ING N.V. has reached a settlement agreement with the Treasury Department, Justice Department, U.S. Attorney’s Office for the District of Columbia and New York County District Attorney’s Office to forfeit $619 million for conspiring to violate the International Emergency Economic Powers Act and the Trading with the Enemy Act and for violating various New York state laws. This is the largest fine ever imposed on a bank in connection with U.S. sanctions violations. Between 2002 and 2007, ING was alleged to have illegally transferred billions of dollars through the U.S. financial system on behalf of sanctioned Cuban, Iranian, Burmese, Sudanese and Libyan entities. It was further alleged that ING manipulated and deleted information about these entities in thousands of transactions routed through third-party banks in the United States. The OFAC release is available at: sanctions/OFAC-Enforcement/Pages/20120612.aspx. The BIS release is available at: