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The SEC global settlement had the same problem.
The cumulative penalties were negotiated as part of a global settlement with US, Brazilian and Swiss authorities.
A global settlement against Standard Chartered, expected as early as the end of the month, will be the latest in a spate of sanctions violations cases.
Another approach might be for BP to offer a "global settlement" of all claims arising from the Gulf Oil gusher.
A further £138m will be paid to the UK's Financial Conduct Authority as part of the global settlement.
HTC and Apple have reached a global settlement that includes the dismissal of all current lawsuits and a ten-year license agreement.
For BP to hammer out a global settlement, it must win over the Gulf Coast states.
"We've looked at many scenarios, including where one or more countries decides to redenominate," said Roger Griffith, who oversees global settlement and customer risk for MasterCard.
Some analysts said that Merck would eventually have to reach a global settlement.
(J.P. Morgan paid thirteen billion, but that was a global settlement covering claims from a number of government entities).
"There was never a global settlement that all parties agreed to," Mr. Watson said.
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