We know that fining international banks for sanctions violations is not an effective deterrent, even when the civil fines & penalties are in the multi-million dollar range, for those in command see such costs as the cost of doing business, but I have seen one sanctions violations case recently, worthy of mention. Inasmuch as fines alone do not stop the big banks, it is much more effective to also hit back at the individuals themselves who are responsible for the organized sanctions violations. Make sure that the people who actually evaded sanctions are terminated, as publicly as possible.
The New York case, where a whopping $258m fine imposed upon Deutsche Bank AG, for doing business with blacklisted countries, also required the bank to discharge six of the bad actors. Additional players in the sanctions evasion process has already left the bank, and three others transferred, and banned from any duties involving the bank's American operations.
You have got to tip your hat the the New York State Department of Financial Services, for it has been at the forefront of effective enforcement of sanctions laws; it reportedly will receive $200m of the fine payment, at in my humble opinion, it is well earned.
I have a suggestion; name, shame and publish the photographs of all the individuals involved in sanctions evasion, Superintendent Albanese, so that bankers worldwide get the message, loud & clear. Bankers are still constantly accessing my article containing the photographs of BNP Paribas officers who were terminated in its scandal. Out all these financial thugs, please.
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