It is being reported today that BNP Paribas remains the subject of an ongoing investigation by the Paris Prosecutor’s office in relation to allegations of complicity in crimes against humanity, torture and genocide arising from the financial services it provided to the government of Sudan between 2002 and 2008.
BNP’s Swiss subsidiary is also the subject of the investigation.
BNP Paribas has previously pled guilty to US sanctions charges, and the Swiss regulator FINMA has previously punished BNP Paribas Suisse.
While the relevant limitation period for sanctions offences in France has expired, the case is a reminder that same sanctions breaches can potentially give rise to liability for other offences.