Civil Enforcement Information - Standard Chartered Bank (Civil Penalty Separate from Second Global Settlement)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (1748 words)

Notes:

1) This is the third case in total (from 2006 onward) in which two enforcement actions are presented in the same web post. Because the Zimbabwe-related penalty is fundamentally distinct from the violations issued in connection with the global settlement to resolve various criminal charges, they are categorized as a separate enforcement action in the Research System. Refer to Civil Enforcement Information - Standard Chartered Bank (Second Global Settlement) (2019) for consolidated comment on the 2019 Standard Chartered Settlement concerning criminal violations.

2) The Zimbabwe civil penalty recalls Civil Enforcement Information - Barclays Bank Plc (Second action) (2016), where Barclays UK was fined for its Zimbabwe branch routing USD payments through the U.S. for customers who were owned 50% or more by Zimbabwean SDNs. In that case, Barclays did not do proper due diligence to determine what customers were beneficially owned by SDNs. ...

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Civil Enforcement Information - Standard Chartered Bank (Civil Penalty Separate from Second Global Settlement)

TURBOFAC Commentary (1748 words)