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3/19/2020

U.S. Treasury Department Announces Settlement with Standard Chartered Bank | U.S. Department of the Treasury

U.S. Treasury Department Announces Settlement with Standard
Chartered Bank
April 9, 2019

Treasury Settlement Part of Combined $1.1 Billion Settlement for Bank’s Apparent Violations of
Multiple Sanctions Programs
WASHINGTON – As part of a combined $1.1 billion settlement with federal, state, local, and
United Kingdom government partners, the U.S. Department of the Treasury’s O ice of Foreign
Assets Control (OFAC) today announced a $639 million agreement with Standard Chartered
Bank (SCB) to settle its potential civil liability for apparent violations of U.S. economic
sanctions. Today’s settlement resolves OFAC’s investigation into apparent violations of a
number of U.S sanctions programs, including those relating to Burma, Cuba, Iran, Sudan, and
Syria. OFAC is also settling a separate case involving apparent violations by SCB of sanctions
related to Zimbabwe.
From June 2009 until May 2014, SCB processed 9,335 transactions totaling $437,553,380 that
were processed to or through the United States. All of these transactions involved persons or
countries subject to comprehensive sanctions programs administered by OFAC (including
Burma, Cuba, Iran, Sudan, and Syria). The majority of the conduct concerns Iran-related
accounts maintained by SCB’s Dubai, UAE branches (“SCB Dubai”), including accounts at SCB
Dubai, held for a number of general trading companies and a petrochemical company. SCB
Dubai processed USD transactions to or through SCB’s branch o ice in New York or other U.S.
financial institutions on behalf of customers that sent payment instructions to SCB Dubai while
physically located or ordinarily resident in Iran. SCB also processed online banking instructions
for residents of comprehensively sanctioned countries.
These actions constitute apparent violations of the now-repealed Burmese Sanctions
Regulations; the Cuban Assets Control Regulations, 31 C.F.R. Part 515; the Iranian Transactions
and Sanctions Regulations, 31 C.F.R. Part 560; the now-repealed Sudanese Sanctions
Regulations; and the Syrian Sanctions Regulations, 31 C.F.R. Part 542, or Executive Order 13582
of August 17, 2011, “Blocking Property of the Government of Syria and Prohibiting Certain
Transactions With Respect to Syria.”
https://home.treasury.gov/news/press-releases/sm647

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3/19/2020

U.S. Treasury Department Announces Settlement with Standard Chartered Bank | U.S. Department of the Treasury

Under the settlement agreement

, SCB has agreed to sustain its commitment to

implementing robust compliance procedures by ensuring that it has a management team in
place that: (1) is committed to a culture of compliance; (2) conducts regular risk assessments;
(3) ensures that its internal controls appropriately mitigate the entity’s sanctions-related risks;
(4) conducts regularized audits; and (5) provides ongoing sanctions compliance training
throughout SCB.
OFAC worked closely and collaboratively with its counterparts at other government agencies in
the investigation of this matter. Today’s settlement is simultaneous with SCB’s settlements with
the Board of Governors of the Federal Reserve System, the Federal Reserve Bank of New York,
the U.S. Department of Justice, Criminal Division, Money Laundering and Asset Recovery
Section, the U.S. Attorney’s O ice for the District of Columbia, the New York County District
Attorney’s O ice, the New York State Department of Financial Services, and the United
Kingdom’s Financial Conduct Authority.
SCB’s $639 million settlement with OFAC will be deemed satisfied by the bank’s payment of a
forfeiture and fine to the Department of Justice and fine to the Federal Reserve Board of
Governors for the same pattern of conduct.
Separately, between May 2009 and July 2013, SCB Zimbabwe processed transactions to or
through the United States involving Zimbabwe-related Specially Designated Nationals (SDNs) or
entities owned 50 percent or more, individually or in the aggregate, by one or more Zimbabwerelated SDNs. These transactions constituted apparent violations of the Zimbabwe Sanctions
Regulations, 31 C.F.R. Part 541. SCB will remit $18,016,283 to OFAC to settle civil liability relating
to the apparent violations of the ZSR.
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https://home.treasury.gov/news/press-releases/sm647

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