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ENFORCEMENT INFORMATION FOR April 15, 2019
UniCredit Bank AG Settles Potential Civil Liability for Apparent Violations of Multiple Sanctions Programs: UniCredit Bank AG, a financial institution headquartered in München, Germany and a subsidiary of the UniCredit Group, has agreed to a settlement amount of $553,380,759 to settle its potential civil liability for 2,158 apparent violations of primarily the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544 (WMDPSR), but also apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR); the Burmese Sanctions Regulations, 31 C.F.R. Part 537 (BSR)[i]; the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (SSR)[ii]; the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR)[iii]; the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR)[iv]; the Libyan Sanctions Regulations, 31 C.F.R. Part 570 (LSR); and the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594 (GTSR) (collectively, the “Apparent Violations”).
This...
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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...