ING Bank has agreed to pay $619 million to settle potential liability for apparent violations of U.S. sanctions against certain foreign countries, according to a statement released by the U.S. Treasury.
The settlement resolves an investigation by the Treasury's Office of Foreign Assets Control, or OFAC, into the bank's "intentional manipulation and deletion of information about U.S.-sanctioned parties in more than 20,000 financial and trade transactions routed through third-party banks located in the United States between 2002 and 2007," the statement said. These transactions routed more than $1.6 billion through the U.S.
The settlement is the largest OFAC settlement of any kind to date.
The bank's insurance and U.S. banking operations were not part of the investigation, the Treasury said.
The Treasury summarized the OFAC charges as follows.
- Bank employees in Curacao began omitting references to Cuba in payment messages sent to the U.S., beginning in the 1990s and at the instruction of senior bank management, to prevent U.S. financial institutions from identifying and interdicting prohibited transactions. This practice was also used by other branches of the bank's wholesale banking division, including offices in France, Belgium and the Netherlands.
- The bank's senior management in France authorized and provided fraudulent endorsement stamps for use by Cuban financial institutions in processing travelers check transactions, which disguised the involvement of Cuban banks when these transactions were processed through the U.S.
- The bank's trade and commodity finance business at its wholesale banking branch in the Netherlands routed payments made on behalf of U.S.-sanctioned Cuban clients through other corporate clients to obscure the sanctioned clients' identities.
- A branch in Romania omitted details from a letter of credit involving a U.S. financial institution to finance the exportation of U.S.-origin goods to Iran.
ING Bank, N.V., has assured OFAC that this conduct has been terminated. Under the settlement agreement, the bank is required to conduct a review of its policies and procedures and their implementation and submit a report to OFAC.
OFAC Director Adam Szubin said in the statement that U.S. sanctions laws reflect national security and foreign policy interests and are "aggressively" policed by the agency.
"Today's historic settlement should serve as a clear warning to anyone who would consider profiting by evading U.S. sanctions," Szubin said.
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