U.S. Economic Sanctions and the Corporate Compliance of Foreign Banks

Abstract

This article links the economic sanctions enacted by the United States and the internal compliance functions of non-American banks. Whereas scholars have recently investigated either aspect, only a few have drawn a connection between them. At the moment of writing, and to our knowledge, no scholar has proposed a comprehensive view of the corporate compliance of banks operating outside the territory of the United States, and in Europe especially, regarding the U.S. economic sanctions arsenal as a whole, including the extraterritoriality problem.