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The United States Attorney’s Office for the District of Columbia and the Money Laundering and Asset Recovery Section of the Criminal Division of the United States Department of Justice (collectively, the “United States” or the “Government”), hereby provide notice that the Government, with the consent of Standard Chartered Bank (“SCB”), is amending the Deferred Prosecution Agreement entered into with SCB on December 10, 2012 (the “2012 DPA”), and amended on December 8, 2014, November 9, 2017, July 27, 2018, December 21, 2018, and March 31, 2019. The amended DPA is attached hereto as Exhibit A (the “Amended DPA”).
On December 10, 2012, the United States filed a criminal Information charging SCB with knowingly and willfully conspiring, in violation of Title 18, United States Code, Section 371, to engage in transactions with entities associated with sanctioned countries, including Iran, Sudan, Libya, and Burma, in violation of the International Emergency Economic Powers Act, Title 50, United States Code, Section 1705, and regulations issued thereunder (“IEEPA”). [Dkt. Entry No. 1]
On the same date, the United States and SCB entered into the 2012 DPA with a term of two years. [Dkt. Entry No. 2] The 2012 DPA required, among other things, that SCB acknowledge responsibility for its conduct, which included processing financial transactions by wire into and through the United States and U.S. financial institutions on behalf of Iranian banks and other countries subject to U.S. sanctions. [Id. at Ex. A] (hereinafter, the “2012 Factual Statement”). In the 2012 DPA, SCB represented that it had stopped doing new business involving Iran in 2007. The purpose of the 2012 DPA was to allow SCB to demonstrate its future good conduct and implement remedial measures, including the enhancement and optimization of its sanctions compliance programs. Under the 2012 DPA, SCB also agreed to forfeit $227 million.