Standard Chartered Bank OFAC Settlement: $639M (2019)

Last updated: July 20, 2026

Standard Chartered Bank ("SCB"), a financial institution headquartered in the United Kingdom, settled potential civil liability for apparent violations of the now-repealed Burmese Sanctions Regulations; the Cuban Assets Control Regulations, 31 C.F.R. Part 515; the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560; the now-repealed Sudanese Sanctions Regulations; the Syrian Sanctions Regulations, 31 C.F.R. Part 542; and, separately, the Zimbabwe Sanctions Regulations, 31 C.F.R. Part 541. SCB settled the global settlement apparent violations for $639,023,750 as part of a broader agreement involving multiple U.S. federal agencies and the United Kingdom's Financial Conduct Authority.

Penalty Amount

$639,023,750.00

Enforcement Date

April 9, 2019

Rank in Top Penalties

Case Details

Type:: Entity
Name:: Standard Chartered Bank
Country:: 🇬🇧 United Kingdom
Industry:: Banking
Address:: United Kingdom
Penalty amount:: $639,023,750.00
Base civil monetary penalty:: $2,715,100,479.00
Egregious case:: Yes
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: June 2009 to June 2014
Program:: now-repealed Burmese Sanctions Regulations (BSR)Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR)Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR)now-repealed Sudanese Sanctions RegulationsSyrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), or Executive Order 13582 of August 17, 2011, "Blocking Property of the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)Zimbabwe Sanctions Regulations, 31 C.F.R Part 541 (ZSR)
Enforcement date:: April 9, 2019

Nature of the Apparent Violations

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 involving persons or countries subject to comprehensive sanctions programs administered by OFAC. The apparent violations span the now-repealed Burmese Sanctions Regulations; the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR); the now-repealed Sudanese Sanctions Regulations; and the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), or Executive Order 13582 of August 17, 2011 (collectively, the Global Settlement Apparent Violations). Separately, SCB also settled apparent violations of the Zimbabwe Sanctions Regulations, 31 C.F.R. Part 541 (ZSR).

The majority of the Global Settlement conduct concerns Iran-related accounts maintained by SCB's Dubai, UAE branches (SCB Dubai), including accounts 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 and/or ordinarily resident in Iran.

How OFAC Determined the Penalty

OFAC determined that SCB did not voluntarily self-disclose the Global Settlement Apparent Violations and that they constitute an egregious case. The total base penalty amount for the Global Settlement Apparent Violations is $2,715,100,479. SCB agreed to settle its civil liability for the Global Settlement Apparent Violations for $639,023,750; SCB's obligation to pay OFAC that settlement amount was deemed satisfied up to an equal amount by payments in satisfaction of penalties assessed by U.S. federal agencies arising out of the same patterns of conduct during the same time periods. The settlement amount reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors Affecting Administrative Action under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A.

Aggravating Factors

At a minimum, SCB acted with reckless disregard and failed to exercise a minimal degree of caution or care with regard to the conduct that led to the Global Settlement Apparent Violations
SCB had actual knowledge and/or reason to know of the conduct at issue, and various supervisory and managerial personnel from multiple business lines, often including those with responsibility for financial crimes and sanctions compliance, were involved in discussions regarding specific customers or products and services that posed OFAC sanctions risks
The Global Settlement Apparent Violations resulted in significant harm to multiple economic sanctions programs, and provided dozens of companies subject to U.S. economic sanctions access to the U.S. financial system
SCB's compliance program was inadequate to manage the bank's risk and suffered from multiple systemic deficiencies, including failure to respond to warning signs in a timely and efficient manner
SCB is a large, commercially sophisticated financial institution

Mitigating Factors

SCB provided OFAC with substantial cooperation throughout the course of its investigation, including by signing a tolling agreement and multiple extensions to the agreement, and submitting detailed, well-organized, and voluminous information and documents to OFAC throughout the course of the multi-year investigation
SCB has undertaken remedial efforts in order to curtail and inhibit similar apparent violations from occurring in the future
A small number of the Syria-related transactions occurred shortly after Executive Order 13582
SCB had not received a penalty notice or Finding of Violation in the five years preceding the earliest date of the transactions giving rise to the Global Settlement Apparent Violations

Official Source Documents

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View archived version View on ofac.treasury.gov

Archived on June 13, 2026

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