Standard Chartered Bank agrees to $1 billion settlement over sanctions violations

The US Department of Justice (DOJ) and Department of Treasury's Office of Foreign Assets Control (OFAC) announced today a combined $1 billion settlement with Standard Chartered Bank (SCB), headquartered in the UK, for potential criminal and civil violations of the Cuban, Iranian, and Syrian sanctions regimes, as well as the now-repealed Burmese and Sudanese sanctions regimes.  According to the DOJ, SCB agreed to forfeit $240 million, a fine of $480 million, and to an extension of its deferred prosecution agreement with the DOJ for an additional two years for conspiring to violate the International Emergency Economic Powers Act (IEEPA).  The DOJ alleges that between 2007 and 2011, SCB processed approximately 9,500 financial transactions worth approximately $240 million through US financial institutions for  the benefit of Iranian entities.  

For its part, OFAC alleges that between June 2009 and June 2014, SCB processed over 9,300 transactions totaling over $437 million through the US that involved persons or countries subject to the  US's comprehensive sanctions programs.  The majority of the breaches concerned Iran-linked accounts maintained by SCB's branches in the United Arab Emirates and involved funds transferred through SCB's New York branch office.  OFAC determined that SCB did not voluntarily disclose the apparent violations, which OFAC characterized as "egregious."  

SCB separately agreed to settle potential civil liability for violations of the Zimbabwe Sanctions Regulations for an additional $18 million arising from transactions with persons identified on OFAC's List of Specially Designated Nationals and Blocked Persons or those entities majority owned by them.  According to OFAC, the designated individuals or entities maintained accounts with SCB's affiliate in Zimbabwe, which processed nearly 1,800 transactions totaling nearly $77  million through New York or other US financial institutions for the sanctions parties. 
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