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The United States informs the Court that:
At all times material to this Information:
- Defendant Standard Chartered Bank (“SCB”) was a financial institution registered and organized under the laws of England and Wales with its headquarters in London, England (“SCB London”).
- Defendant SCB was subject to oversight and regulation in the United States by the Board of Governors of the Federal Reserve System, as well as the New York State Department of Financial Services.
- Defendant SCB conducted U.S. dollar (“USD”) clearing at SCB’s New York branch (“SCB New York”).
- Defendant SCB had branches throughout the world and conducted financial transactions in USD at and through SCB New York and unaffiliated U.S. financial institutions in New York and elsewhere.
- Person A worked at SCB’s branch office in Dubai (“SCB Dubai”) as a Relationship Manager from 2007 through 2014. As a relationship manager, Person A was the main point of contact between the bank and numerous small and medium enterprise (“SME”) companies that were in his or her portfolio. Person A interacted with his or her customers frequently: answering questions, conducting research, and representing the customer’s interests to other SCB components (e.g., the foreign exchange desk).