The earlier of Standard Chartered’s two large OFAC settlements on this site, and the smaller. The 2019 case is the one with the Dubai accounts.
What OFAC counted
OFAC’s enforcement information for 10 December 2012 lists 919 wire transfers across five programmes:
| Programme | Transfers | Approximate value | Base penalty |
|---|---|---|---|
| Sudan | 283 | $96.7m | $109.3m |
| Iran | 488 | $24.0m | $74.6m |
| Libya | 135 | $12.3m | $25.1m |
| Burma | 5 | $0.06m | $0.6m |
| Narcotics (Kingpin Act) | 8 | $0.24m | $0.12m |
Sudan carried 52 per cent of the $209.7 million total base penalty and Iran 36 per cent. The Iran transfers ran from 2001 to 2007 and were the largest by number, but Sudan’s were worth four times as much.
The settlement
Standard Chartered voluntarily self-disclosed all of the apparent violations. OFAC found everything except the eight Kingpin Act transfers egregious: the conduct was reckless, employees including senior management were aware of it, the programmes were significantly harmed, and the bank lacked adequate policies. It mitigated because some transactions might have been licensable, for a clean five-year record, for self-disclosure and cooperation, and for the agreement to settle. The $132 million was part of a global settlement and was deemed satisfied by a greater payment to US federal or county officials. See correspondent banking abuse.
What the record shows
- Sudan again. See the Sudan page and the stripping-era note.
- A self-disclosed, egregious case is possible. Disclosure lowers the base penalty without changing the finding. See egregious case and voluntary self-disclosure.