The US Treasury and Federal Banking Agencies (FBAs) have published a fact sheet on foreign correspondent banking, summarising key areas of federal supervisory and enforcement practice (link here). In relation to sanctions, the fact sheet says that: The largest OFAC penalties have followed a sustained pattern of serious sanctions violations, with intentional evasion of sanctions or failure by senior management…...
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Michael is Senior Partner at Peters & Peters Solicitors LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters &...
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