UniCredit Bank
According to a US congressional report, updated in February 2022, UniCredit AG paid $1.3 billion in April 2019 in a settlement "For illicitly processing transactions through the U.S. financial system on behalf of Islamic Republic of Iran Shipping Lines (IRISL)."
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"Banks owned by UniCredit Group have agreed to pay $1.3 billion to settle claims they processed payments allegedly in violation of multiple U.S. government-sanctions programs.
The banks processed payments worth $500 million through U.S. financial institutions between 2007 and 2011 that breached sanctions related to Iran, Cuba, Libya and other countries, the U.S. Department of the Treasury’s Office of Foreign Assets Control said in a statement Monday." (Wall Street Journal, "UniCredit to Pay $1.3 Billion to Settle Sanctions Charges," 4/15/19)
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According to a settlement with the US Treasury Department signed April 5, 2019, "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 OF AC sanctions programs.
OFAC determined that UniCredit Bank AG did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute an egregious case...."
The apparent violations include conduct relating to the Islamic Republic of Iran Shipping Line (IRISL), according to the settlement:
"Between 2004 and 2008, UniCredit Bank opened, and through its Hamburg branch maintaned, accounts denominated in US dollars and other currencies for at least 34 entities owned, controlled by, or otherwise affiliated with IRISL."
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"The company has been reported as potentially providing financial services in Iran. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."
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In 2017, CalSTRS designated Unicredit SpA as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Unicredit SpA after reviewing the company’s business with Iran and internal controls to prevent sanction violations.
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In 2017 the U.S. state of California listed Unicredit Spa as a company under review for reportedly providing banking services to Iran.
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In 2017 the U.S. state of Michigan listed Unicredit on its Iran restricted companies list rendering Unicredit ineligible for investment and/or state contracting.
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Austrian and Iranian bankers met in Vienna in September to discuss the resumption of trade financing, people with knowledge of the plans said at the time. Austria’s top three banks, Erste Group Bank AG, UniCredit Bank Austria AG and Raiffeisen Bank International AG would be among the participants, according to the people, who asked not to be identified. (Bloomberg News, "Three Foreign Banks to Open in Iran, Central Bank Official Says," 11/1/2016).
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"Austrian and Iranian bankers are meeting in Vienna on Wednesday to discuss the resumption of trade financing, people familiar with the discussion said... Austria’s top three banks Erste Group Bank AG, UniCredit Bank Austria AG and Raiffeisen Bank International AG are all among the participants, the people said." (Bloomberg ,"Iranian Bankers Said to Meet Austrians to Resume Commercial Ties," 9/28/2016)
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- Services designated Iranian banks while conducting business with U.S. banks
- Provides U.S. Dollars to Iranian banks
- Provides services to UN3* Iranian banks ("Iran's Dirty Banking", Avi Jorisch)
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“The U.S. investigation of UniCredit SpA (UCG) on suspicions it violated economic sanctions with Iran involves far fewer transactions than those that surfaced in probes of other banks, Chief Executive Officer Federico Ghizzoni said. Italy’s biggest bank is one of several European financial institutions bracing for the outcome of investigations for alleged sanctions-busting after France’s BNP Paribas SA (BNP) was fined a record $8.97 billion in June for dealing with blacklisted countries. French lenders Credit Agricole SA (ACA) and Societe Generale SA (GLE) and Germany’s Deutsche Bank AG (DBK) and Commerzbank AG are also under scrutiny from state and federal authorities including the U.S. Department of Justice. The UniCredit case involves volumes ‘by far lower than what we have seen with many other banks,”’Ghizzoni said in an interview with Bloomberg Television late yesterday, referring to questionable payments the bank is alleged to have processed and could be fined for. He didn’t elaborate on the number and said the bank isn’t considering setting aside funds to cover possible penalties.” (Bloomberg, "UniCredit Iran Probe for Amounts ’Far Lower’ Than Peers," 8/6/14)
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“As part of talks in Geneva over the nuclear question, Tehran is pressing world powers to speed up trade finance arrangements on humanitarian deals involving both Western and Iranian banks, according to an Iranian government document seen by Reuters and sources familiar with the initiative. Iranian government officials and international trade sources say Tehran wants to simplify complex trade finance arrangements potentially worth billions of dollars, which would alleviate pressure on the country's sanctioned banking system…Iranian government officials said the document, which has been sent to Iran's Supreme National Security Council, tasked with safeguarding Tehran's interests, listed the following banks as ‘available for further actions’: Standard Chartered Bank (London), Societe Generale (Paris), Banque de Commerce et de Placements (BCP) (Geneva), UniCredit Bank (Munich), Commerzbank (Frankfurt), United Bank (Zurich) and BHF Bank (Frankfurt). It was not clear whether these banks had been approached to provide finance. Two business executives familiar with the initiative said they were aware that Standard Chartered, Societe Generale, Commerzbank were among those on the wish list. Commerzbank, Societe Generale, United Bank and BCP all declined to comment. A spokeswoman for Standard Chartered said the bank was not involved and would not get involved in any transaction with any party from Iran. Unicredit said the group was ‘not aware of, and hence is not participating in any international initiative involving financial institutions related to Iran subsequent to the P5+1 (major powers) accord.’” (Reuters, “Western banks cold-shoulder Iran trade finance scheme,” 3/13/14)
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"U.S. authorities are investigating UniCredit's (CRDI.MI) German unit HVB as part of a global crackdown on possible violations of sanctions on Iran that has already cost Standard Chartered (STAN.L ) a hefty settlement. In an emailed statement on Sunday, UniCredit said the New York County District Attorney's Office, the U.S. Department of Justice and the U.S. Treasury Department's Office of Foreign Assets Control were leading the investigation... UniCredit said HVB was conducting a broader review of its historic compliance with U.S. economic sanctions on its own initiative. HVB declined to comment beyond the statement. 'The investigation and review are ongoing, and it would be inappropriate to comment further at this time,' UniCredit said... UniCredit mentioned the U.S. probe in a 463-page prospectus for a capital increase in January and in its following financial earnings statements. The documents however mentioned neither HVB, the German bank UniCredit acquired in 2005, or Iran. These details were first reported by the Financial Times on Sunday. 'It is not possible at this time to predict the outcome of the on-going investigation, including the timing and any potential financial impact it may have upon the operating results of the company in any future financial period,' UniCredit said in its first-half results statement on August 3." (Reuters, "UniCredit unit HVB probed over Iran sanctions," 8/26/2012)
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