Civil Enforcement Information - UniCredit Bank AG (Settlement 1 of 3 in web post)

Date issued: Apr. 15 2019

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TURBOFAC Commentary (2507 words)

Notes:

1) This is the first of three separate settlement agreements pertaining to UniCredit entities. Comments are broken apart by entity fined. See:

* Civil Enforcement Information - UniCredit Bank AG (Settlement 1 of 3 in web post)
* Civil Enforcement Information - UniCredit Bank Austria AG (Settlement 2 of 3 in web post)
* Civil Enforcement Information - UniCredit S.p.A. (Settlement 3 of 3 in web post)

2) Further factual information provided in Settlement Agreement (OFAC) - UniCredit Bank AG; Criminal Forfeiture Information - UniCredit Bank AG.

3) As noted in the first paragraph of the web post, most or all of the OFAC fine is essentially non-payable, given that the fines imposed by the other federal agencies party to the global settlement are owed over $553,380,759.

4) Up through the day on which it was released, the UniCredit Bank...