كيف سرق نظام الإنقاذ مليارات الدولارات من أموال بترول السودان؟ .. هذا ما كشفه المحققون الأمريكان

9. During the period covered by the bank's intemal review, BNPP Suisse maintained
USD-denominated correspondent accounts for several Sudanese banks, including four banks
identified by OFAC as Specially Designated Nationals. BNPP Suisse appears to have structured
a two-part payment process involving non-Sudanese banks in order to facilitate USD payments
from the Sudanese banks' correspondent accounts at BNPP Suisse to other non-U.S. accounts.
By January 2005, BNPP Suisse had opened USD accounts for nine banks located in third
countries (the "Regional Banks"). Based on the documentation and information submitted to
OFAC, the Regional Banks appear to have used their accounts at BNPP Suisse to facilitate "USD
clearing on behalf of Sudanese banks." BNPP identified certain Know Your Customer account
opening documents stating that at least several ofthe Regional Banks' accounts were opened "in
the context of the US embargo against Sudan" with the aim of "facilitating transfers of funds in
USD for Sudanese banks." In order to process the Sudanese-related transactions to or through
the United States, BNPP Suisse utilized a combination of book-to-book transfers and the
Regional Banks' accounts that concealed the interest ofthe Sudanese parties inthe underlying
payments. First, acting on payment instructions from a Sudanese customer, BNPP Suisse
processed a book transfer in USD from the Sudanese entity's account to a Regional Bank's
account on BNPP Suisse's books. Subsequently, acting on payment instructions from the
Regional Bank, BNPP Suisse processed a USD clearing transaction in the name of the Regional
Bank (without referencing sanctioned parties or Sudan), to or through the United States. BNPP
appears therefore to have conveyed the benefit ofthe services ofthe unwitting U.S. bank
recipients to Sudan and directly or indirectly exported financial services from the United States
to Sudan.