SHOULD ING BANK LOSE ITS US LICENSE ?

I  am totally disgusted with the latest OFAC settlement; $619m fine levied against ING bank, clearly their biggest yet,  for the most egregious sanctions violations seen in a long time. Look at what the bank admitted to doing:

(1) Omitting references to Cuba in payment messages sent to US financial institutions.

(2) Creating and providing fraudulent bank endorsement stamps, for use by Cuban financial institutions.

(3) Use of corporate entities to obscure the identities of sanctioned clients.

Frankly, the fine is insufficient; why haven't any of those bloody bank officers who committed these violations been arrested ?

Finally, the only punishment that bankers will understand is the revocation of a US bank license; anything else is not a sufficient deterrent. Helping Iran to evade sanctions, and probably facilitate its WMD and ballistic missile programmes, through purchasing of equipment and supplies; helping all the sanctioned jurisdictions make purchases ?   Let the punishment fit the crime; take away something meaningful, Mr. Regulator, please. Not another financial slap on the wrist. That is the cost of doing business.

your public servants at OFAC 

Shut down their New York offices for five years.