The United States charges that:
CONSPIRACY TO DEFRAUD THE UNITED STATES AND TO VIOLATE THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT
(18 U.S.C. § 371)
1. From in or around January 2002, through in or around December 2011, in the District of Columbia and elsewhere, defendant UNICREDIT BANK AG and others, both known and unknown to the United States, unlawfully, willfully and knowingly combined, conspired, confederated and agreed with one another to commit offenses against the United States, that is, to defraud the United States and to engage in financial transactions with Sanctioned Entities including Specially Designated Nationals (SDNs) in violation of the International Emergency Economic Powers Act (IEEPA), Title 50, United States Code, Sections 1702 and 1705, and the executive orders, regulations, and embargoes issued thereunder.
2. The goal of the conspiracy was for UNICREDIT BANK AG and others, both known and unknown to the United States, to profit financially by engaging in a conspiracy and a scheme to defraud the United States and to violate IEEPA, and the executive orders, regulations, and embargoes issued thereunder.
3. A further goal of the conspiracy was for UNICREDIT BANK AG and others both known and unknown to the United States, to violate executive orders and regulations prohibiting the exportation, directly and indirectly, of financial services from the United States to Sanctioned Entities, which are geographies, entities, and individuals sanctioned by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), which is located in the District of Columbia, or entities and individuals designated as SDNs by OFAC.