Sanctions Evasion Reference

Lloyds TSB: a policy of deleting sanctioned names

Lloyds TSB paid $217 million in 2009 although OFAC counted only $37 million in transfers. OFAC says it had a policy of intentionally manipulating and deleting information about sanctioned parties in wire instructions.

period

2003–2006

outcome

Settlement

parties

Lloyds TSB Bank, plc

programmes

Islamic Republic of Iran, Sudan, Libya

reviewed

2026-10-04

Cite this page
APA 7
Sanctions Evasion Reference. (2026, October 4). Lloyds TSB: a policy of deleting sanctioned names. https://sanctionsevasion.org/cases/lloyds-tsb-2009/
Chicago
Sanctions Evasion Reference. “Lloyds TSB: a policy of deleting sanctioned names.” Last reviewed October 4, 2026. https://sanctionsevasion.org/cases/lloyds-tsb-2009/.
BibTeX
@misc{ser-cases-lloyds-tsb-2009,
  author = {{Sanctions Evasion Reference}},
  title  = {Lloyds TSB: a policy of deleting sanctioned names},
  year   = {2026},
  note   = {Last reviewed 2026-10-04},
  url    = {https://sanctionsevasion.org/cases/lloyds-tsb-2009/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2009-12-22 $217,000,000 Not voluntarily self-disclosed. Deemed satisfied by a prior payment of a greater amount to the Department of Justice and the New York County District Attorney for the same pattern of conduct.

The ratio is the first thing to notice: a $217 million settlement for payments that totalled $37 million.

What OFAC counted

OFAC’s web posting says “Lloyds had a policy of intentionally manipulating and deleting information about U.S. sanctioned parties — notably Iran, Sudan, and Libya — in wire transfer instructions executed on behalf of its bank and non-bank customers.” From June 2003 to August 2006 it routed at least 4,200 electronic funds transfers, worth $36,988,457, through third-party banks in the United States:

  • Iran: at least 165 transfers worth $13.7 million, June to October 2003, for the Government of Iran or persons in Iran, including Iranian financial institutions.
  • Sudan: at least 574 transfers worth $13.9 million, June 2003 to August 2006.
  • Libya: about 3,542 transfers worth about $9.4 million, June 2003 to April 2004, for one Libyan customer.

Lloyds said it had stopped dollar clearing for Iranian bank customers in 2003. The dollar accounts concerned were vostro accounts, dollar accounts Lloyds kept for Iranian and Sudanese financial institutions. See correspondent banking abuse and wire stripping.

The settlement

OFAC did not treat the matter as self-disclosed, but credited substantial cooperation: Lloyds engaged an independent consulting firm to review all applicable payment messages and all periodic account statements for the vostro accounts, and handed the results over in electronic form. Remediation included an annual review of its policies and a statistically significant sample of dollar payments by Internal Audit for two years, overseen and certified by an independent third party that the UK’s Financial Services Authority had to approve. The $217 million was deemed satisfied by an earlier payment of a greater amount to the Justice Department and the New York County District Attorney.

What the record shows

  • The settlement is far above the value counted. That fits OFAC describing a policy that ran for three years rather than a set of isolated errors. See the stripping-era note.
  • A single customer can dominate the count. About 3,500 of the 4,200 transfers were for one Libyan customer.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Sudan sanctions — A US embargo regime from 1997, revoked in 2017 and followed by targeted measures. Its main relevance here is historical: several of the largest penalties in OFAC's record concern conduct from the years it was in force.
  • Libya sanctions — A UN regime aimed at armed groups, illicit petroleum exports and the misuse of Libyan state institutions, with a parallel US programme. The Panel of Experts' reporting documents fuel smuggling in unusual detail.

Enforcement documents and sources

  1. Lloyds TSB Bank, plc, Settles Allegations of Violations of the Iranian Transactions Regulations, the Sudanese Sanctions Regulations, and the now-repealed Libyan Sanctions Regulations. U.S. Department of the Treasury, Office of Foreign Assets Control, 2009. Web posting, 2009-12-22, US$217,000,000.
  2. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All enforcement cases