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

Date issued: Apr. 09 2019

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TURBOFAC Commentary (1453 words)

Notes:

CONSOLIDATED COMMENT ON THE 2019 GLOBAL SETTLEMENT INVOLVING STANDARD CHARTERED BANK

1) RELATIONSHIP WITH THE 2012 OFAC SETTLEMENT AND DOJ DEFERRED PROSECUTION AGREEMENT

The relationship between violations described in the web post and those the subject of the 2012 global settlement involving Standard Chartered (SCB), the DOJ and OFAC is somewhat complex.

The Zimbabwe violations appear to have taken place subsequent to the 2012 original Settlement Agreement, but in any event these violations were not considered criminal, and are therefore outside the scope of and reported separately from the “global settlement.”

With respect to the global settlement, SCB settles charges stemming from violations some of which took place prior to the 2012 initial global settlement, and some of which took place after. Because some of...