Credit Suisse announced on December 15, 2009 that it is nearing a $536 million settlement with the New York County District Attorney's office and the US Department of Justice, Federal Reserve Board, Federal Reserve Bank of New York and the Office of Foreign Assets Control (OFAC). Click here for Credit Suisse's press release. Credit Suisse reported that among other actions it has closed its representative office in Tehran, Iran. According to press reports, Credit Suisse assisted Iranian organizations in transferring funds through US banks in violation of US sanctions.

This is the second large settlement with a foreign bank regarding violation of US sanctions this year. Lloyds TSB paid $350 million to settle claims by US federal and state regulators in January.

The US has much broader sanctions in place against Iran than the EU or the UN and compliance with these inconsistent sanctions regimes can be challenging to multi-national organizations. However, according to press reports, Credit Suisse personnel may have taken affirmative steps to facilitate evasion of OFAC regulations as to Iran. Click here for a link to OFAC's Iranian sanctions program.