Could Proper Paperwork Have Saved NY Bank From OFAC?

Law360, New York ( December 3, 2015, 10:50 AM EST) -- On Nov. 4, 2015, the Office of Foreign Assets Controls of the U.S. Department of the Treasury announced that Banco do Brasil SA, New York Branch (BBNY) has agreed to pay $139,500 to settle civil charges related to the U.S. sanctions program against Iran under the Iranian Transactions and Sanctions Regulations (ITSR). Important lessons may be learned based on the allegations in OFAC's Enforcement Information, including:...

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