Last year in the United States some very large companies paid some very large fines for export control and sanction violations. In June 2012 United Technologies Corporation agreed to a $78 million settlement with the U.S. Department of State and the U.S. Department of Justice for illegal software exports to China, and Dutch bank ING paid $619 million to New York city and state governments and the federal government to settle allegations of breaches of sanctions against Cuba and Iran. Two months later, Standard Chartered Bank made a $340 million settlement with the New York Department of Financial Services (DFS).
While the U.S. has a long history of sanction-related enforcement, the European Union’s efforts have been less high-profile, and without the big-ticket fines and settlements. But the European Union has become increasingly robust in its use of unilateral sanctions—meaning restrictive measures that go above and beyond those imposed by the United Nations Security Council. The newly imposed sanctions, spurred by Iran’s race to attain nuclear power, affect European businesses across a wide spectrum of industries, including exporting companies, banks, insurance companies, and shipping companies.
