The most aggressive enforcer of federal sanctions law may now be New York State, which on Thursday fined Bank of Tokyo Mitsubishi UFJ $250 million. The settlement allows the Japanese bank to put sanctions allegations behind it, but for other banks and regulators, the trouble may just be starting.

The state's deal with the company effectively trumps a much smaller 2012 settlement the bank cut with the Office of Foreign Assets Control, a Treasury Department wing that exists to enforce "sanctions based on US foreign policy and national security goals," according to its website.

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