Standard Chartered Deferred Prosecution Agreement 2012

Among these factors was the fact that the SCB cooperated fully throughout the investigation and went down considerable resources, both for its internal investigation and for the investigations conducted by the Prosecutor`s Office and the DOJ. Although the vast majority of these payments were legal under the derogations existing at the time from the sanctions legislation, they should nevertheless have been disclosed in accordance with the terms of the retrospective agreement and in response to questions from the regulatory authorities. This failure to inform occurred despite the fact that SCB and the supervisory authorities agreed that financial transactions with Iran and other companies sanctioned by OFAC constituted a de facto risk related to AML. .