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ENFORCEMENT INFORMATION FOR APRIL 9, 2019
Standard Chartered Bank Settles Potential Civil Liability for Apparent Violations of Multiple Sanctions Programs: Standard Chartered Bank (“SCB” or the “Bank”), a financial institution headquartered in the United Kingdom, has agreed to settle potential civil liability for apparent violations of the now-repealed Burmese Sanctions Regulations (BSR); the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR)[1]; the now-repealed Sudanese Sanctions Regulations; and the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), or Executive Order 13582 of August 17, 2011, “Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria” (E.O. 13582)[2] (collectively, the “Global Settlement Apparent Violations”). SCB’s settlement with OFAC is part of a global settlement among SCB, OFAC, the Board of Governors of the Federal Reserve System, the Federal Reserve Bank of New York, the...
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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...