Sanctions are relevant to the issue of double criminality, but it wasn enough to dismiss the case."The essence of the alleged wrongful conduct in this case is the making of intentionally false statements in the banker client relationship that put HSBC at risk. Sanctions are part of the state of affairs necessary to explain how HSBC was at risk, but they are not themselves an intrinsic part of the conduct," she wrote in her decision."For this reason, I cannot agree with Ms. Sanctions in order to understand the risk to HSBC is to allow the essence of the conduct to be defined by foreign law..

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