Posts Tagged With Sanctions

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Eight Foreign Businessmen Indicted On Charges of Conspiracy to Violate Economic Sanctions Against Syria, Crimea

On June 12, 2018, five Russian nationals and three Syrian nationals were charged with conspiring to violate U.S. economic sanctions against Syria and Crimea.  The charges were based on transactions conducted through a Russian shipping company, Sovracht, which had previously been designated for violating sanctions against Crimea and was not permitted to transact in U.S. dollars without first receiving a license from OFAC.  The alleged conspirators used fake companies and fabricated shipping records to conceal ... Continue Reading

Turkish Banker Sentenced to 32 Months for Conspiring to Violate U.S. Sanctions Against Iran and Other Offenses

On May 16, 2018, Mehmet Hakan Atilla, the former Deputy General Manager of International Banking of a Turkish bank, was sentenced to 32 months in prison for his role in a scheme to violate U.S. economic sanctions against Iranian entities.  In January, a jury convicted Atilla of bank fraud and conspiracy charges in connection with the scheme, which involved the facilitation of billions of dollars in transactions in the proceeds of oil sales held in ... Continue Reading

Turkish Banker Convicted of Conspiring to Evade U.S. Sanctions against Iran and Other Offenses

On January 3, 2018, Mehmet Hakan Atilla, a citizen and resident of Turkey, was found guilty of conspiring with others to use the U.S. financial system to conduct transactions on behalf of the Government of Iran and other Iranian entities and to defraud U.S. financial institutions by concealing the nature of these transactions.  After a four-week trial before U.S. District Judge Richard M. Berman, a federal jury convicted Atilla on five of six charges in ... Continue Reading

Turkish Banker Arrested for Conspiring to Violate U.S. Sanctions against Iran

On March 27, 2017, Mehmet Hakan Atilla, a citizen and resident of Turkey, was arrested for conspiring to use the U.S. financial system to conduct transactions on behalf of the Government of Iran and other Iranian entities and to defraud U.S. financial institutions by concealing the nature of these transactions.  According to the Complaint unsealed on March 28, Atilla, a Deputy General Manager of International Banking at a Turkish Bank, helped Reza Zarrab, a gold ... Continue Reading

ZTE Corporation Agrees to Plead Guilty and Pay over $430.4 Million for Violating U.S. Sanctions by Sending U.S.-Origin Items to Iran

On March 7, 2017, Attorney General Jeff Sessions announced that ZTE Corporation agreed to plead guilty for conspiring to violate the International Emergency Economic Powers Act (“IEEPA”), obstructing justice and making a material false statement.  ZTE’s agreement to plead guilty is the DOJ component of a series of settlements that ZTE reached with U.S. agencies, which totals to an agreement to pay the U.S. Government $892,360,064.  On the criminal side, ZTE will enter a guilty ... Continue Reading

BNP Paribas to Pay Record $8.9 Billion Penalty

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 ... Continue Reading

D.C. Circuit Reaffirms Prosecutors’ Authority over Deferred Prosecution Agreements

On April 5, the D.C. Circuit overturned a decision by a district court judge that rejected a DPA between DOJ and Fokker Services B.V.  The Circuit held that the district court erred in rejecting the agreement as too lenient because the executive’s “long-settled primacy over charging decisions” includes the decisions to pursue a DPA and define its terms.  The D.C. Circuit also recognized that DPAs are an “increasingly important tool” in government resolutions and could ... Continue Reading

Crédit Agricole Corporate and Investment Bank Admits to Sanctions Violations, Agrees to Forfeit $312 Million

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 ... Continue Reading

BNP Paribas Sentenced for Conspiring to Violate the International Emergency Economic Powers Act and the Trading with the Enemy Act

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 ... Continue Reading

Schlumberger Oilfield Holdings Ltd. Plead Guilty and Agrees to Pay Over $232.7 Million for Violating U.S. Sanctions by Facilitating Trade with Iran and Sudan

On April 30, Schlumberger Oilfield Holdings Ltd. (“SOHL”)—a wholly owned subsidiary of Schlumberger Ltd.—pled guilty to facilitating illegal transactions with Iran and Sudan.  As part of the plea agreement, SOHL agreed to forfeit more than $77 million and pay a $155.1 million fine—the largest criminal fine in connection with an International Emergency Economic Powers Act prosecution to date.  In the agreed-upon statement of facts, the company acknowledged that its U.S. employees (1) approved capital expenditure ... Continue Reading

Commerzbank AG Admits to Sanctions and Bank Secrecy Violations, Forfeits $563 Million and Pays $79 Million Fine

On March 12, Commerzbank AG, a global financial institution, and its U.S. branch entered into a DPA for violations of the International Emergency Economic Powers Act and the Bank Secrecy Act and agreed to forfeit $563 million and pay a $79 million fine.  The bank moved $263 million through the U.S. financial system on behalf of Iranian and Sudanese businesses. It used non transparent payment messages, amended payments to avoid U.S. sanctions filters, and employed ... Continue Reading

Judge Rejects Fokker Settlement

On February 5, U.S. District Judge Richard Leon rejected a deferred prosecution agreement that Fokker Services B.V. had negotiated with the government.  An information charged the company with making over 1100 separate shipments of parts used in aircraft aviation and navigation systems to Iran, Sudan, and Burma—countries subject to export controls.  Judge Leon noted that the penalty the government proposed, even when combined with fines that would be paid to other regulators, did not exceed ... Continue Reading

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