A UK financial institution agreed to settle U.S. Treasury Department Office of Foreign Assets Control ("OFAC") charges that it violated United States sanctions imposed on a number of countries.
Standard Chartered Bank ("SCB") allegedly violated:
- the now-repealed Burmese Sanctions Regulations;
- the Cuban Assets Control Regulations;
- the Iranian Transactions and Sanctions Regulations;
- the now-repealed Sudanese Sanctions Regulations; and
- the Syrian Sanctions Regulations (collectively, the "Global Settlement Apparent Violations").
According to OFAC, SCB processed over 9,000 improper transactions totaling approximately $400 million that were processed to or through the United States. OFAC concluded that SCB did not voluntarily self-disclose the Global Settlement Apparent Violations. OFAC described the non-disclosure as an "egregious case." To settle the violations, SCB agreed to pay $639,023,750, and committed to various compliance enhancements. SCB's settlement with OFAC is part of a "global settlement" between SCB, OFAC, the Federal Reserve Board, the Federal Reserve Bank of New York, the Department of Justice, the New York Country District Attorney's Office, the New York State Department of Financial Services and the UK's Financial Conduct Authority.
In addition, SCB agreed to remit roughly $18 million to settle potential civil liability for alleged violations of the Zimbabwe Sanctions Regulations. OFAC stated that all of the transactions that led to the Zimbabwe-related violations concerned individuals listed on OFAC's Specially Designated Nationals and Blocked Persons List ("SDN List") or parties that were owned by individuals on the SDN List at the time that the transactions took place. OFAC determined that SCB voluntarily self-disclosed the apparent Zimbabwe-related violations, and that the violations constitute a "non-egregious case."
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