HEC Research Papers Series,
HEC Paris

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.

Keywords: economic sanctions; non-American banks

JEL-codes: K33

40 pages, September 1, 2018

Note: Available at SSRN: https://ssrn.com/abstract=3320477

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