Sanctions Evasion Reference

ING: 20,452 Cuba transactions, run from the branches

ING Bank paid OFAC $619 million in 2012 over mostly Cuban dollar transactions. Treasury said senior managers told staff in Curaçao to omit Cuba from payment messages, and a French office authorised false endorsement stamps.

period

2002–2007

outcome

Settlement

parties

ING Bank N.V.

programmes

Cuba, Islamic Republic of Iran, Sudan, Myanmar (Burma), Libya

reviewed

2026-10-04

Cite this page
APA 7
Sanctions Evasion Reference. (2026, October 4). ING: 20,452 Cuba transactions, run from the branches. https://sanctionsevasion.org/cases/ing-bank-2012/
Chicago
Sanctions Evasion Reference. “ING: 20,452 Cuba transactions, run from the branches.” Last reviewed October 4, 2026. https://sanctionsevasion.org/cases/ing-bank-2012/.
BibTeX
@misc{ser-cases-ing-bank-2012,
  author = {{Sanctions Evasion Reference}},
  title  = {ING: 20,452 Cuba transactions, run from the branches},
  year   = {2026},
  note   = {Last reviewed 2026-10-04},
  url    = {https://sanctionsevasion.org/cases/ing-bank-2012/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2012-06-12 $619,000,000 Egregious; all but one matter voluntarily self-disclosed. Statutory maximum $1,329,268,888; total base penalty $665,992,444. Part of a global settlement; the obligation was deemed satisfied by a $619 million payment to the Department of Justice and the New York County District Attorney.

The largest bank settlement of its time, and the most Cuban one: nearly all of it is a single programme, which is not what the era’s reputation suggests.

What the notice counts

ING processed 20,452 wire transfers, trade-finance transactions and travellers’ cheques worth about $1.65 billion involving Cuba between October 2002 and July 2007. That set carried a base penalty of $636 million of the $666 million total. The rest was small by comparison:

  • Burma: 41 transactions, about $15.5 million.
  • Sudan: 44 transactions, about $2.0 million.
  • Libya: 3 transfers, about $27,000.
  • Iran: two trade-finance transactions worth about $1.36 million.

The conduct ran through ING’s commercial banking offices in the Netherlands, Belgium, France, Curaçao and Cuba, and not through its US insurance or banking operations. ING voluntarily self-disclosed everything except the Iran transaction handled by its Bucharest office.

How, according to Treasury

OFAC’s enforcement notice gives the numbers. Treasury’s press release the same day gives the methods. At the instruction of senior management, ING staff in Curaçao began in the 1990s omitting references to Cuba from payment messages sent to the United States, so US banks could not identify and stop prohibited transactions. Branches in France, Belgium and the Netherlands used the same practice for dollar payments and trade finance.

Two further stratagems are named. Senior management in France authorised, advised on the creation of, and ultimately supplied fraudulent endorsement stamps for Cuban banks to use in travellers’ cheque transactions, which disguised the Cuban banks’ involvement when the cheques were processed in the US. And the Dutch Trade and Commodity Finance business routed payments for sanctioned Cuban clients through other corporate clients to obscure their identity, while the Romanian branch left details out of a letter of credit involving a US bank that financed the export of US-origin goods to Iran. See correspondent banking abuse and front companies.

The penalty

Egregious: OFAC found the conduct marked by wilfulness and recklessness, with several employees, including senior management, aware of it, and significant harm to the programmes’ objectives. It also aggravated the penalty because ING did not consistently cooperate early with explicit requests for information. Mitigation came from the possibility that some transactions, those relating to agricultural or medical goods or large personal remittances, could have been licensed, from ING’s clean five-year record, from later cooperation including a tolling agreement with multiple extensions, and from its agreement to settle. OFAC referred the matter for criminal investigation “in light of the sheer number of apparent violations, the array of stratagems employed by ING Bank to conceal its actions, and the seriousness of the conduct.” The $619 million was deemed satisfied by the payment to the Justice Department and the New York County District Attorney, so it is not a separate bill.

What the record shows

  • Policy, not a rogue desk. The practice sat in the Wholesale Banking Division’s offices in four countries and was directed from the top, according to Treasury.
  • The money was Cuba. For a case remembered as a general “sanctions” settlement, 96 per cent of the base penalty is one programme. See the stripping-era note.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Cuba sanctions — The oldest US embargo still administered by OFAC: the Cuban Assets Control Regulations of 1963, layered with later statutes, that prohibit most transactions involving Cuba or its nationals unless licensed.
  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Sudan sanctions — A US embargo regime from 1997, revoked in 2017 and followed by targeted measures. Its main relevance here is historical: several of the largest penalties in OFAC's record concern conduct from the years it was in force.
  • Myanmar (Burma) sanctions — The current US programme, built on E.O. 14014 of 2021, blocks the military, the defence and jet fuel sectors, and anyone materially supporting them. OFAC still uses the name Burma.
  • Libya sanctions — A UN regime aimed at armed groups, illicit petroleum exports and the misuse of Libyan state institutions, with a parallel US programme. The Panel of Experts' reporting documents fuel smuggling in unusual detail.
  • Netherlands — A major European trading and logistics hub whose port and trading companies appear in enforcement records the way any high-volume gateway does, from a criminal prosecution to an investigation still at the arrest stage.

Enforcement documents and sources

  1. Enforcement action: ING Bank N.V.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2012. Penalty notice, 2012-06-12, US$619,000,000.
  2. U.S. Treasury Department Announces $619 Million Settlement with ING Bank, N.V.. U.S. Department of the Treasury, 2012. Press release, 12 June 2012.
  3. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All enforcement cases