These compliance obligations include many of the “best practices” of the sanctions compliance program and are largely in line with the expectations of federal regulators for compliance, including the Federal Reserve Board.  With respect to UniCredit`s comparisons, Secretary of State Mandelker stated that “the United States continues to improve our sanctions programs, that the integration of compliance obligations into OFAC`s comparison agreements is an important part of our broader strategy to ensure that the private sector implements strong and effective compliance programs that protect the U.S. financial system from abuse.”  Therefore, financial institutions and other entities may consider this list of compliance obligations as a guide for the design and assessment of the adequacy of their own sanctions compliance programmes. Nevertheless, OFAC`s recent approach to imposing standard compliance obligations in its transaction agreements is made more difficult by the fact (as OFAC has repeatedly acknowledged) that there is no consistent approach and that, in terms of the “right” compliance program, much depends on the particular type of business profile and risk. Bank Austria has entered into a no-prosecution agreement with the DOJ and will lose US$20 million related to the operations of sanctioned companies.  Under the non-prosecution agreement, Bank Austria participated, on behalf of its Iranian clients, including Bank Saderat, an SDN, in a “Wire Stripping” and in an opaque transmission of payment messages.  UniCredit S.p.A. has separately undertaken to ensure the fulfilment of the obligations of UCB AG and Bank Austria vis-à-vis the DOJ.  The Integrity Bank Unit investigates and prosecutes complex, inter-Bezirk and international criminal cases involving financial institutions. Prosecutions against the unit focus on banks and other financial institutions, including their senior executives, officers and employees, whose actions threaten the integrity of each institution or the entire financial system. UniCredit SpA is close to reaching an agreement with U.S. authorities on allegations that the bank provided dollar clearing services to Iranian customers in violation of U.S.
sanctions, people with knowledge of the case said. . . .