BNP Paribas Terminates Cuba Business

Wednesday, July 2, 2014
In addition to the historic financial penalties, $8.9 billion, leveled against BNP Paribas (BNNP) for violating sanctions towards Cuba, Iran and Sudan, various other provisions were agreed to with the pertinent U.S. agencies.

As part of the Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and BNNP, it was further stipulated that:

"BNPP has taken global remedial actions by increasing the frequency and content of its employee training program, adding additional resources to the bank's Compliance units, enhancing its internal audit process, implementing a stronger compliance review of its client base, reinforcing the bank's existing intemal controls (such as upgrading its interdiction filter to identify transactions where a sanctions target may have been removed from a set of payment instructions), and prioritizing compliance from the top levels of the bank's senior management. These efforts included policy changes, including terminating all business and prohibiting new business in any currency with sanctioned entities. In addition, BNPP relocated its group responsible for developing and strengthening sanctions policies from Paris to New York. BNPP has also taken substantial steps to discipline individuals who were involved in the conduct at issue, including terminating several employees, reducing bonus compensation, mandating training, and issuing warnings, among other types of discipline."