Standard Chartered Bank Extends DPA for Violating Iran Sanctions and Agrees to More than $1 Billion in Penalties

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Saturday, April 13, 2019
Author: 
Bruce Zagaris
Volume: 
35
Issue: 
4
Abstract: 

On April 9, 2019, Standard Chartered Bank (SCB), which is headquartered in London, England, agreed to pay more than $1 billion in penalties (including forfeiture of $240 million and a fine of $480 million) as well as to amend and extend its deferred prosecution agreement (PA) with the Justice Department for an additional two years for conspiring to violate the International Emergency Economic Powers Act (IEEPA). From 2007 to 2011, SCB participated in a criminal conspiracy, resulting in SCB processing approximately 9,500 financial transactions worth approximately $240 million through U.S. financial institutions for the benefit of Iranian entities. On April 9, 2019, the New York County District Attorney’s Office (DANY) also announced that SCB has agreed to amend its DPA with DNAY and extend it for two additional years, and to pay an additional financial penalty of $292,210,160.  In the amended DPA with DANY, SCB admits it violated New York State law by, inter alia, falsifying the records of New York financial institutions.  SCB has also entered into separate settlement agreements with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Board of Governors of the Federal Reserve System (the Federal Reserve), the New York State Department of Financial Services (DFS), and the United Kingdom’s Financial Conduct Authority (FCA) under which SCB must pay additional penalties totaling more than $477 million.  The Justice Department has agreed to credit a portion of these related payments.  After crediting, the DOJ will collect $52,210,160 of the fine, in addition to SCB’s $240 million forfeiture.