disguised transactions valued at more than USD 10 billion, and did not have sufficient... - comma

Leafka

Senior Member
Polish
Hi,

I can't decide whether I need a comma after billion or not:

From at least 1999 through 2006, XYZ allegedly disguised over 27,000 dollar-clearing transactions valued at more than USD 10 billion, and did not have sufficient procedures to ensure that activities conducted at its offices outside of the US complied with US sanctions laws.

(I'm the author of the sentence.)
 
  • PaulQ

    Banned
    UK
    English - England
    Does "without having" work? As I read it, there are two actions (i) disguising transactions (ii) failing to ensure sufficient procedures to ensure that activities conducted at its offices outside of the US complied with US sanctions laws.
     

    The Newt

    Senior Member
    English - US
    I would probably use the comma, because the phrase before it is fairly long. A few (purely optional) stylistic things: I would write "more than 27 dollar-clearing transactions valued at in excess of USD 10 billion..."
     
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