Settlement Agreement Between Unicredit Bank AG and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC)

April 15, 2019

I. PARTIES

1. OFAC administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, and proliferators of weapons of mass destruction, among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction. 

2. UniCredit Bank AG is a German subsidiary of UniCredit S.p.A., the parent company of the UniCredit Group headquartered in Milan, Italy. UniCredit Bank AG is headquartered in Munich, Germany. UniCredit Bank AG was formerly known m Bayerische Hypo-und Vereinsbank AG ("HVB"), prior to its merger with UniCredit S.p.A. in 2005. 

II. APPARENT VIOLATIONS

3. OFAC conducted an investigation of UniCredit Bank AG in connection with more than 2,100 transactions processed to or through the United States or involving U.S. financial institutions in apparent violation of various OFAC sanctions programs. 

4. OFAC detennined that UniCredit Bank AG did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute an egregious case. 

III. FACTUAL STATEMENT

5. For a number of years, up to and including 2011, UniCredit Bank AG operated U.S. dollar (USD) accounts on behalf of the Islamic Republic of Iran Shipping Lines (lRISL) and several companies owned by or otherwise affiliated with IRISL. UniCredit Bank AG managed the accounts of those companies in a manner that did not identify the interest or involvement of IRISL in transactions sent to or through U.S. intermediaries. UniCredit Bank AG implemented auto-transfer mechanisms and selectively applied controls on those companies' accounts and processed transactions involving an interest of IRISL to or through the United States for almost two years after OFAC added IRISL to the List of Specially Designated Nationals and Blocked Persons (the "SDN List") in September 2008. UniCredit Bank AG's
processing of these transactions appears to have violated the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (WMDPSR). 

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