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BNP Paribas pleads guilty to violating U.S. sanctions against Sudan, Iran and Cuba

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BNP ParibasLots of forms of financial skulduggery can be described as "sophisticated," but not all of them are. A classification might be:

If you do some complicated stuff in such a way that you'd have a plausible case that you're following the rules, even if the authorities knew about all your complicated stuff, then that's a "sophisticated" way to evade the rules.
If you just, like, use Wite-Out to conceal the bad stuff that you're doing, then it's something else, even if you use a lot of Wite-Out and in complicated ways.

BNP Paribas pleaded guilty yesterday to violating U.S. sanctions against Sudan, Iran and Cuba, agreeing to pay almost $9 billion to various regulators and prosecutors. Those regulators and prosecutors variously described its methods as "elaborate" and "egregious schemes," but they stopped short of "sophisticated." Because in fact the methods mostly went something like this:

First, the payment from the Cuban entity would be made from its account at French Bank 1 to a BNPP Paris bank account at French Bank 1. As a book-to-book transfer -- i.e., a transfer from one account to another within the same financial institution -- no U.S. dollar clearing would occur. Second, BNPP Paris would transfer the money from its account at French Bank 1 to a transit account held at BNPP Paris itself. This bank-to-bank transfer would result in U.S. dollar clearing, with the payment typically being transferred through BNPP NY or on occasion by U.S. Bank 1.


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