UniCredit Bank AG agreed to pay over US $1.3 billion in sanctions to multiple federal and state regulators to settle allegations that it violated US sanctions against Iran by facilitating the movement of almost US $400 million through the US financial system from 2002 through 2011 on behalf of a number of sanctioned entities, including the Islamic Republic of Iran Shipping Lines. The sanctions – which included fines and forfeiture – were divided among multiple UniCredit Bank entities and were imposed by the US Department of Treasury’s Office of Foreign Assets Control, the Board of Governors of the Federal Reserve System, the New York State Department of Financial Services, the US Department of Justice and the NY County District Attorney’s Office. Two weeks ago, Standard Chartered Bank agreed to pay sanctions (including fines and forfeiture) in excess of US $1.1. billion to resolve US federal, state and local allegations, as well as claims by the UK Financial Conduct Authority, that the bank violated various US government sanctions programs, as well as maintained poor anti-money laundering controls. (Click here for background in the article “Multinational Bank Resolves Purported Breaches of US Sanctions Program and AML Breakdowns by Paying Over US $1.1 Billion to Multiple Government Overseers” in the April 14, 2019 edition of Bridging the Week.)