On June 30, BNP Paribas pled guilty in the Southern District of New York to conspiring to violate the International Emergency Economic Powers Act and the Trading with the Enemy Act by allegedly processing billions of dollars of transactions through the U.S. financial system on behalf of Sudanese, Iranian, and Cuban entities subject to U.S. economic sanctions.  According to the government, between 2004 and 2012, BNP knowingly moved over $8.8 billion through the U.S. financial system on behalf of sanctioned entities, including more than $4.3 billion in transactions involving entities that were specifically designated by the U.S. government as being cut off from the U.S. financial system.  As part of the guilty plea, BNP will pay a record $8.9 billion penalty.  Federal prosecutors attributed this large penalty, in part, to BNP’s initial failure to fully cooperate with the government’s investigation.  The U.S. Attorney’s Office for the Southern District of New York coordinated with the New York County District Attorney’s Office, the Federal Reserve, the New York State Department of Financial Services, and the Treasury Department in investigating BNP.  In addition to reaching a guilty plea with federal prosecutors, BNP entered into an agreement with the Federal Reserve to take certain remedial steps to ensure its compliance with U.S. law in its ongoing operations and to pay a civil monetary penalty.  BNP also entered into an agreement with the New York Department of Financial Services which, among other things, requires BNP to suspend its U.S. dollar clearing operations through its New York Branch and other affiliates for one year for business lines on which the misconduct centered. DOJ Press Release

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