Treasury Department’s OFAC – UniCredit Bank Settlements

Earlier this month, OFAC announced 3 settlements totaling $611M with 3 UniCredit Group Banks located in Germany, Austria and Italy.  This was a part of a $1.3B settlement of the banks with other federal and state governments and agencies.

OFAC investigated the banks in connection with violations of US sanctions on Burma, Cuba, Iran, Libya, Sudan, Syria, and violations related to proliferation of weapons of mass destruction and global terrorism.  According to OFAC, “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.  For the Treasury Press Release on this action, click here.

The three banks are UniCredit Bank AG in Germany, UniCredit Bank Austria AG and UniCredit S.p.A in Italy.  Click the hyperlinks for each bank’s settlement agreement.  According to OFAC, the bank did not self-disclose.

This is a summary.  See the complete documents accessible via hyperlinks above for more detail.

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