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On June 28, 2013, the Office of Foreign Assets Control (OFAC) announced that Intesa Sanpaolo S.p.A. (Intesa) had agreed to remit $2,949,030 to settle potential civil liability for apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515; the Sudanese Sanctions Regulations (SSR), 31 C.F.R. part 538; and the Iranian Transactions Regulations (ITR), 31 C.F.R. part 560.1. OFAC has determined that Intesa did not voluntarily self-disclose the apparent violations and that the apparent violations constituted a non-egregious case. As early as the late 1990s, Intesa maintained a customer relationship with Irasco S.r.l. (Irasco), an Italian company headquartered in Genoa, Italy that is owned or controlled by the Government of Iran (GOI). Despite Irasco’s ownership and line of business as an exporter of goods to Iran, and its financial and commercial associations with Iranian state-owned financial institutions, companies, and projects, Intesa failed to identify Irasco as meeting the definition of the GOI in the ITR and, at the time of the apparent violations, did not take appropriate measures to prevent the bank from processing transactions for or on behalf of Irasco that terminated in the United States and/or with U.S. persons. Intesa’s payment instructions for these transactions all identified Irasco as the ordering customer. |
US – Intesa Sanpaolo settles potential civil liability for apparent violations of multiple sanctions programs
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