Standard Chartered Bank is required to pay a US $300 million fine as part of a settlement with the NY State Department of Financial Services (DFS) over its alleged failure to fix anti-money laundering problems as required by a 2012 settlement between the bank and the DFS. As part of its 2012 settlement, the bank was required to retain an on-site independent monitor for 24 months to review its AML operations, including its transaction monitoring system. The monitor subsequently observed that the system failed to detect a number of “high-risk transactions” emanating from the bank’s branches in the United Arab Emirates and a subsidiary in Hong Kong, among other places. According to the DFS, this was “because of a lack of adequate testing and analysis both pre- and post-implementation of the transaction monitoring system and fail[ure] to adequately audit the transaction monitoring system.” As part of its current settlement with the DFS, the bank again agreed to upgrade its transaction monitoring system and temporarily to suspend US-dollar clearing services for certain clients from the UAE and Hong Kong, among other sanctions.