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On June 12, 2012, the U. S. Department of the Treasury ’ s Office of Foreign Assets Control announced a $ 619 million settlement with ING Bank N. V. to settle potential liability for conspiring to violate the International Emergency Economic Powers Act ( IEEPA ) and the Trading with the Enemy Act ( TWEA ) and for violating New York state laws by illegally moving billions of dollars through the U. S. financial system on behalf of sanctioned Cuban and Iranian entities .. ING Bank ’ s settlement with OFAC is simultaneous with settlements with the U. S. Attorney's Office for the District of Columbia, the Department of Justice's National Security Division, the Department of Justice's Asset Forfeiture and Money Laundering Section and the New York County District Attorney ’ s Office.