On December 22, 2009, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the settlement of apparent violations by Lloyds TSB Bank of OFAC regulations relating to Iran, Sudan and Libya. As reported here, Credit Suisse recently announced it had reached a $536 million settlement with regulators relating to violations of sanctions, including OFAC’s Iranian sanctions program. OFAC noted that Lloyds had fully cooperated with OFAC and promptly provided results of internal investigations. The settlement requires annual compliance reviews and reporting to OFAC for the next two years.

Lloyds agreed to pay a $215 million fine which was deemed satisfied by its earlier payment of a $350 million fine to the U.S. Department of Justice and the New York Count District Attorney’s Office relating to the same matters.

The Lloyds TSB Bank and Credit Suisse settlements evidence the current focus of U.S. regulators and prosecutors on compliance by global financial services firms with U.S. trade sanctions.