While I was at ACAMS: 3-for-1 OFAC settlements with UniCredit Germany, Austria and Italy units

Settlement Agreements between the U.S. Department of the Treasury’s Office of Foreign Assets Control and UniCredit Group Banks

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced three separate settlements totaling $611 million with the following UniCredit Group banks: UniCredit Bank AG in Germany, UniCredit Bank Austria AG in Austria, and UniCredit S.p.A. in Italy.  The settlements resolve OFAC’s investigations into apparent violations of a number of U.S. sanctions programs, including those related to weapons of mass destruction proliferation, global terrorism, and the following countries: Burma, Cuba, Iran, Libya, Sudan, and Syria.

Between January 2007 and December 2011, UniCredit Bank AG processed over 2,000 payments totaling over $500 million through financial institutions in the United States in apparent violation of multiple U.S. sanctions programs.  During this time period, UniCredit operated U.S. dollar accounts on behalf of the Islamic Republic of Iran Shipping Lines (IRISL) and several companies owned by or otherwise affiliated with IRISL, and managed the accounts of those companies in a manner that obscured the interest or involvement of IRISL in transactions sent to or through U.S. intermediaries.  For a number of years up to and including 2011 (UniCredit Bank AG) and 2012 (UniCredit Bank Austria AG and UniCredit S.p.A.), all three banks processed payments to or through the United States in a manner that did not disclose underlying sanctioned persons or countries to U.S. financial institutions which were acting as financial intermediaries.

 

OFAC determined that the apparent violations largely constituted egregious cases and that the banks did not voluntarily self-disclose the apparent violations.

After Mr. Watchlist gets back from ACAMS, he will dig into the Enforcement Information and Settlement Agreements.

By the way, this is part of a multi-agency settlement totaling 1.3 billion dollars.

Links:

OFAC Notice

Enforcement Information

Settlement Agreements: UniCredit Bank AG (Germany), UniCredit Bank Austria AG, UniCredit S.p.A. (Italy)

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