On December 11, 2012, the Office of Foreign Assets Controls (OFAC) announced that HSBC Holdings, plc has agreed to remit $375 million to settle potential civil liability on behalf of the company and certain of its affiliates (collectively "HSBC Group") for violations of the Cuban Assets Control Regulations, the Burmese Sanctions Regulations, the Sudanese Sanctions Regulations, the now-repealed Libyan Sanctions Regulations, and the Iranian Transactions Regulations.
The settlement covers violations all of which OFAC has determined were egregious under its Economic Sanctions Enforcement Guidelines. Specifically, on numerous occasions between 2004 and 2010, HSBC Group processed wire transfers totaling millions of dollars that involved Cuba, the Governments of Libya and Iran, and other sanctioned countries and entities.
HSBC Group did not voluntarily self-disclose the violations. The total base penalty amount for these violations, which was the statutory maximum in this case, totaled $1,159,872,734.