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U.S. Economic Sanctions, Corporate Compliance and the Global Regulation of Banks

jeudi 16 novembre 2017

David Restrepo Amariles and Matteo Winkler (HEC Paris) will present their recent paper on U.S. Economic Sanctions and the Corporate Compliance of Foreign Banks at the Perelman Centre. An overview of the discussion of the paper is available here.

In the last decade, the U.S. has dramatically increased the enforcement of its economic sanctions arsenal against foreign banks. While this arsenal continues to expand, legal scholarship tends to overlook one of its crucial consequences : a radical change in the compliance functions of the targeted banks. In fact, after entering into specific agreements with the U.S. government, non-U.S. banks commit to reforming their compliance functions according to U.S. standards. The depth of the relationship between the extraterritoriality of U.S. laws and banks’ compliance functions demands further inquiry. This article fills that gap by expounding how economic sanctions legislation drives developments in substantial compliance efforts by foreign banks, discussing the current economic sanctions regime and analyzing important enforcement cases. This Article concludes that, as non-U.S. banks manage the heavy burden of U.S. sanctions more deftly than before, a process of Americanization of corporate compliance is underway in the banking industry and beyond.

A paper will be distributed among the attendees. If you would like to access the paper, please contact Prof. Gregory Lewkowicz or the authors.

Responsable du comité éditorial :

Centre Perelman de l’Université libre de Bruxelles
CP 132 - Av. F. D. Roosevelt 50 - 1050 Bruxelles
Tel. 02/650 38 84 - Fax 02/650 40 07 - e-mail