On October 20, Crédit Agricole Corporate and Investment Bank (“CACIB”), based in Paris, agreed to enter into a deferred prosecution agreement and forfeit $312 million for violations of the International Emergency Economic Powers Act and the Trading with the Enemy Act.  According to court documents, CACIB subsidiaries in Switzerland moved approximately $312 million through the U.S. financial system on behalf of sanctioned entities located in Sudan, Burma, Iran and Cuba.  The government alleged that CACIB’s subsidiaries did so by employing deceptive practices to conceal the involvement of sanctioned banks.  As a result of this conduct, CACIB also entered into a deferred prosecution agreement with the New York County District Attorney’s Office and agreed to a cease-and-desist order with the Board of Governors of the Federal Reserve System.  DOJ Press Release