The US$1.92 billion settlement reached between HSBC and the U.S. Department of Justice this past December over allegations of money laundering by the global bank served as a stark reminder to all financial institutions: The penalty for breaking sanctions against Iran and other blacklisted nations would not only be severe, but even the biggest institutions would be held accountable.
The aggressive stance is the result of a shift in priorities and particular changes in the way U.S. authorities are interpreting laws, say Eric Volkman and Robert Sims, attorneys with international law firm Latham & Watkins.
looking beyond borders 