According to the Bureau of Industry and Security (BIS), ING Bank N.V. has agreed to forfeit $619 million to the Justice Department and the New York County District Attorney’s Office for illegally moving billions of dollars through the US financial system on behalf of Cuban and Iranian sanctioned entities. ING Bank is held responsible for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), as well as violating New York state laws by illegally moving over $2 billion dollars through the US financial systems via more than 20,000 transactions between the early 1990s and 2007. This fine is the largest ever against a bank in connection with an investigation into US sanctions violations.


ING Bank executed this scheme through tactics including:

  • eliminating payment data that would have revealed the involvement of sanctioned countries and entities
  • advising sanctioned clients on how to conceal their involvement in U.S. dollar transactions
  • threatening to punish certain employees if they failed to take specified steps to remove references to sanctioned entities in payment messages

Most upsetting is that these illegal activities occurred with the knowledge and encouragement of members of both the legal and compliance departments.


The bank has also entered a parallel settlement agreement with the Office of Foreign Assets Control (OFAC). As part of the agreement, ING will be required to conduct a full review of its policies and procedures to ensure that its compliance program is functioning effectively.


To read the entire Bureau of Industry and Security (BIS) press release, click here.


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