Standard Chartered Bank OFAC Settlement: $132M (2012)

SCB processed wire transfers in apparent violation of five sanctions programs. Under the Burmese Sanctions Regulations (BSR), 31 C.F.R. part 537, SCB processed 5 wire transfers totaling approximately $59,642 between August 5, 2003, and May 24, 2005. Under the Iranian Transactions Regulations (ITR), 31 C.F.R. part 560, SCB processed 488 wire transfers totaling approximately $24,002,250 between January 26, 2001, and December 31, 2007. Under the now-repealed Libyan Sanctions Regulations (LSR), 31 C.F.R. part 550, SCB processed 135 wire transfers totaling approximately $12,349,361 between January 11, 2001, and April 27, 2004, involving the Government of Libya or Libyan persons. Under the Sudanese Sanctions Regulations (SSR), 31 C.F.R. part 538, SCB processed 283 wire transfers totaling approximately $96,665,537 between January 4, 2001, and November 13, 2007. Separate and unrelated to the conduct in the BSR, ITR, LSR, and SSR apparent violations, SCB processed 8 wire transfers totaling approximately $243,506.69 between February 28, 2011, and April 5, 2011, in apparent violation of the Foreign Narcotics Kingpin Sanctions Regulations (FNKSR), 31 C.F.R. part 598.

SCB voluntarily self-disclosed all apparent violations under OFAC's Economic Sanctions Enforcement Guidelines. OFAC determined the apparent violations were egregious, except for the apparent violations of the FNKSR. The total base penalty amount under the Guidelines for all apparent violations was $209,747,769: $625,000 for the BSR apparent violations; $74,553,945 for the ITR apparent violations; $25,127,006 for the LSR apparent violations; $109,320,066 for the SSR apparent violations; and $121,753 for the FNKSR apparent violations. The statutory maximum penalty was $427,852,032. SCB agreed to settle for $132,000,000, with the obligation deemed satisfied by payment of a greater amount in satisfaction of penalties assessed by U.S. federal or county officials arising out of the same pattern of conduct.

In reaching its egregious determination, OFAC found that SCB's conduct was marked by recklessness; a number of SCB employees, including senior management, were aware of the conduct that led to the apparent violations; the apparent violations resulted in significant harm to U.S. sanctions programs objectives; SCB is a highly sophisticated global financial institution; and SCB did not maintain adequate policies or procedures to ensure compliance with the sanctions programs administered by OFAC. OFAC noted that any civil penalty should be commensurate with the seriousness of SCB's conduct in order to achieve maximum future compliance effect and deter similarly situated financial institutions.

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