United States ex rel. Brutus Trading, LLC v. Standard Chartered Bank - 3rd Decl. of the OFAC Asst. Dir. Of SC&E

Date issued: Mar. 08 2021

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TURBOFAC Commentary (639 words)

1) Notes Common to all Three Declarations of OFAC’s Assistant Director of Sanctions Compliance and Evaluation Made in United States ex rel. Brutus Trading, LLC v. Standard Chartered Bank (SDNY, 2019)

The procedural context of the declarations is a “qui tam” suit brought by an entity incorporated by two individuals for the purposes of the suit. “Qui tam” is a mechanism by which private individuals (i.e. whistleblowers, or more formally, “realtors”) who assist a prosecution can receive part financial penalties recovered by the government as a result of the prosecution. The government can choose to support or oppose a realtor’s suit. Here, the qui tam realtors sued Standard Chartered Bank (SCB) pursuant to the False Claims Act, alleging that SCB had, as a result of the bank’s failure to make proper disclosures throughout the investigation, fraudulently induced OFAC and other