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A penalty issued against an American lender this month and a bevy of designations that followed may indicate a new willingness among U.S. sanctions officials to impart "know your customer's customer" expectations on American and foreign banks alike. But that depends on whom you ask. On Oct. 5, the Treasury Department's Office of Foreign Assets Control levied a $5.3 million fine against JPMorgan Chase & Co. for settling nearly 100 payments through an omnibus-like account for clients tied to Iran, Cuba and U.S.-blacklisted proliferators of weapons of mass destruction. OFAC blacklisted a network of more than 20 businesses 11 days...