Her Biggest Scandal Yet! Iran and China Are Circumventing Sanctions via Notorious Bank and Letitia James Is Implicated

The Standard Chartered Bank sanctions evasion case, now in court in the US Second Circuit, found at least $9.6 billion of illegal payments by the bank to Iranian and Hezbollah entities.

The case implicates NYAG Letitia James and the Federal Reserve for ignoring billions of these illicit payments and ignoring Treasury sanctions designations. Maximum Pressure is not being enforced because of the failures of the Fed and the NYAG.

Make sure this case continues.

** Call the Southern District of New York …. Office number: 212-637-2200

At least $9.6 billion of specifically identified illicit payments were made by SCB from its NYC branch to OFAC and known terrorist names. The $9.6 billion was found in internal trade reports turned over by bank whistleblowers and represents the first batch from SCB Dubai office that cleared through SCB NYC. There are estimated over $100 billion more of illegal payments that are more recent and from SCB China where it has 53 mainland branches that facilitate dollar trade payments for oil and war-making materials.

These payments were hidden by SCB from required disclosure in its ongoing Deferred Prosecution Agreement now under the jurisdiction of DCUSA Pirro and SDNY Clayton where both were briefed on SCB after their appointments. There are career blockers at each jurisdiction.

Letitia James screenshot – NYC protest

Involvement by the NYAG

In early 2024, NYAG was briefed by terrorist financing experts and the whistleblowers in detail on the illicit payments yet did nothing about it other than reapprove SCB annual license. DOJ Special Counsel Ed Martin sent Letitia James a letter of inquiry in late May 2025 with a deadline for her to respond by June 5, 2025. She failed to respond.

NYAG was briefed in two meetings in February and March 2024 about the $9,6 billion of illegal payments and did nothing but approve the annual renewal of SCB State banking license. One of meetings was recorded and clearly shows that NYAG officials recognized the payments were not previously known and not in prior SCB sanctions settlements. Five NYAG senior staff including Letitia James Deputy Scott Spiegleman were in all meetings. In late 2024, Spiegleman went to work for IBM which has a large tech contract running the SWIFT platform.  IBM Promontory advised SCB to hide currency trade data.

Involvement by the Federal Reserve

The Fed, along with its wire operations platform SWIFT, failed to block the SCB payments to sanctioned names – ignoring the Treasury OFAC and SDGT lists. The COO of SWIFT, Cheri McGuire had been at SCB where she was directly involved in SCB hiding its currency trades.  Cheri McGuire was approved by the Fed and is now COO of SWIFT – designated under Dodd-Frank as a Systematically Important Financial Market Utility quasi-regulated by the Fed. The Eastern District of Virginia USA is also considering investigation because SWIFT its US headquarters in VA.

With all oil trade required to be in $USD, China is using Standard Chartered Bank (“SCB”) and it’s NYC branch to buy Iranian oil in $USD. Maximum Pressure is being thwarted by a lack of enforcement by the Fed and the SWIFT system – each have ignored the Treasury sanction designations.

Recommendations:

Direct USA Pirro to prosecute SCB for breach of its Deferred Prosecution Agreement; Direct SDNY Clayton to intervene and prosecute SCB in the case now in the US Second Circuit.
Retract delegated authority from the Fed returning it to Treasury to enforce Maximum Pressure. End any operating agreement the Fed has with Brussels-based Society for Worldwide International Financial Transactions and merge its operations into Treasury.
Collect more than $10 billion from SCB for the US in sanction evasion penalties.

The Fed is undermined and ignoring Treasury. Treasury too is being ignored by State regulators like those in New York where the NYAG ignored and was busy doing lawfare.

Next Steps:

Background

The SCB evasion case is a rare situation where inside whistleblowers turned over 40,000 emails that contained the currency trade records for several years.  SCB attempted to hide 100% of their currency trades. The internal whistleblowers were fired and filed suit in a case now on appeal in the US Second Circuit. Obama and Biden career DOJ officials (John-David Barnea in SDNY, Gregg Maisell in DCUSA, and Matthew Komar FBI) have been blocking action on this case since 2024 because it was likely that news of $9.6 billion in specific evasion payments made by a NYC bank branch to known sanctioned terrorist and Iran linked entities would be embarrassing to a Biden campaign. Enforcing the sanctions laws on the currently known sanctions evasion payments in this case will yield the US more than $10 billion in settlements, while full investigation of the SCB China oil trade payments is likely to be a much higher amount of proceeds to the US.  The exact same evidence of $9.6 billion of SCB illicit payments is the subject of a UK Royals Court investor suit that is going to trial.

Here is more on the allegations brought forth by credible former Standard Charter Bank whistleblowers.

Standard Chartered Bank USA Iran Sanctions Evasion Case

(United States ex rel Brutus Trading vs. Standard Chartered Bank) active 2nd Circuit

 

Allegations by two former SCB whistleblowers:

Standard Chartered Bank “(SCB”) concealed more than $9,6 billion of illicit payments to 92 OFAC / SDGT entities that were not previously disclosed nor part of prior sanctions settlements with the US.
SCB knowingly and frequently violated its obligations to self-report SARS to Treasury FinCen and excluded 100% of its F/X trades in breach of its Deferred Prosecution Agreements of 2015, and 2019.
Whistleblowers in late 2023 realized they were in possession of all the SCB’s internal trade reports over a 6-year period that formed the basis of SCB’s prior sanctions evasion settlements and DPAs.
After 3 meetings (one recorded) with SDNY USA Damian Williams and NY AG Letitia James senior staff in 2024 where the new sanctions evasions evidence was presented, Brutus alleges a coverup began.
FBI agent Matthew Komar, Treasury’s Alexander Manfull, and SDNY’s Jean-David Barnea made false statements to the Court claiming the SCB’s currency trades had been included even though the $9.6 billion to the 92 SDGT entities were not previously listed in the DPA’s nor part of prior settlements.
Based on these shocking findings and the change in DOJ’s case posture in 2024, Brutus moved to re-open its case against SCB. Biden DOJ denied the existence of any of the currency trades that had been in the 75 excel files given to the Government by Brutus as evaluated by Declarant David Scantling, a terrorism financing expert and former Assistant Secretary of Defense for Counter Terrorism who evaluated a subset of 551,000 trades to find the 92 entities on the OFAC / SDGT list.
New OFAC / SDGT entities uncovered include Euro African Group Ltd, majority owned by Mohommed Bazzi, the lead global Hizballah financing agent, Koussani Steel, Kuwait Automotive Group, Bank d’Algeria, Iranian oil trading cutouts and know SDGT proxies, and Bank of Gambia.

Policy Implications:

The Biden Administration and NYAG adopted a posture to ignore the $9.6 billion of illegal payments.

SCB has chosen a major ongoing role in lucrative illicit payments while purposely concealing those payments.

Policy Goal is to align Maximum Pressure with Robust Sanctions Enforcement to deter illicit payments

Exhibit K containing certain evidence is under seal by Judge Paul Englemeyer

Drop Box data room at www.IranMoneyTrail.com

Media Coverage is ongoing and UK FCA (Non-Reliance) case is open and heading to trial.

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