Standard Chartered plc is an international banking group headquartered in London, United Kingdom. The US Department of Justice has described Standard Chartered Bank as a global financial institution headquartered in London.
Although British-based, much of Standard Chartered's historic franchise has been concentrated in Asia, Africa and the Middle East, making it an especially relevant institutional comparison with BCCI.
Background
Standard Chartered faced extensive US investigations into the processing of transactions tied to Iranian interests and other sanctioned jurisdictions. This went well beyond regulatory criticism - criminal charges were formally filed.
Round one
In 2012, Standard Chartered entered a Deferred Prosecution Agreement with the US Department of Justice over sanctions-related conduct from 2001-2007, agreeing to forfeit US$227 million.
Round two
Further misconduct led to a new two-count felony criminal information in April 2019 - one count tied to the original 2001 - 2007 conspiracy, the second covering fresh criminal conduct from 2007 through 2011. For that later period, Standard Chartered admitted processing approximately 9,500 US-dollar transactions worth roughly US$240 million on behalf of Iranian individuals and entities.
Still operating
Despite criminal charges filed twice, over two separate periods spanning a full decade, and substantial forfeitures each time, Standard Chartered continued operating as a major international bank throughout.
The comparison with BCCI
Standard Chartered wasn't just found to have a compliance gap once - US prosecutors filed criminal charges against it on two separate occasions, a decade apart, covering ten years of sanctions violations. Each time, the response was forfeiture, deferred prosecution, and continued operation under stronger controls. If a bank could face criminal charges twice over a decade of sanctions violations and still be trusted to reform and continue, why was BCCI's restructuring - backed by an engaged, funded shareholder - never given the same chance to demonstrate it could isolate its own problems and continue?
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