Affiliated Banks Pay $1.3 Billion for Violations of U.S. Sanctions

Three affiliated banks agreed to resolve OFAC's investigation into apparent violations of numerous economic sanctions programs, including those concerning weapons of mass destruction ("WMD") proliferation.

According to the three Settlement Agreements (see here, here and here), OFAC stated that UniCredit Bank AG, UniCredit Bank Austria AG and UniCredit S.p.A. processed payments through U.S. financial institutions without disclosing the involvement of sanctioned persons, in apparent violation of U.S. sanctions programs aimed at WMD proliferators and global terrorism, as well as Burma, Cuba, Iran, Libya, Sudan and Syria.

In addition, OFAC claimed that UniCredit Bank AG operated U.S. dollar accounts on behalf of companies affiliated with the Islamic Republic of Iran Shipping Lines ("IRISL") in a manner that obscured IRISL's involvement from U.S. intermediaries.

All three banks are mandated to implement and maintain certain compliance commitments intended to lower the risk of the recurrence of the conduct that led to the apparent violations. The banks agreed to pay a total of $611 million under the OFAC settlement agreements, which were part of a global $1.3 billion settlement with the DOJ, the New York County District Attorney's Office, the Federal Reserve Board and the Department of Financial Services of the State of New York.