Unicredit Plea Agreement

The deal follows last week`s announcement of a $1.08 billion global deal between Standard Chartered Bank and US and UK authorities for similar sanctions, as well as UK failings in the fight against money laundering. As part of the deal, the London-based lender will remain in a deferred prosecution agreement with the Department of Justice until April 2021. UCB AG also pleaded guilty, while imposing a fine of approximately $US 316 million with DANY. [42] UCB AG pleaded guilty to forgery of first-degree business documents and fifth-degree conspiracy to move hundreds of millions of dollars through Manhattan banks on behalf of sanctioned counties and institutions. Bank Austria separately entered into a joint non-prosecution agreement with DOJ and DANY and recovered $20 million in the sanctioned companies` transactions. [43] UniCredit S.p.A. has agreed separately to ensure that the commitments made by UCB AG and Bank Austria vis-à-vis DOJ and DANY are respected. [44] According to DANY, UniCredit Group`s investigation was conducted following a previous investigation conducted by IRISL in 2011, during which certain USD payment activities related to UniCredit Group were identified. [45] OfAC stated that UniCredit S.p.A. was well aware of the sanctions prohibitions applicable in the United States and that it had taken steps to “correct” payment information (i.e., remove references to sanctioned companies or countries) in order to avoid such prohibitions. [27] According to OFAC, UniCredit S.p.A. transactions in USD carried out in the context of akcredits involving the delivery of goods to Cuba, and UniCredit S.p.A.

knew, on the basis of the documents it had received from its client, that the payments related to Cuba. [28] OFAC stated that UniCredit S.p.A. also processed transactions worth more than one million dollars on behalf of companies established in Burma and designated in accordance with the Burmese sanctions program and transactions worth hundreds of thousands of USD on behalf of companies established in Sudan during the period when Sudan was subject to extensive U.S. economic sanctions. [29] Under the settlement agreement, UniCredit S.p.A. also processed transactions worth more than USD 100,000 related to Syria, which is also subject to extensive US economic sanctions. [30] As part of the admission of guilt, UCB AG agreed, on the application, to pay approximately $316 million in criminal damages to D.A.`s office. At the same time, UCB AG agreed to plead guilty and pay $316 million in forfeiture to the United States, in accordance with a plea agreement with the Department of Justice. In accordance with the lease and non-prosecution agreements and the regulation of parallel federal and prudential investigations, UCB AG, Bank Austria and its parent company UniCredit S.p.A.

have agreed to adhere to best practices in international banking transparency and to continue to implement procedures and training to ensure compliance with US sanctions laws and regulations. France`s BNP Paribas SA pleaded guilty in 2014 and paid a record fine of $US 8.9 billion. Other banks have agreed on much lower penalties and deferred prosecution agreements, including Amsterdam-based ING Bank, which paid $619 million in 2012, and Zurich-based Credit Suisse Group AG, which paid $536 million in 2009. “The actions of UCB AG in the intentional provision of a designated proliferation of weapons of mass destruction with access to the United States. . . .

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