Ofac`s Settlement Agreement With Ing Na

“Our sanctions legislation reflects the central interests of the United States in security and foreign policy, and OFAC is acting aggressively. Today`s historic agreement should serve as a clear warning to all those considering taking advantage of U.S. sanctions,” said Adam Szubin, OfAC`s Director of Treasury. “We congratulate our colleagues in the Confederation and the Federal States for their work on this important investigation.” WASHINGTON – ING Bank N.V., an Amsterdam-based financial institution agreed to contribute $619 million to the Department of Justice and the New York County Attorney`s Office for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) and violating New York State laws by illegally transporting billions of dollars through the U.S. financial system on behalf of sanctioned Iranian companies. The bank also entered into a parallel transaction agreement with the Ministry of Finance`s Office of Foreign Assets Control (OFAC). From 2008 to 2018, OFAC surveys led to comparisons with companies totalling more than $2,780,000,000. Yes, it`s $2.7 billion! This e-mail, which ING probably did not put in the best possible light with OFAC, should serve as a reminder that anything an employee of the company writes one day – even things allegedly covered by the privilege of the lawyer – can end up in the hands of a management body. ING Bank has agreed to settle potential liability for its overt violations of the $619 million cash rules with the obligation that is considered fulfilled by the payment of this amount to the U.S.

Department of Justice and the New York District Office for the same pattern of behavior. The costly liquidation of ING Bank was largely the result of stripping, the practice of withdrawing or replacing the information contained in payment or commercial financing instructions, in order to prevent the transaction from being associated with a sanctioned entity – a person or a capital company – or a country. The receipt of US$309.5 million by ING Bank in the United States and US$309.5 million from the New York County Attorney`s Office will settle claims by the Department of Justice and the State of New York. In light of the Bank`s corrective measures to date and its willingness to acknowledge responsibility for its actions, the Department will recommend that the information be withheld in 18 months, provided that ING Bank cooperates fully with and complies with the terms of the deferred prosecution agreement. “One of the best investments we`ve ever made. It helps us avoid dealing with unauthorized persons and avoid the terrible consequences of a violation of OFAC. ING`s problems apparently began when the bank was seized a letter of credit from the Iranian bank Tejerat on behalf of Iran Air regarding the purchase of an American-made VOLANT engine.

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