On October 20, 2015, the US Department of Justice, the US Department of Treasury’s Office of Foreign Assets Control, the New York County District Attorney’s Office, the New York Department of Financial Services and the Federal Reserve Board jointly announced penalties against Crédit Agricole and Credit Agricole Corporate and Investment Bank,—headquartered in Paris, France—in connection with violations of US sanctions laws, and imposed a total of $787.3 million in criminal and civil financial penalties. According to the agencies, CACIB and certain predecessor banks thereof processed thousands of transactions to or through US financial institutions involving countries/persons subject to sanctions regulations issued by OFAC through 2008, even as personnel within these entities were aware of the sanctions programs requiring US financial institutions to block and reject transactions involving such countries. In addition to monetary penalties, the Federal Reserve Board announced that Crédit Agricole and CACIB have consented to a cease and desist order requiring the firms to implement an enhanced global compliance program to meet US sanctions requirements administered by OFAC. CACIB has also entered into settlement agreements with OFAC, the New York District Attorney’s Office and the NYDFS. Furthermore, CACIB has entered into deferred prosecution agreements with the US Attorney’s Office of District of Columbia for violations of the International Emergency Economic Powers Act and the Trading With the Enemy Act and with the New York County District Attorney’s Office for violations of New York State law based on falsification of records of New York financial institutions. The NYDFS has also required Crédit Agricole to install an independent consultant for one year.

The Federal Reserve Board press release is available at: http://www.federalreserve.gov/newsevents/press/enforcement/20151020a.htm.

The Federal Reserve Board order is available at: http://www.federalreserve.gov/newsevents/press/enforcement/enf20151020a1.pdf.

The US Department of Justice notice is available at: http://www.justice.gov/opa/pr/cr-dit-agricole-corporate-andinvestment-bank-admits-sanctions-violations-agrees-forfeit-312.

The US Department of Treasury settlement is available at: http://www.treasury.gov/resourcecenter/sanctions/CivPen/Documents/20151020_cacib_settlement.pdf.

The NYDFS press release is available at: http://www.dfs.ny.gov/about/press/pr1510201.htm.