Sanctions Evasion Reference

Standard Chartered UK: 70 loans to a Sberbank subsidiary

OFSI penalised Standard Chartered £20.47m in 2020 over loans to Denizbank, a Turkish bank almost wholly owned by Sberbank, that did not qualify for the EU-nexus exemption. Ministerial review cut the earlier £31.5m.

period

2015–2020

outcome

Civil penalty

parties

Standard Chartered Bank; Denizbank A.Ş.; Sberbank of Russia

programmes

Russian Federation

reviewed

2026-09-20

Cite this page
APA 7
Sanctions Evasion Reference. (2026, September 20). Standard Chartered UK: 70 loans to a Sberbank subsidiary. https://sanctionsevasion.org/cases/standard-chartered-uk-2020/
Chicago
Sanctions Evasion Reference. “Standard Chartered UK: 70 loans to a Sberbank subsidiary.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/standard-chartered-uk-2020/.
BibTeX
@misc{ser-cases-standard-chartered-uk-2020,
  author = {{Sanctions Evasion Reference}},
  title  = {Standard Chartered UK: 70 loans to a Sberbank subsidiary},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/standard-chartered-uk-2020/}
}

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

Penalties imposed

AuthorityDate AmountNote
OFSI 2020-02-18 £20,471,810 Two penalties (£7,693,233.50 and £12,778,576.33) substituted on ministerial review for £11.9m and £19.6m. 30% voluntary-disclosure reduction. Covers 21 loans worth £97.4m; OFSI assessed 70 of 102 loans as lacking an EU nexus.

Not the Standard Chartered case in the OFAC record, which concerns Iran and Dubai accounts. This one concerns Russia, loans, and a bank in Türkiye that a sanctioned Russian bank owned almost outright.

The structure

In 2014 the EU, and with it the UK, restricted lending to certain Russian banks and their subsidiaries. Article 5(3) of Council Regulation 833/2014 prohibited loans or credit with a maturity over 30 days to the listed entities. Sberbank was one of them, and OFSI’s notice records that its restrictions applied to Denizbank A.Ş. as its majority-held subsidiary.

Between April 2015 and January 2018 Standard Chartered made 102 loans to Denizbank. Article 5(3)(a) exempts credit whose specific and documented objective is financing the import or export of non-prohibited goods between the EU and a third country, which means the financed trade has to have an EU nexus. OFSI assessed that some of the 102 loans qualified and that 70, with an estimated transaction value over £266 million, did not.

Why it is a screening case, not a scheme

The bank did not hide anything. It had ceased all trade finance with Denizbank when the restrictions arrived. It then introduced dispensations to allow loans where it judged an exemption applied, and OFSI found those dispensations “were not appropriately put in place”, so the loans that followed were made outside any exemption, repeatedly, over an extended period.

The subsidiary is the point. A designated parent’s majority-owned subsidiary is restricted whether or not it is named on any list, which is the same lesson as the fifty percent rule, arriving through a lending desk instead of a payments queue. And the exemption that was supposed to guard against it had a single, checkable condition, the EU nexus, that the loans did not meet.

Why the figures moved

OFSI could penalise only breaches after 1 April 2017, when the relevant power under section 146 of the Policing and Crime Act 2017 began. That is why the penalties cover 21 of the 70 non-qualifying loans, £97.4m of the £266m. OFSI classed the case “most serious”, applied a 30% reduction for voluntary disclosure and cooperation, and imposed £11.9m in August 2019 and £19.6m in December 2019. On ministerial review in February 2020 the Economic Secretary substituted £7,693,233.50 and £12,778,576.33, for a total of £20,471,809.83. A published penalty can move after review, and in this case it moved down by about a third.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Russia sanctions — Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.
  • Türkiye — A large manufacturing and transit economy whose trade with several restricted destinations has grown substantially, making it central to third-country routing analysis.

Enforcement documents and sources

  1. Imposition of Monetary Penalty – Standard Chartered Bank. HM Treasury, Office of Financial Sanctions Implementation, 2020. Report of penalty, s149(2) PACA 2017, 18 February 2020.
  2. Financial sanctions enforcement: decisions and monetary penalties imposed. HM Treasury, Office of Financial Sanctions Implementation, 2026.
  3. Financial sanctions enforcement and monetary penalties guidance. HM Treasury, Office of Financial Sanctions Implementation, 2024. Section 146 of the Policing and Crime Act 2017 as amended.
  4. Policing and Crime Act 2017, section 146. UK Parliament (legislation.gov.uk), 2017.

All enforcement cases