Our Global Regulatory Enforcement colleagues, Michael J. Lowell and Michael A. Grant, recently wrote about the announcement made by the U.S. Office of Foreign Assets Control (“OFAC”) and Bureau of Industry & Security (“BIS”), regarding a settlement with ING Bank N.V. (“ING”), relating to potential liability under various U.S. sanctions against Burma (Myanmar), Cuba, Iran, Libya, and Sudan. The apparent violations date back to conduct that begin in 1994 and concern an allegedly willful plan by ING to covertly process fund transfers that benefited U.S. sanctioned countries through the U.S. financial system. To read the entire posting, please visit our Global Regulatory Enforcement Law Blog.