Standard Chartered PLC Strongly Rejects the Position by NYDFS

Standard Chartered PLC (the "Group") "strongly rejects" the accusations set out in an order issued by the New York Department of Financial Services (NYDFS) on August 6. The order accused the Group of concealing, over a period spanning nearly a decade, at least $250 billion worth of illicit transactions routed through the Group's New York Branch on behalf of Iranian clients. The Group argues that, contrary to the impression given by the order, it had voluntarily approached all relevant U.S. agencies in early 2010 to inform them of its review of historical U.S. dollar transactions for compliance with U.S. sanctions. In particular, this review focused on transactions relating to Iran in the period 2001-2007, and whether these transactions complied with the "U-turn" framework established by U.S. authorities.

The Group asserts that the results of this analysis had been previously shared with U.S. agencies, and had demonstrated that "well over 99.9% of the transactions relating to Iran complied with U-turn regulations." The Group believes the interpretation reflected in the NYDFS order to be "incorrect as a matter of law," and states additionally that Standard Chartered ceased all new business with Iranian customers over five years ago.

(The Order was set out in yesterday's news.)

Cross-Reference(s): U-turn exemption

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