Standard Chartered Bank OFAC Settlement: $18M (2019)

All of the transactions giving rise to the Zimbabwe-Related Apparent Violations involved persons identified on OFAC's 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. The conduct occurred over a period of several years; multiple SCBZ personnel appear to have been unaware that Bank customers, including those on the SDN List, could use their SCBZ-issued credit cards outside of Zimbabwe, including in the United States.

OFAC determined that SCB voluntarily self-disclosed the Zimbabwe-Related Apparent Violations and that the Zimbabwe-Related Apparent Violations constitute a non-egregious case. The total base penalty amount is $26,690,789. The settlement amount of $18,016,283 reflects OFAC's consideration of the facts and circumstances pursuant to the General Factors Affecting Administrative Action under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, app. A.

Since 2013, SCB undertook a comprehensive global remediation of its sanctions compliance program, including: forming a special board committee with responsibility for overseeing SCB's overall financial crime compliance program; implementing additional and more rigorous U.S. sanctions policies and procedures; spending $2.8 billion on financial crime compliance since 2012; increasing legal and financial crime compliance staff six-fold since 2012; certifying that relevant employees were trained on complying with U.S. economic sanctions laws and regulations; implementing additional measures to block payment instructions from countries subject to U.S. sanctions; providing compliance training programs for SCB's global correspondent banking clients; upgrading customer due diligence, transaction screening, and other compliance tools and technology; and improving the ability to assess and measure sanctions compliance risk.

In its Settlement Agreement with OFAC, SCB agreed to maintain a management team that: (1) is committed to a culture of compliance; (2) conducts regular risk assessments; (3) ensures that its internal controls appropriately mitigate the entity's sanctions-related risks; (4) conducts regularized audits; and (5) provides ongoing sanctions compliance training throughout SCB.

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