The Value And Limitations Of Trade Compliance Policies

By Eric Sandberg-Zakian (March 2, 2018, 11:16 AM EST) -- Companies around the world are increasingly paying eye-popping penalties to settle allegations that they have violated U.S. economic sanctions or export controls. Last year, the Chinese telecom equipment company ZTE Corp. agreed to penalties of just under $1.2 billion in a combined civil and criminal settlement with the U.S. departments of Commerce, Treasury and Justice in connection with an alleged conspiracy to sell products subject to U.S. export control jurisdiction to Iran. In 2014, the French bank BNP Paribas agreed to pay $8.9 billion in a combined civil and criminal settlement with the Treasury and Justice departments for violating sanctions restricting financial transactions involving Cuba, Sudan and Iran. Some of the largest settlements involve violations that allegedly occurred over many years during which the defendants' compliance teams repeatedly missed opportunities to uncover and remediate compliance lapses....

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