Trial Court Testimony of Adam Szubin and David Cohen re: the Application of Secondary Sanctions in United States v. Atilla

Date issued: Nov. 30 2017

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TURBOFAC Commentary (1011 words)

Notes:

1) The native PDF file contains trial court testimony from United States v. Atilla 15 Cr. 867 (RMB) (S.D.N.Y.), the criminal prosecution of the deputy director general of the Turkish bank "Halkbank" in connection with his role in evasive transactions that were "sanctionable" under certain secondary sanctions authorities and, potentially, prohibited under the ITSR. See comments to United States v. Atilla 15 Cr. 867 (RMB) (S.D.N.Y. Feb. 7, 2018) (Dkt. 493) for comment on the legal bases of the criminal prosecution. The initial indictment contained allegations of direct violations of the ITSR as a result of certain funds transiting the U.S. financial system, but as the litigation proceeded it appeared less likely that such allegations could be proven.

Of particular note here, there is testimony of Adam Szubin (pp. 645-678), testifying about events having taken...