U.S. Government's $619 Million Settlement With ING Bank and Increased Sanctions on Iran Present New Challenges for Non-U.S. Banks
ING Bank N.V., a Dutch financial institution, has agreed to pay $619 million in a settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC), the Department of Justice (DOJ) and the Manhattan District Attorney. The settlement is the result of OFAC’s investigation into an alleged ING Bank conspiracy to violate state and federal laws by illegally moving billions of dollars through the U.S. financial system on behalf of persons and entities subject to U.S. sanctions. The enforcement actions against ING come against a backdrop of increasing enforcement and aggressive new extraterritorial measures aimed at third-country banks that deal with U.S. sanctions targets.
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