On November 4, 2015, Deutsche Bank agreed to pay US $258 million to the New York Department of Financial Services (NYDFS) and will install an independent monitor to settle alleged violations of New York Banking laws. The alleged violations stem from transactions conducted by employees of Deutsche Bank on behalf of countries and entities subject to U.S. sanctions. Enforcement officials claimed that between 1999 and 2006, employees at the bank engaged in banking practices that facilitated U.S. dollar clearing transactions for bank customers who were from sanctioned countries or listed on the Specially Designated Nationals (SDN) list maintained by OFAC. As part of the settlement, Deutsche Bank agreed to work with an independent monitor to conduct a comprehensive review of its sanctions compliance program and institute corrective measures in its U.S. dollar clearing business. It also agreed to take steps to terminate employees deemed by the agency to have played central roles in facilitating the transactions at issue.