Media commentators and bank analysts have suggested that the evil actors in this drama were the employees who did the “repairs and the managers who supervised them. Others have absolved Standard Chartered, accepting the bank’s argument that the scope of wrongdoing was minimal and had nothing to do with terrorism. But the New York regulators’ order centres on the bank’s general counsel and compliance offices. This focus on lawyers is important.
媒体评论员和银行分析师指出,在这出戏中扮演恶人的演员是那些执行“修正程序的员工以及管理他们的上级经理。其他人则认为渣打无罪,接受该行有关违规操作的范围极小以及绝不牵涉恐怖主义的说辞。但纽约州监管当局的报告将矛头对准了该行法律总顾问办公室以及合规办公室。这种对银行内部律师的关注引人回味。
Among the most incriminating documents cited in the order are memoranda and emails from the bank’s attorneys, who allegedly advised that wire instructions should not identify the names of Iranian clients because that would trigger scrutiny in New York. Legal and compliance officers were allegedly involved in a plan called Project Gazelle, which sought to build the bank’s business with Iranian clients without exposing the New York branch “to the risk of a breach of sanctions. Given these allegations, the opening line at next week’s hearing might be: “The first thing we do, let’s kill all the lawyers.
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2020-09-15
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