What is it about?
The purpose of this paper is to use two recent US prosecutions of Turkish nationals for sanctions evasion, the Zarrab and Atilla cases, as case studies of recent developments in US sanctions law and law enforcement. This paper highlights the expanding scope of US sanctions laws and the challenges for banks in complying with them. In particular, it shows the similarities between sanctions evasion and other financial crime methodologies, arguing that banks need to become more interdisciplinary in their operational approach to financial crime.
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Why is it important?
The Zarrab and Atilla cases are of international significance in sanctions law. This paper is the first in-depth case study of these cases from a legal and compliance perspective.
Perspectives
From my perspective, the Zarrab and Attila cases are both important and fascinating, particularly for the complexity of the methods used to evade sanctions, and the way these methods changed over time. It is only by examining the facts and arguments of cases like these is a great way of developing a better understanding of sanctions compliance in practice.
Ben Scott
Read the Original
This page is a summary of: Halkbank and OFAC: a sanctions evasion case study, Journal of Money Laundering Control, October 2019, Emerald,
DOI: 10.1108/jmlc-12-2018-0074.
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