Zong also allegedly conspired with anonymous conspirators to circumvent U.S. sanctions laws, drawing up fictitious contracts, bills of lading, and invoices to convince Korean banking authorities and banks, including IBK, that Iranian companies owed Zong money for products that did not exist. As a result, according to NYDFS, IBK transferred funds from its restricted account to Zong`s IBK account in Korean won, and Zong paid the funds in U.S. dollars from February 2011 to July 2011 to individuals and organizations around the world for an amount of more than a billion dollars. Most of these transactions are made through New York financial institutions, including the New York branch and at least one other bank regulated by the department, the order of approval indicates. Accordingly, in February 2016, DFS and the Federal Reserve Bank of New York entered into a written agreement with IBK and IBKNY (the “Written Agreement”) requiring them to develop plans and programs in order to make various improvements to the subsidiary, including corporate governance and management oversight, the BSA/AML compliance program, tracking of suspicious activity and reporting. and OFAC compliance.  USAO and NYDFS appeared to point out that the New York branch was alerted to its flawed AML program, both through internal warnings and supervisory warnings, before incorrect transactions were detected. Following an investigation by the New York branch in 2010, the New York State Banking Supervisors drew the New York branch`s attention to their faulty transaction monitoring system, identified their program as immediately necessary, and ordered the New York branch to use the necessary resources to detect and report suspicious activity in a timely manner. And in 2016, the bank entered into a written agreement with NYDFS and the Federal Reserve Bank of New York to address persistent deficiencies in its compliance program.
However, according to NYDFS, the bank did not comply with the terms of the written agreement until its last review in 2019. In particular, IBKNY and IBK did not immediately identify a series of transactions that violated the economic sanctions imposed by the United States on Iran (the “Zong Transactions”): from January 2011 to July 2011, Kenneth Zong, a U.S. citizen, and various bank accounts, mostly Iranian, created with IBK and another bank, were used, to allow certain forms of trade between Korean companies and Iran (the “CBI Won Accounts”) to transfer U.S. .