DoJ's investigation into ING Bank arose out of an earlier export control investigation. As part of an ongoing investigation into the export of US-origin goods to Iran, the Department of Commerce initiated a criminal investigation involving a Dutch aviation company, Aviation Services International B.V. (ASI), for exporting US-origin items, including aircraft parts, to Iran via the Netherlands and other countries. The US Department of Commerce and the US Department of Treasury ultimately entered into a joint settlement agreement with ASI. According to DoJ's factual statement, ING Bank processed payments on behalf of ASI through the United States. The DoJ press release suggests that its investigation of ING Bank began when it became aware of ING Bank's involvement in the illegal export scheme.