The Banksters

0x3…6f4

ERC721

ABN AMRO lacked adequate risk management and legal review policies and procedures to ensure compliance with applicable U.S. law, and failed to adhere to those policies and procedures that it did have. As a result, one of ABN AMRO’s overseas branches was able to develop and implement “special procedures” for certain funds transfers, check clearing operations, and letter of credit transactions that were designed and used to circumvent the compliance systems established by the Branches to ensure compliance with the laws of the U.S. B. ABN AMRO lacked effective systems of governance, audit, and internal control to oversee the activities of the Branches with respect to legal, compliance, and reputational risk, and failed to adhere to those systems that it did have, especially those relating to anti-money laundering policies and procedures, including the procedures to implement the Currency and Foreign Transactions Reporting Act, 31 U.S.C. § 5311 et seq. (the Bank Secrecy Act (the “BSA”)); the rules and regulations issued thereunder by the U.S. Department of the Treasury (31 C.F.R. Part 103); and the suspicious activity reporting requirements of Regulation K of the Board (12 C.F.R. § 211.24(f)). As a result, ABN AMRO and the Branches (1) failed to adequately document, report, and follow up on negative findings from certain internal audits; (2) failed to produce negative audit findings in a timely manner to the U.S. Supervisors, and to appropriate internal governing bodies; (3) failed to follow-up on inquiries referred to the New York Branch from overseas offices regarding compliance with U.S. law; (4) overstated to internal auditors, compliance personnel, and the U.S. Supervisors the extent of due diligence efforts undertaken by certain branches outside the United States with respect to high risk correspondent banking customers; and (5) failed to escalate the “special procedures” for review outside of the trade processing business or reporting line; C. Following the action of an overseas ABN AMRO branch that removed or revised the identification of the relevant parties, the Branches engaged in transactions or dealings in or related to services of Iranian origin or for exportation, directly or indirectly, to Iran and the facilitation of exportation of services to Iran, in violation of sections 560.206 and 560.208 of the ITR, and also violated section 560.203 of the ITR, which prohibits transactions that evade or Prior to August 1, 2004, the New York Branch processed wire transfers originated by Bank Melli Iran, a financial institution owned or controlled by the Government of Iran. The payment instructions on the wire transfers had been modified by one of ABN AMRO’s overseas branches such that any reference to Bank Melli Iran was removed. Prior to August 1, 2004, the Branches advised a number of letters of credit issued by Bank Melli Iran. The letters of credit had been reissued by one of ABN AMRO’s overseas branches such that any reference to Bank Melli Iran was removed; and D. Following the action of an overseas ABN AMRO branch that removed or revised the identification of the relevant parties, the Branches engaged in transactions in which the Government of Libya had an interest, in violation of section 550.209 of the LSR, and transactions that had the purpose or effect of evading or avoiding the LSR, in violation of section 550.208 of the LSR. These violations justify an OFAC civil penalty. Specifically: i. Prior to August 1, 2004, the Branches of ABN AMRO advised letters of credit for Arab Bank for Investment and Foreign Trade (“ARBIFT”), a U.A.E. chartered bank, which was an entity determined by the Secretary of the Treasury to be the Government of Libya. The letters of credit had been reissued by one of ABN AMRO’s overseas branches, which obscured the ARBIFT origin of the letters; 5 ii. Prior to August 1, 2004, the Chicago Branch of ABN AMRO cleared U.S. dollar checks for ARBIFT. The cleared checks were submitted by one of ABN AMRO’s overseas branches, which had arranged for ARBIFT to not endorse or stamp the check

Name

1155

Owner

0xD52fbA65a52214A65C78Dc7f95c9FeE1F13a5955

ID#1155

Rarity

HI:24%