[twic]

There have occasionally been efforts to do large international USD transactions which don't touch the US, usually because one or both of the participants is under US sanction. There is enough USD infrastructure in London that it may be an alternative to New York, but everyone involved has to scrupulously avoid any interaction with any machinery under US jurisdiction, which is quite difficult.

I learned about this from reading the case brought in he UK by the US government to try to stop this happening. I didn't bookmark it, and of course can't find it now.

Not this, but an example of how it can go wrong:

> According to the settlement agreement, BACB actively solicited U.S. dollar business from Sudanese banks and processed the transactions by way of an internal book transfer process that involved a nostro account maintained at a foreign bank (Bank B) located in a country that imports Sudanese-origin oil. (A nostro account is an account a bank holds in a foreign currency in another bank.) Although these transactions were not processed to or through the U.S. financial system, the process to fund BACB’s U.S. dollar nostro account at the foreign bank did involve transactions processed by or through U.S financial institutions in apparent violation of the U.S. economic sanctions.

https://www.nafcu.org/compliance-blog/ofac-dings-london-bank...