The Treasury Department's Office of Foreign Assets Control (OFAC) set a record June 12 with its $619 million settlement with ING Bank N.V. related to violations of U.S. sanctions against countries including Cuba and Iran. Other recent high-profile OFAC settlements include a
$536 million settlement with Credit Suisse AG, a $217 million settlement with Lloyds TSB, a
$176 million settlement with Barclays and an $88 million settlement with JPMorgan Chase, all related to violations of U.S. sanctions.

OFAC Director Adam Szubin said in a statement announcing the June 12 ING settlement, “Today's historic settlement should serve as a clear warning to anyone who would consider profiting by evading U.S. sanctions.”

By now, however, large financial institutions seem to have gotten the message and are suitably scared.