On March 12, Commerzbank AG, a global financial institution, and its U.S. branch entered into a DPA for violations of the International Emergency Economic Powers Act and the Bank Secrecy Act and agreed to forfeit $563 million and pay a $79 million fine.  The bank moved $263 million through the U.S. financial system on behalf of Iranian and Sudanese businesses. It used non transparent payment messages, amended payments to avoid U.S. sanctions filters, and employed other tactics to conceal the involvement of sanctioned entities.  Additionally, the bank failed to maintain an adequate compliance program, and as a result, the bank was used by Olympus, a Japan-based manufacturer, to obtain loans for off-balance sheet entities to perpetuate an accounting fraud.  Olympus asked the bank to falsify documents provided to Olympus’s auditors in order to avoid disclosing certain pledged assets.  Although the Bank refused, it suggested other ways that Olympus could avoid disclosing the pledge, and Olympus later conducted suspicious business at the bank, which the bank did timely investigate or report.  DOJ Press Release