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ENFORCEMENT INFORMATION FOR DECEMBER 11, 2012
HSBC Holdings plc Settles Potential Liability for Apparent Violations of Multiple Sanctions Programs: HSBC Holdings plc ("HSBC Holdings") has agreed to remit $375,000,000 to settle potential civil liability on behalf of it and certain of its affiliates (collectively "HSBC Group") for apparent violations of: the Cuban Assets Control Regulations ("CACR"), 31 C.F.R. part 515; the Burmese Sanctions Regulations ("BSR"), 31 C.F.R. part 537; the Sudanese Sanctions Regulations ("SSR"), 31 C.F.R. part 538; the now-repealed Libyan Sanctions Regulations ("LSR"), 31 C.F.R. part 550; and the Iranian Transactions Regulations ("ITR"), 31 C.F.R. part 560 [1]. HSBC Holdings’ settlement with the Office of Foreign Assets Control ("OFAC") is part of a global sanctions related settlement among HSBC Holdings, OFAC, the U.S. Department of Justice, the New York County District Attorney’s Office, and the Federal Reserve Board of Governors. HSBC Holdings agreed to settle...
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*For further factual information see: Settlement Agreement (OFAC) - HSBC Holdings plc and Deferred Prosecution Agreement - HSBC Holdings plc.
1) With respect to Paragraph 22 of the Settlement Agreement:
"Separately and unrelated to the above matters, on May 24, 2006, the London branch of HBUS acted as a clearing bank in a book entry transfer of 32,000 ounces of gold bullion, valued at $20,560,000, for the ultimate benefit of Bank Markazi, Iran, in apparent violation of the prohibition against the "exportation ... , directly or indirectly, from the United States, ... of any ... services to Iran or the Government of Iran," 31 C.F.R. § 560.204."
Note that, here and in general, when a transaction is effected for the benefit of some beneficiary not otherwise party to the transaction effected on...