Intensa Sanpaolo S.p.A.

Intensa had conducted business with an Italian firm, Irasco, that was found to be Iranian owned. The fine was particularly harsh because Intesa was found to have failed to maintain a sufficiently robust compliance program over the time the apparent violations took place.

ING Bank NV

Conspired to violate U.S. sanctions on Iran and Cuba by processing several thousand wire transfers, travelers' checks, and trade finance transactions involving Iran, Sudan, Cuba, Burma and Libya.

Industrial Scientific Corp.

On or about June 2, 1998, ISC transferred the goods referred to in Charge 1 from the United States to the United Arab Emirates with knowledge that a violation of the Regulations would occur - that the goods which were subject to both the Regulations and the Iranian Transactions Regulations would be transferred to Iran.