ABN AMRO Bank, N.V. OFAC Enforcement: $40M (2006)

Between December 2001 and April 2004, ABN AMRO's overseas branches removed or revised references to entities in which the Governments of Libya and Iran had an interest before forwarding wire transfers, letters of credit, and U.S. dollar checks to ABN AMRO branches in New York, NY and Chicago, IL.

OFAC and the Board of Governors of the Federal Reserve System jointly assessed the $40,000,000 penalty. ABN AMRO voluntarily disclosed the violations to OFAC and has paid the fine. ABN AMRO also agreed to continue implementation of improvements to its global compliance and risk management systems to ensure adequate oversight, effective risk management, and full compliance with OFAC regulations. The $40,000,000 payment also satisfies a $30,000,000 penalty concurrently assessed by FinCEN.

FinCEN concurrently assessed a separate penalty of $30,000,000 against ABN AMRO. That penalty is satisfied by ABN AMRO's $40,000,000 payment to OFAC and the Federal Reserve Board.

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