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ARTICLE · 20 APRIL 2015

Settlements In Brief: Recent Settlements Highlight Importance Of Preventative Action

De Brauw Blackstone Westbroek
De Brauw Blackstone Westbroek
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De Brauw Blackstone Westbroek

De Brauw Blackstone Westbroek

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Foreign corrupt practices and violations of sanctions and export control increasingly lead to enforcement actions.

GlobalInternational Law
Roan Lamp
Roan Lamp
Patrick Ploeger
Patrick Ploeger
Geert Potjewijd
Geert Potjewijd
Rick Van ’T Hullenaar
Rick Van ’T Hullenaar
Marnix Somsen
Marnix Somsen
Richard Van Staden Ten Brink
Richard Van Staden Ten Brink
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Foreign corrupt practices and violations of sanctions and export control increasingly lead to enforcement actions. These enforcement actions are settled regularly by criminal and supervisory authorities. In light of these developments, companies are advised to take appropriate measures. We provide a brief overview of the most important settlements every month. This month we discuss recent settlements with four companies in the US. The first settlement concerns one of Germany's largest banks, Commerzbank AG, which allegedly violated several US laws by doing business with sanctioned entities and failing to have adequate anti-money laundering controls. The second and third settlements also involved violations of US sanctions laws. PayPal had not implemented effective compliance procedures to identify and prevent transactions in apparent violation of the applicable US sanctions regulation. Schlumberger Oilfield Holdings Ltd., one of the largest oilfield services providers

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