Intesa Sanpaolo SpA
New York’s top banking regulator on Thursday fined Italian bank Intesa Sanpaolo SpA and its New York branch $235 million for violations of the state’s laws prohibiting money laundering and bank secrecy, including the masking of transactions involving Iran, a sanctioned entity. The bank “specifically trained certain employees” to obscure money-processing activities involving Iran so those transactions couldn’t be properly flagged, according to the state Department of Financial Services. Milan-based Intesa Sanpaolo and its New York branch had “severe compliance failures” in its transaction-monitoring system and deliberately concealed information from bank examiners, DFS said... In regard to Iranian transactions, the bank used “a special process” to clear thousands of Iranian transactions between 2002 and 2006, worth more than $11 billion, through its New York branch during a period when Iran was subject to economic sanctions. The process omitted details in payment messages sent to New York that could have caused the transactions to be flagged for scrutiny. (Wall Street Journal, "Intesa Sanpaola Fined $235 Million by New York Regulator," 12/15/2016).
Noted for conducting business with Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)
"Intesa Sanpaolo S.p.A. ('Intesa') has 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 The Office of Foreign Assets Control ('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... Intesa processed 31 wire transfersfor Irasco totaling $3,142,565 between November 1, 2004, and December 8, 2006, in apparent violation of the ITR." (US Treasury Sanctions Enforcement Information for June 28, 2013)
"On Aug. 21, 2003, Banca Intessa blocked a transaction for an unknown amount from China Precision Machinery Import Export to a second party. But a few months later, the bank was given an OFAC license to release China Precision Machinery's funds to the other party in the transaction. This, despite the fact that the Chinese government-owned company had been sanctioned multiple times for providing sensitive technology to Iran and other countries under the Treasury Department's weapons of mass destruction sanctions program. OFAC declined to say how much money was released back to a company the United States has called a 'serial proliferator,' citing the objections of a different party to the transaction, presumably Banca Intesa. Within months of granting the license, OFAC again penalized China Precision Machinery under its weapons of mass destruction program, this time based on 'credible information' that it and other companies had been transferring goods to Iran that could be used to 'make a "material contribution" to weapons of mass destruction or cruise missile or ballistic missile systems.' OFAC's director, Adam J. Szubin, said that at the time the license was granted to Banca Intesa, the agency did not have the authority to keep the funds blocked; firms sanctioned under the weapons of mass destruction sanctions regime face narrower penalties, such as losing United States government contracts and losing the ability to export their products into the United States. He said the amount in this case was small - under $10,000. And he noted that it was not until several years later, with the levying of additional, tougher sanctions against the Chinese company, that OFAC received the authority to order its funds frozen." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)
"ABAN Commercial & Industrial Ltd. had accounts at the Rome branch of Iran's government-owned Bank Sepah, records show. Bank Sepah has longstanding ties to Banca Intesa, although no evidence has surfaced to date showing that Banca Intesa facilitated illegal acquisitions of sensitive materials by ABAN, people with knowledge of the matter said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)