Intesa Sanpaolo SpA (“Intesa Sanpaolo”), Italy’s largest retail bank, has agreed to pay a USD235 million fine to the New York State Department of Financial Services (the “DFS”) for sanctions and anti-money laundering violations identified by the DFS dating back to 2002. According to the DFS, Intesa Sanpaolo mismanaged its transaction monitoring system, repeatedly processed suspicious transactions involving shell companies and deliberately concealed information from the DFS. The bank is also said to have trained certain employees to handle transactions involving Iran to obfuscate the money-processing activities so they could not be identified as transactions tied to a sanctioned entity. In addition to the agreed fine, the bank is required to extend the involvement of an independent compliance consultant for up to two years. Furthermore, the bank must submit a revised compliance program to the DFS within 60 days.