The bank was officially neutral during World War II, but was widely seen as supporting Nazi war efforts, starting with the transfer of gold from the Czechoslovak National Bank to the German Reichsbank in early 1939. At the end of the war, the Allies agreed to close the BIS, but the decision was not implemented, in part at the insistence of John Maynard Keynes. While the Bretton Woods agreement remained in force, the BIS played a key role in maintaining international monetary convertibility. She also served as an agent for the European Payments Union with 18 countries, a settlement system that helped restore convertibility between European currencies from 1950 to 1958. The last time Ghaddar reached an agreement with the BIS on November 26, 2019, he imposed a civil fine of $368,000 which, unlike other companies that were taken in 2019 until enforcement, is a foreign company (from Lebanon). In 20 different cases between 2014 and 2016, the company exported generator sets with a total value of about $736,236 from Lebanon to Syria without the required export licenses. The generators are classified as EAR99 articles and controlled for re-export to Syria. The Bank for International Settlements is often referred to as the “central bank for central banks” because it provides banking services to institutions such as the European Central Bank and the Federal Reserve. These services include trading in gold and currency, as well as obtaining short-term credits. This measure shows that the BIS will not only exercise its power to impose civil sanctions, but will also not hesitate to deny export-related privileges. Because of the significant loss of activity that may result from the denial of export privileges, it is potentially even more damaging than a civil penalty.
According to the Order, the generators mounted in Lebanon were delivered with U.S. engines submitted to the EAR when they were re-exported to Syria, as they contained more than 10% of the original controlled content.  Ghaddar purchased the engines from a U.S. supplier in the U.K., which marked them as controlled objects. It is important that Ghaddar has been warned by the United Kingdom, a supplier, that Syria is a sanctioned country and that the products cannot be made available to individuals or institutions in Syria. After receiving the warning in 2014 and 2015, Ghaddar certified to the supplier`s U.S. parent company that it understood and complied with all applicable laws, rules and regulations, including EAR and other U.S. export and sanctions laws. Despite these certifications, Ghaddar re-exported the generators without the necessary BIS licenses.  Order Relating to Arrowtronic, LLC, United States Department of Commerce, Bureau of Industry and Security (October 30, 2019); Order Relating to AW-Tronics, LLC, United States Department of Commerce, Bureau of Industry and Security (October 30, 2019). Order Relating to Multiwire Laboratories, Ltd., United States Department of Commerce, Bureau of Industry and Security (January 16, 2019). . All of these companies received significant penalties for export violations and non-compliance with export laws. What does this tell us about possible enforcement measures in 2020? The BIS also encourages cooperation between central banks. Although technically separate from the BIS, the Basel Committee on Banking Supervision (BCBS) is a closely linked international forum for financial regulation, located in the BIS offices in Basel, Switzerland.