- OFAC settlement extends sanctions reach beyond US dollar
- What were First Bank’s violations?
- Processing US dollar payments for individuals or entities located in Iran and Syria
- Euro-denominated payments to Iran as a foreign subsidiary of a US company
- Sanctions compliance implications
Law360, Expert analysis: The recent Office of Foreign Assets Control (OFAC) settlement with JC Flowers & Co over sanctions arising from non-US currency services provided by its Romanian bank subsidiary extends OFAC’s reach outside the US financial system, and highlights the need to educate foreign affiliates about US sanctions compliance, say lawyers at Arnold & Porter.
Sign in or take a trial to read the full analysis.
To continue reading this news article, as well as thousands of others like it, sign in to LexisPSL or register for a free trial