Quoting the Wall Street Journal's Risk and Compliance Blog, the FCPA blog notes multiple cases in the guilty plea where BNP staff warned management that it was exposed to regulatory liability:
In 2005, a senior compliance officer at BNP warned: “As I understand it, we have a number of Arab Banks (nine identified) on our books that only carry out clearing transactions for Sudanese banks in dollars. … This practice effectively means that we are circumventing the U.S. embargo on transactions in USD by Sudan.”
Later that year, BNP's compliance staff met with executives to again express, “to the highest level of the bank, the reservations of the Swiss Compliance office concerning the transactions executed with and for Sudanese customers.”
In 2007, a senior compliance officer warned that clearing Sudan transactions through U.S. banks could be viewed as a “grave violation” of sanctions law.
Another compliance officer warned that the banks BNP was helping “play a pivotal part in the support of the Sudanese government which … has hosted Osama Bin Laden and refuses the United Nations intervention in Darfur.”
I will say it is curious that all 3 examples are about the Sudanese violations, while none reference the violations in regard to Iran, which was arguably more in OFAC's enforcement crosshairs.
Note: The Wall Street Journal story is behind a paywall. Mr. Watchlist does not typically promote primary sources that are not freely available. In this case, however, the article is a secondary source referenced from the FCPA Blog story.
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