On May 1, BNP Paribas S.A. (“BNP”) was sentenced to a five-year term of probation, ordered to forfeit $8,833,600,000, and ordered to pay a $140,000,000 fine for conspiring to violate the International Emergency Economic Powers Act and the Trading with the Enemy Act.  This marked the first time a financial institution had been convicted and sentenced for violations of U.S. economic sanctions, and the total financial penalty was the largest ever imposed in a criminal case.  The government alleged that BNP, in violation of U.S. embargoes and sanctions, provided Sudan, Iran, and Cuba with access to billions of dollars.  In addition to its federal criminal conviction, BNP also (1) pled guilty in New York State Supreme Court to falsifying business records and conspiring to falsify business records; (2) agreed to a cease-and-desist order and to the payment of a monetary penalty of $508 million to the Board of Governors of the Federal Reserve System; and (3) entered into an agreement with the New York State Department of Financial Services, which required BNP to pay a fine of $2.24 billion, terminate 13 employees and suspend U.S. dollar clearing operations through its New York Branch for one year for business lines on which the misconduct centered.  United States v. BNP Paribas SA, 14-cr-460 (S.D.N.Y.).  DOJ Press Release