Civil Enforcement Information - UniCredit S.p.A. (Settlement 3 of 3 in web post)

Date issued: Apr. 15 2019

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TURBOFAC Commentary (462 words)

Notes:

1) This is the third 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 S.p.A.

3) Fact patterns and jurisdictional bases are all broadly typical for the genre of large, post-2007 non-U.S. bank penalties. Jurisdictional basis for all violations is that the non-U.S. bank caused U.S. processing institutions to violate the primary sanctions provisions cited, either by dealing in blocked property, exporting a financial service to an...