The Federal Reserve responded by escalating our enforcement action to a cease and desist order and imposing a substantial penalty on ABN AMRO.3 The Federal Reserve’s order required ABN AMRO to implement a global compliance program and take specific steps to prevent circumvention of the required U.S.  2  Board of Governors of the Federal Reserve System (2004), “Written agreement with ABN AMRO Bank,” press release, July 26.
3  Board of Governors of the Federal Reserve System (2005), “Agencies release bank supervisory and penalty actions against ABN AMRO Bank, N.V.,” press release, December 19. 4  BIS central bankers’ speeches  sanctions filters. We coordinated this action with other U.S. and foreign regulators, including the home country supervisor for ABN AMRO.