British American Tobacco’s Financial Scheme to Avoid Sanctions Detection (Part II of II)
British American Tobacco’s deceit and elevation of business over compliance permeates its recent blockbuster settlement for $629 million with the Department of Justice and Office of Foreign Asset Control. Importantly, the BAT settlement confirms DOJ’s new, aggressive approach to sanctions and export enforcement, and OFAC’s imposition of a penalty equal to the statutory maximum. For compliance professionals, the BAT scheme is interesting to review because...