Earlier this year, Standard Chartered Bank settled a deferred prosecution agreement in the US which includes $1 billion in financial enforcement plus a number of actions which the bank should take immediately.
The bank was negotiating to accept guilt over the violation of the sanctions regime while employees continued systematically finding more ways to offer sanctions clients with ways to avoid the impact of sanctions.
The investigation showed that the conduct was possible given the fact that compliance departments were not properly sourced.
As per recent studies and as highlighted in the link herein, the mindset of business and relationship managers has remained isolated from the regulatory change, making possible to criminals to conduct business with the willing cooperations of sales departments.
This point was noted by the FATF report in private banking according to which, the more complex risk to handle is the lack of a compliance culture as business model take longer to adapt to regulation.