So your boss thinks worrying about the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) program is a waste of time? Well, here is the biggest wake-up call you could ask for.

Yesterday, the U.S. Treasury announced that ING Bank is to pay a record $619 million for intentionally manipulating information about U.S. sanctioned parties - including North Korea, Sudan, Burma, Cuba, Iran and Syria - all in violation of OFAC.

"For more than a decade, ING Bank helped provide state sponsors of terror and other sanctioned entities with access to the U.S. financial system, allowing them to move billions of dollars through U.S. banks for illicit purchases and other activities," said Assistant Attorney General Lisa Monaco. Here is the link to the settlement for more on what business activities landed ING Bank in hot water.

Obviously the record fine is in part because of the sheer scale and scope of the OFAC violations, and we would hope that your organization would not be so aggressively dismissive of the law in terms of doing business with state sponsors of terrorism such as those that ING willingly worked with. However, the point here is that if your organization does not have firm policies and procedures in place regarding avoiding such business transactions (including with thousands of individuals and entities currently identified by OFAC as one's you should not be doing business with), or has not fully trained all your personnel, particularly in AP; then things can get real expensive real fast.

Please note that the Non-Resident Alien Reporting Supplement to the 2012 Form 1099 Compliance Guide that we released yesterday has several articles and tools to help your AP department make sure its OFAC related controls are in place. These tools include our simple 5 step process to determine if you have a valid OFAC match and guidance on how to comply with OFAC, what to do if you have accidentally done business with an individual, entity, or state on the OFAC list, and more.