Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank.





In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the United Kingdom’s Financial Conduct Authority (FCA) announced a number of settlement agreements in connection with SCB’s violations of Iran Sanctions Programs.



Under the agreements, SCB agreed with the:



(1) Justice Department to forfeit $240 million, a fine of $480 million and to extend its existing deferred prosecution agreement (DPA) for an additional two years;


(2) Department of Treasury’s Office of Foreign Asset Control (OFAC) to pay total penalties of $657 million; the Federal Reserve to pay penalties of $163 million; the New York Department of Financial Services to pay total penalties of $180 million; and the UK’s Financial Conduct Authority to pay total penalties of $133 million; and


(3) New York District Attorney’s Office to pay a financial penalty of $292 million and extend its DPA with DA-NY for two years.





The Justice Department agreed to credit a portion of these payments and reduced its fine for SCB from $480 million to $52 million, along with the $240 million forfeiture.


 


In this episode, Mike Volkov reviews the Standard Chartered Bank enforcement action and the implications of the action.