Capping off a year of robust sanctions enforcement, two recent enforcement actions highlight the risks of doing business with sanctioned countries, in particular Iran. In December 2016, federal and New York state regulators initiated enforcement actions related to alleged sanctions violations involving Iran. In the first enforcement action, Italy’s largest retail bank, Intesa Sanpaolo SpA (Intesa), was alleged to have engaged in dollar-clearing transactions on behalf of Iranian clients. In the second action, a US person individual, Kenneth Zong, was alleged to have engaged in a scheme to move restricted Iranian funds out of South Korea and transfer them to Iranian recipients. Read more at Steptoe’s advisory here.
