The bank had reserved provisions beyond the transaction and will therefore have 300 million euros ($339 million) after tax in additional profits in the first quarter. The core capital ratio – a reference to financial capacity – will increase by about 8.5 basis points, he said. The Bank will report first quarter results on May 9. Finally, the OFAC regime includes the 23 OFAC compliance obligations (which are in Appendix A of this Memorandum) that have been included in more than half a dozen transaction agreements since December 2018. OFAC stated that these obligations should be considered as guidelines for compliance with sanctions for all businesses and should be the “characteristics of an effective compliance program.” Financial institutions and non-financial institutions in the United States and abroad should carefully consider these 23 compliance obligations when evaluating and updating their compliance programs. These compliance obligations include many “best practices” of the sanctions compliance program and largely meet the compliance expectations of federal banking supervisors, including the Federal Reserve Board. [47] With respect to the UniCredit agreements, Under-Secretary of State Mandelker stated that “[a] the United States continues to improve our sanctions programs and that the inclusion of compliance obligations in OFAC settlement agreements is an important part of our broader strategy to ensure that the private sector implements robust and effective compliance programs that protect the U.S. financial system from abuse.” [48] As a result, financial institutions and other entities may view this list of compliance obligations as a guide for designing and assessing the adequacy of their own sanctions programs. Nevertheless, OFAC`s recent approach to imposing default compliance obligations in its comparison agreements is made more difficult (as OFAC has repeatedly acknowledged) by the lack of a one-size-fits-all approach and the fact that much of the “right” compliance program depends on the particular nature of a company`s business profile and risk profile.

See transaction agreements: UniCredit Bank AG, UniCredit Bank Austria AG, UniCredit S.p.A. The sectoral amounts outstanding by the banks are fully covered by provisions, so that the final settlement amount in the first quarter of 1999 will be around 300 million euros according to the negative positive P-L effect at the group level and will have a positive impact on the group`s CET1 ratio of about 8.5 basis items. , in line with UC`s third quarter 18 and 4Q18 results.