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Extraterritorial Enforcement Resumes with OFAC Penalty Against African Lender

By Valentina Pasquali and Daniel Bethencourt

A multi-million dollar penalty against a Zimbabwean bank accused of sanctions violations reflects the U.S. Treasury Department’s increasingly aggressive enforcement efforts, an approach that analysts say has led to an uptick in legal challenges. In a “pre-penalty notice,” the department told CBZ Bank in March that it was preparing to assess what would have been a record-shattering fine of $3.8 billion against it for processing U.S. dollars on behalf of another blacklisted Zimbabwean lender, the Zimbabwe Independent reported in October. According to Jeremy Paner, a former official with the department’s Office of Foreign Assets Control, U.S. dollar-denominated transactions do not...

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