Abstract This article establishes a link between the economic sanctions imposed by the United States and the internal compliance procedures of non-American banks.  Scholars have recently examined one or the other of these issues, but have rarely established a connection between the two. At this time, we do not know of another study that offers a comprehensive perspective on the compliance of banks operating outside the United States, particularly European banks, while also taking into consideration the arsenal of American sanctions as well as the extraterritoriality problem.David Restrepo, Matteo Winkler, U.S. Economic Sanctions and the Corporate Compliance of Foreign Banks, The International Lawyer, 2018. 3 questions for HEC professors Matteo Winkler and David Restrepo Amariles What led you to examine American economic sanctions? M.W.: I have been studying the extraterritoriality question for 13 years. It’s a fascinating subject because it’s at the crossroads of so many other issues: politics, international business, public and private law, public control over private transactions… David, an expert in numbers and data, and I wanted to understand the impact of American sanctions. In other words, how the United States uses its own law as an economic weapon of war. D.R.: What interested me about this subject is the way American foreign policy, which is strictly regulated, affects corporate operations in other countries. So, we studied the impact of these measures on the organization and even the business cultures of non-American companies. I don’t know if this was the goal of these sanctions, but it’s certainly […]

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