Sanctions — Primary, Secondary, OFAC Enforcement Mechanisms
How a sanctions regime is built, what each tier actually prohibits, and why secondary sanctions extend U.S. reach
On June 30, 2014, BNP Paribas — France's largest bank and one of the largest banks in the world — pleaded guilty in the U.S. District Court for the Southern District of New York to conspiring to violate U.
S. sanctions on Sudan, Iran, and Cuba. The bank agreed to pay approximately $8.
9 billion in penalties to U.S. federal and state authorities, the largest single-entity sanctions enforcement penalty in U.
S. history at that time. The conduct U.
S. prosecutors documented was specific and operational: between roughly 2002 and 2012, BNP Paribas employees in Geneva and Paris had structured U.S.
-dollar transactions on behalf of sanctioned counterparties — Sudanese state oil companies, Iranian financial institutions, Cuban entities — by routing them through unaffiliated U.S. correspondent banks while stripping or omitting payment messages of identifying information that would have caused those U.
S. banks to block the transactions.
That is the opening. Finishing a lesson is where it stops being interesting and starts being useful: the full lesson runs to 7 sections and ends with 6 practice questions. A free account is what opens the rest, and the other 255 lessons in the Academy with it. No card.
What this lesson covers
- 1Primary versus secondary sanctions — different mechanisms, different reach
- 2The license system — how OFAC permits exceptions to the prohibitions
- 3The penalty architecture — civil and criminal exposure under IEEPA
- 4Major OFAC enforcement actions, 2008-2020 — what large sanctions cases actually look like
- 5BNP Paribas, June 30, 2014 — what a sanctions enforcement action actually delivers
- 6Where to see this on the platform
- 7Summary