On 9 December, Standard Chartered PLC, a UK banking organisation with a significant presence in Asia, Africa and the Middle East, announced that it agreed to a three year extension of the Deferred Prosecution Agreements (“DPAs”) entered into in December 2012 with the US Department of Justice (“DOJ”) and the New York County District Attorney’s Office (“DANY”) relating to violations of US sanctions on Iran and other countries. The extended DPAs provide that US authorities will dismiss the charges against Standard Chartered in December 2017, provided that Standard Chartered fulfils certain requirements and obligations before that time, such as bolstering its sanctions compliance program. Standard Chartered also agreed to retain an independent monitor to evaluate and make recommendations regarding its sanctions compliance program. This news follows the imposition of a $300 million penalty in August 2014 by the New York State Department of Financial Services (“NYDFS”) for failure to comply with an earlier settlement with the NYDFS relating to the 2012 DPAs (please see Issue 26 for additional details).
At the same time, Standard Chartered announced that it is cooperating with an on-going US sanctions-related investigation. The Wall Street Journal reports that this investigation involves the bank’s operations in Dubai, which may have handled business for Iranian- controlled entities, and also involves employees who worked in the United Arab Emirates. These investigations cover possible violations of US sanctions that occurred after the period covered by the 2012 DPAs.