Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III)
Sometimes a picture is very clear but legal words and concepts are proffered in an attempt to disguise and even deceive. As set forth in the factual statements outlined by the government, and agreed to by Commerzbank, it is evident that Commerzbank had no culture of ethics and compliance. Instead, Commerzbank was committed, strategically and operationally, to circumventing and evading US sanctions and BSA/AML laws....