bank PLC for violations of the Trading with the Enemy Act and the International Emergency Economic Powers Act as administered by the Office of Foreign Assets Control (“OFAC”). Part II of this article analyzes the subsequent regulatory and law enforcement actions taken against ING Bank, N.V., Standard Chartered Bank, HSBC Holdings plc, The Bank of Tokyo-Mitsubishi UFJ, Ltd., The Royal Bank of Scotland plc, and BNP Paribas S.A. for OFAC violations.