Enforcement Release - CA Indosuez Switzerland S.A.

Date issued: Sep. 26 2022

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TURBOFAC Commentary (244 words)

Consolidated comment on the CA Indosuez Switzerland S.A. and CFM Indosuez Wealth Enforcement Actions.

1) The CA Indosuez Switzerland S.A. and CFM Indosuez Wealth enforcement actions are unusual insofar as they are announced as two separate enforcement actions, but the text of the two documents is, in large part, identical. Apart from the fact that one action relates to a Swiss entity and one relates to a Monaco entity the other meaningful distinctions are (i) the sanctions programs violated and (ii) the value of the transactions processed.

From a legal basis standpoint, this is a straightforward case of a non-U.S. entity "causing" U.S. person financial institutions to deal in blocked property or otherwise export financial services to embargoed destinations. Compare Civil Enforcement Information - UBS AG and Civil Enforcement Information (FOV) - TD Bank, N.A.. As...