Between October 2018 and December 2019, US regulators levied $4.3 billion in fines, up 186% from the same analysis period before. Eighty-six percent (86%) of the total fines (in $) issued by US regulators were aimed at EMEA-headquartered financial institutions for violations against sanctions programs.
This focus on foreign banks illustrates the geopolitical climate in the US where trade wars have led to sanctions programs being implemented against Iran, North Korea, Sudan, Myanmar, Libya, Cuba and more.
Key Enforcement Trends:
- The average fine value issued by US regulators to foreign banks was 10 times higher (in $) than those issued to domestic banks
- The biggest single fine amounted to $717.2 million, issued by the DoJ to a Tier 1 French bank as part of a multi-authority settlement