Standard Chartered Bank (SCB), a global financial institution based in London, England, has agreed to revoke US$240 million, a $480 million fine and amend and extend its deferred Prosecution Agreement (DPA) with the Department of Justice for conspiracy to violate the International Emergency Economic Powers Act (IEEPA) by two years. This criminal conspiracy, which continued from 2007 to 2011, led SCB to process some 9500 financial transactions worth about $240 million through U.S. financial institutions for the benefit of Iranian companies. SCB refers to the behavior described above and in transaction agreements as “legacy behavior” and points out that “the vast majority [of the behavior] before 2012 and none. after 2014. He also highlights his positive steps for improvement and notes that since 2012, he has invested heavily in his financial crime compliance operations, revised his senior management and governance, implemented mandatory LSA training and implemented “strict due diligence requirements for existing and new clients”. The agreement recognizes that the Panel has taken a number of steps and has made significant progress in meeting the requirements of the DPA and in improving its sanctions compliance program, but that the program has not yet met the standards required by the DPA. The FCA also described the UAE branches of the SCB as an epicenter, or at least an epicenter, or at least emblematic of the bank`s supposedly systemic problems, namely the lack of “risk-sensitive guidelines and procedures.” (and) to ensure that its UAE agencies have used equivalent controls to combat the financing of terrorism.” The ACF highlighted some of the most monstrous examples of these failures that occurred between 2009 and 2014, such as “opening an account of 3 million dirhams in cash in a suitcase [about £500,000 or $652,000] with little evidence that the origin of the funds has been studied. The ACF fined SCB more than £102 million – a fine that itself reflected a “30% discount” following SCB`s agreement not to challenge the ACF`s findings and is the second largest fine for AML control defects ever imposed by the Agency. . . .