Lloyds TSB reached a deferred prosecution agreement and agreed to forfeit $350 million after U.S. authorities alleged it helped process payments for sanctioned clients by removing identifying information from wire messages. The case highlighted how “stripping” information in payment instructions can defeat sanctions screening and became an early benchmark for large bank resolutions in this period.
Credit Suisse agreed to a $536 million global settlement with U.S. authorities over transactions involving sanctioned countries routed through the U.S. financial system. Authorities said the bank structured transactions to make sanctioned parties harder to detect, reinforcing the expectation that banks must preserve accurate payment and customer information for screening.
OFAC announced a separate $217 million settlement with Lloyds TSB for apparent violations involving deliberate deletion or manipulation of information in wire transfers. This entry showed how a single pattern of conduct could trigger coordinated criminal and civil outcomes across agencies, increasing the total financial and compliance impact.
Barclays entered a global resolution in which its OFAC settlement amount was $176 million, deemed satisfied by a $298 million payment to the U.S. Department of Justice and the New York County District Attorney’s Office. The case again focused on practices that obscured links to sanctioned parties, showing regulators’ continued emphasis on transparency in U.S. dollar clearing.
JPMorgan Chase agreed to pay $88.3 million to settle potential civil liability for apparent sanctions violations across multiple programs. The settlement signaled that large U.S. banks—not only foreign banks using New York dollar clearing—could face major penalties if controls failed or risks were mishandled.
ING Bank agreed to a $619 million settlement with OFAC, the largest OFAC settlement at the time, tied to transactions routed through U.S. banks involving sanctioned countries. Authorities said the bank manipulated payment information so U.S. banks would not detect prohibited activity, strengthening the compliance message that accurate data must be maintained end-to-end.
Standard Chartered reached a combined $327 million settlement with U.S. agencies and New York authorities, including an OFAC component of $132 million (treated as satisfied by other payments in the global deal). The settlement focused on allegedly stripping information from payment messages, reinforcing the principle that compliance failures in one office can create U.S. legal exposure when dollars clear through the United States.
HSBC agreed to a wide-ranging set of settlements totaling more than $1.9 billion for conduct involving Bank Secrecy Act/anti-money laundering failures and U.S. sanctions violations. The resolution paired monetary penalties with enhanced compliance obligations and a monitor, illustrating a shift toward enforcement that combined fines with longer-term oversight.
OFAC announced a $963 million settlement with BNP Paribas for apparent sanctions violations tied to thousands of transactions routed to or through U.S. banks. The announcement made clear that systematically concealing sanctioned-party information across large volumes of trade and payment activity would be treated as a major enforcement priority.
BNP Paribas agreed to a combined settlement of about $8.9 billion with U.S. federal and state authorities tied to sanctions violations involving countries such as Sudan, Cuba, and Iran. The scale of the penalty and the coordinated multi-agency structure made it a reference point for later bank sanctions cases and internal compliance investment decisions.
Commerzbank reached settlements totaling $1.452 billion with U.S. and New York authorities, covering sanctions-related issues and separate anti-money laundering program weaknesses. The case showed that sanctions enforcement often overlaps with broader controls (like customer due diligence and transaction monitoring), not just name-screening against lists.
Société Générale agreed to pay $1.34 billion in penalties to resolve investigations into U.S. dollar transactions that violated U.S. sanctions, including programs involving Cuba and other jurisdictions. U.S. authorities used the resolution to underline that long-running compliance weaknesses—and decisions to continue risky activity after warnings—can drive major penalties and multi-year remediation commitments.
Major Bank Fines and Settlements for Sanctions Violations (2008–2018)