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Expert Analysis

Inside Clearstream's OFAC Settlement Agreement

Law360, New York (February 4, 2014, 12:33 PM EST) -- Clearstream Banking SA has agreed to pay $152 million to resolve claims it violated U.S. sanctions against Iran by exporting custody and related services from the United States to the Central Bank of Iran. This latest settlement not only highlights the sanctions risks faced by firms in the financial sector, but also the need for a robust compliance program, the benefit of timely and complete voluntary self-disclosures (which generally cut a potential Office of Foreign Assets Control penalty in half) and the extraterritorial reach of the U.S. sanctions programs....

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