Abduwali Abdukhadir Muse—the headline-grabbing Somali pirate awaiting trial for attacking the Maersk Alabama in April—was probably surprised when his activities in the Gulf of Aden landed him in a defendant’s chair in federal court in downtown Manhattan. He is not the only one. In recent years, foreign individuals, banks and companies that deal with Iran or other targets of U.S. economic sanctions have also been surprised to learn that they have become the subjects of unexpected criminal proceedings in New York.

Recent criminal proceedings carried out by the New York County District Attorney and the U.S. Attorney for the Southern District of New York have resulted in the largest criminal penalties ever imposed for sanctions violations, and some of the furthest-reaching criminal enforcements in terms of jurisdiction over foreign persons.

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