On April 9, 2019, officials announced that London-based Standard Chartered Bank (“SCB”) reached resolutions with a half-dozen Federal, State, and UK agencies (DOJ, the Manhattan District Attorney’s Office (“DANY”), the Federal Reserve Bank, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the New York Department of Financial Services, and the U.K. Financial Conduct Authority) arising out of U.S. dollar transactions involving Iran and other sanctioned countries.  Following a six-year investigation, SCB, inter alia, entered into Amended Deferred Prosecution Agreements with DOJ and DANY, had monitorships that it was operating under since 2013 terminated, and paid in the aggregate to all six agencies approximately $1.08 billion (with DOJ and OFAC crediting a variety of the payments the Bank made to the other agencies).  In the amended DPAs, SCB acknowledged that two former Dubai-based employees had conspired with bank customers with known Iranian connections to conduct U.S. dollar transactions in violation of U.S. sanctions.  One of the former employees has pleaded guilty to conspiracy to defraud the United States and to violate the International Emergency Economic Powers Act.  DOJ officials noted that SCB has made significant improvements to its sanctions and financial crime compliance programs since the original 2012 DPAs, and provided substantial cooperation with the government’s investigation.  They also acknowledged SCB’s work in devising and implementing new models of industry collaboration and public-private partnerships to detect and prevent financial crime.

Separately, on April 15, 2019, officials announced an Iranian sanctions-related resolution with two UniCredit Group financial institutions that allegedly facilitated U.S. dollar transactions on behalf of sanctioned entities by concealing the entities’ true identity and connection to the transactions.  UniCredit Bank AG agreed to plead guilty to conspiring to violate IEEPA and to defraud the United States, and affiliate UniCredit Bank Austria entered into a non-prosecution agreement with DOJ to resolve similar allegations.  UniCredit Group institutions will pay total financial penalties of approximately $1.3 billion to resolve investigations by DOJ and other federal and New York state and local authorities.

United States v. Standard Chartered Bank, No. 12-cr-262 (D.D.C.)

DOJ Press Release (Standard Chartered)

United States v. UniCredit Bank AG, No. 19-cr-128 (D.D.C.)

DOJ Press Release (UniCredit)