With the suspension of FCPA, is the SFO now really likely to proceed against corrupt businesses? And is the UK government likely to grant fu

The recent allegations involving Santander and Lloyds Bank remind us that sanctions due diligence is a minefield. It also raises important questions about how far financial institutions can reasonably go to insulate themselves from harm.   The Financial Times  and other publications recently reported that two of the UK’s largest banks, Lloyds and Santander, provided banking services to a business ultimately owned by a US-sanctioned Iranian entity.   Last week, Santander issue