The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $639,023,750 settlement with Standard Chartered Bank (“SCB” or the “Bank”), a financial institution headquartered in the United Kingdom. The bank has agreed to settle its potential civil liability for apparent violations of the now-repealed Burmese Sanctions Regulations (BSR); the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR); the now-repealed Sudanese Sanctions Regulations; and the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), or Executive Order 13582 of August 17, 2011, “Blocking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).
From June 2009 until June 2014, SCB processed 9,335 transactions totaling $437,553,380 that were processed to or through the United States. All of these transactions involved persons or countries subject to comprehensive sanctions programs administered by OFAC. The majority of the conduct concerns Iran-related accounts maintained by SCB’s Dubai, UAE branches (“SCB Dubai”), including accounts at SCB Dubai held for a number of general trading companies, and a petrochemical company. SCB Dubai processed USD transactions to or through SCB’s branch office in New York (“SCB NY”) or other U.S. financial institutions on behalf of customers that sent payment instructions to SCB Dubai while physically located or ordinarily resident in Iran. OFAC determined that the Bank did not voluntarily self-disclose the apparent violations, and the apparent violations constitute an egregious case.
Separately, the bank has agreed to settle its potential civil liability for apparent violations of the Zimbabwe Sanctions Regulations (ZSR). The bank has agreed to remit $18,016,283. All of the transactions giving rise to the Zimbabwe-Related Apparent Violations involved persons identified on OFAC's List of Specially Designated Nationals and Blocked Persons (the “SDN List”) or parties that were owned 50 percent or more, directly or indirectly, by persons on the SDN List at the time the transactions occurred. The designated and/or blocked persons maintained account relationships with SCB’s affiliate in Zimbabwe (“SCBZ”), and engaged in funds transfer or debit/credit card transactions whose net settlement transfers were sent to, and processed by SCB NY or other U.S. financial institutions. SCB NY processed 1,795 transactions totaling $76,795,414, for or on behalf, or that otherwise contained a property interest, of those sanctioned entities.
OFAC determined that SCB voluntarily self-disclosed the Zimbabwe-Related Apparent Violations and that the Zimbabwe-Related Apparent Violations constitute a non-egregious case.