BNP Paribas paid roughly $8.97 billion in 2014 to resolve U.S. charges that it had spent nearly a decade moving money through the American financial system for countries under U.S. sanctions. The BNP Paribas sanctions fine remains the largest sanctions-related penalty ever imposed on a bank, and it came with a guilty plea, a one-year suspension of U.S. dollar clearing in part of the bank’s business, and five years of federal probation.
What BNP Paribas Did
From at least 2004 through 2012, BNP Paribas knowingly processed more than $8.8 billion through the U.S. financial system on behalf of entities tied to Sudan, Iran, and Cuba, in violation of the International Emergency Economic Powers Act and the Trading with the Enemy Act.1United States Department of Justice. BNP Paribas Sentenced for Conspiring to Violate the International Emergency Economic Powers Act and the Trading with the Enemy Act The Treasury Department’s OFAC settlement also covered violations involving Burmese sanctions.2U.S. Department of the Treasury. Treasury Reaches Largest Ever Sanctions-Related Settlement with BNP Paribas SA for $963 Million
The method was deliberate. Bank employees stripped references to sanctioned entities from wire transfer messages before routing payments through New York correspondent banks, and in some cases instructed other financial institutions not to include sanctioned party names in payment details. The point was to make the transactions invisible to U.S. compliance filters so the money would clear. The concealment was not the work of a few employees. It ran across multiple business lines in several countries and was known to senior executives.3United States Department of Justice. BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion for Illegally Processing Financial Transactions
How the $8.97 Billion Breaks Down
The federal criminal component was a forfeiture of $8,833,600,000 plus a criminal fine of $140 million.1United States Department of Justice. BNP Paribas Sentenced for Conspiring to Violate the International Emergency Economic Powers Act and the Trading with the Enemy Act Around that federal case, several other U.S. authorities settled their own investigations, and their penalties were credited against the total rather than added on top of it.4BNP Paribas. BNP Paribas Announces a Comprehensive Settlement Regarding the Review of Certain USD Transactions by US Authorities
The agencies involved and their pieces of the settlement:
- The Department of Justice handled the criminal prosecution and the guilty plea in the Southern District of New York.
- The Office of Foreign Assets Control settled its civil investigation for $963 million, the largest OFAC settlement on record.2U.S. Department of the Treasury. Treasury Reaches Largest Ever Sanctions-Related Settlement with BNP Paribas SA for $963 Million
- The Federal Reserve Board imposed a $508 million civil money penalty and a cease and desist order.5Federal Reserve. Order to Cease and Desist and Order of Assessment of Civil Money Penalty Issued Upon Consent
- The New York State Department of Financial Services assessed a $2.24 billion civil penalty and installed an independent monitor.6New York State Department of Financial Services. Cuomo Administration Announces BNP Paribas To Pay $8.9 Billion
- The New York County District Attorney’s Office secured a separate guilty plea in New York State Supreme Court to falsifying business records in the first degree and conspiracy in the fifth degree.
Business Restrictions and Compliance Overhaul
The money was only part of the punishment. BNP Paribas was sentenced to five years of probation in federal court, the first time a global bank had been convicted and sentenced for U.S. sanctions violations.1United States Department of Justice. BNP Paribas Sentenced for Conspiring to Violate the International Emergency Economic Powers Act and the Trading with the Enemy Act
The bank also accepted a one-year suspension of U.S. dollar direct clearing beginning January 1, 2015, focused on the Oil and Gas Energy and Commodity Finance business line where the misconduct had been concentrated.4BNP Paribas. BNP Paribas Announces a Comprehensive Settlement Regarding the Review of Certain USD Transactions by US Authorities Losing dollar clearing, even temporarily, is a serious commercial hit for a global bank, because so much commodity trade settles in dollars.
The Federal Reserve’s cease and desist order required BNP Paribas to build a new OFAC compliance program and to relocate part of its Group Financial Security function to the United States, where it would take ultimate responsibility for the bank’s global OFAC compliance.7Board of Governors of the Federal Reserve System. Cease and Desist Order – BNP Paribas S.A. The New York DFS installed an independent monitor to oversee the compliance and management reforms.8New York State Department of Financial Services. Consent Order Issued to BNP Paribas S.A.
What Happened to the People Involved
At the direction of the DFS, 13 individuals were terminated by or separated from the bank as a result of the investigation.6New York State Department of Financial Services. Cuomo Administration Announces BNP Paribas To Pay $8.9 Billion The Federal Reserve permanently barred the bank from rehiring 11 named individuals, identified in the public order as Banker A through Banker K. They included a former Chief Operating Officer, a former Head of Group Compliance, and several front-office employees and relationship managers in Paris and Geneva who had handled sanctioned-country clients.5Federal Reserve. Order to Cease and Desist and Order of Assessment of Civil Money Penalty Issued Upon Consent
No individual BNP Paribas executive was criminally prosecuted. Deputy Attorney General James Cole said at the time that the bank’s failure to cooperate “significantly impacted the government’s ability to bring charges against responsible individuals.”3United States Department of Justice. BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion for Illegally Processing Financial Transactions
Civil Lawsuits Still in Play
The 2014 settlement did not close the book. Plaintiffs have brought civil suits under U.S. anti-terrorism statutes, arguing that the transactions BNP Paribas processed for Sudan effectively supported a government with known ties to terrorism. Those claims draw on facts the bank admitted in its guilty plea.
In late 2024, a jury returned a $20.75 million verdict against the bank in a case brought by plaintiffs connected to acts of terrorism linked to the Sudanese government. A federal judge in Manhattan later rejected the bank’s motion to dismiss that verdict, finding BNP Paribas had not shown the decision was a miscarriage of justice. As of early 2026, the ruling cleared the way for a formal appeal. The bank has said publicly that it is confident the verdict will be overturned and has described it as specific to three plaintiffs, though related litigation may still be pending.