UANI

The Society for Worldwide Interbank Financial Telecommunication ("SWIFT") is “a member-owned cooperative through which the financial world conducts its business operations.” “More than 9,700 banking organisations, securities institutions and corporate customers in 209 countries” use SWIFT services “to exchange millions of standardised financial messages.” (SWIFT Website. “Company information”)

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SWIFT provides services to Iranian banks sanctioned by the U.S., EU and UN. SWIFT has issued Business Identifier Codes (BIC) codes to sanctioned Iranian institutions, including major Iranian financial institutions designated by the United States.

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The SWIFT 2010 Annual Review reported that Iran’s 19 member banks and 25 connected institutions had sent 1.160 million FIN messages and received 1.105 FIN messages. Compared to 2009, this represented a 0.7% growth in FIN messages sent and received. (“SWIFT Annual Review 2010,” April 2011)

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“An organization that is central to the international banking system said it is working with U.S. and European governments to address their concerns that its financial services are being used by Iran to avoid sanctions and conduct illicit business. Current and former U.S. officials said that if the Belgium-based organization, the Society for Worldwide Interbank Financial Telecommunication, or Swift, bans sanctioned Iranian entities from using its network, Tehran could find itself virtually incapable of conducting electronic financial transactions. 'This would be the knockout blow,' said Avi Jorisch, a former U.S. Treasury Department official who has worked on Swift... Swift's board of directors is comprised of executives from some of the world's most important banks. This week, activist group United Against Nuclear Iran wrote to board members arguing that they are acting outside U.S. law by allowing designated Iranian banks to use Swift's services. They argued that Swift's guidelines mandate that its cut ties to Iran.” (The Wall Street Journal. "Banking Hub Adds to Pressure on Iran," 2/4/12)

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"The Senate Banking Committee unanimously approved a new regimen of anti-Iran sanctions on Thursday that would for the first time threaten to punish the global financial telecommunications network that nearly all banks rely on to conduct their daily business. The legislation's banking provision, aimed at forcing the telecommunications network to expel Iranian banks that have already been blacklisted, would be financially catastrophic for Iran if carried out fully, according to proponents and sanctions experts. Expulsion from the network - the Society for Worldwide Interbank Financial Telecommunication, known as Swift - would deny to Iran many billions of dollars in revenue from abroad that is routinely routed into its domestic banking system. 'The Senate Banking Committee has sent a strong message,' said Mark D. Wallace, the president of United Against Nuclear Iran, an advocacy group based in New York that has been pushing for such a provision. He has argued that Swift, which based in Belgium, is already in violation of other sanctions against Iran as well as its own rules. "Swift must end its business in Iran," he said. The legislation does not specify what action would be taken against Swift if it did not comply. There was no immediate comment by Swift on the legislation. But officials of the network, mindful of pressure from Mr. Wallace's group and others that have increasingly advocated stricter sanctions against Iran, denied it was acting illegally, in a statement posted earlier Thursday on the network's Web site." (The New York Times. "Senate Panel Approves Potentially Toughest Penalty Yet Against Iran’s Wallet," 2/3/12)

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"In a sign that the sanctions could tighten further, United Against Nuclear Iran, a New York-based advocacy group that has successfully promoted other economic penalties against Iran, said it had started a campaign to publicize Iran’s dependence on the global financial telecommunication network that nearly every financial institution uses to conduct business. On Monday the group sent a letter to the network, the Society for Worldwide Interbank Financial Telecommunication, known as Swift, warning it to end all relations with Iran’s central bank and 'deny access to all Iranian banks.' The letter asserted that Iran’s membership in the network already violated American and European financial sanctions as well as Swift’s own rules. There was no immediate comment to the letter from either Iran or Swift, which is headquartered in Belgium. Mark D. Wallace, president of United Against Nuclear Iran, said in a telephone interview that the group might seek Congressional hearings on Iran’s Swift membership, which he described as crucial to the country’s economic survival. 'This campaign has the potential to force action,' Mr. Wallace said. 'In some ways it’s a silver bullet. If the Iranians don’t have access to Swift, they can’t get access to revenue.'" (The New York Times. "Iran Praises Nuclear Talks With Team From U.N.," 2/1/12)

Gazprombank is a subsidiary of Russian gas producer and exporter giant, Gazprom. (Gazprombank website, "Bank's Shareholders")

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"The semi-official Iranian Mehr news agency said on Friday that importers in India -- Iran's second biggest oil customer after China -- were paying off oil debts through Gazprombank... 'There has been no word of this at all... No name has been mentioned, not Gazprom nor any other particular bank. These news reports are not valid,' said the ministry source... An Indian industry source said there had been talks about paying for Iranian oil via Gazprombank but no Indian companies had yet opened an account there and they were still paying through Halkbank." (Reuters, "Iran downplays report India paying for oil via Russia," 10/29/2011) 

"The Persian Gulf country will buy two Ukrainian-made Antonov-158s, after a test flight of the aircraft earlier this month, Mohammad-Ali Sirati, managing director of the Iranian aircraft company, was cited as saying by the official Islamic Republic News Agency. The countries then will start to jointly build the aircraft next year, Sirati, whose company will be in charge of the project, said in Tehran yesterday. Some 30 percent of each plane will be made in Iran, state-run media reported." (Business Week, "Iran Says Antonov-158 Built With Ukraine May Fly in 2013," 10/6/2011)

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Antonov lists on its website that their AN-24 turboprop aircraft is serially produced at HESA plant in Isfahan, Iran. (Antonov website)

"This license was so heavily redacted by OFAC at the request of JPMorgan Chase that it is impossible to say exactly what was authorized other than the fact that it involved a letter of credit that somehow ran afoul of the sanctions against Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Over the last three presidential administrations, the United States government has granted Citigroup 37 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"OFAC granted a license on Dec. 27, 2007, to Citibank authorizing it to make good on an agreement its Japanese subsidiary had entered into in October. The bank had agreed to confirm that certain conditions in a letter of credit had been meet, after which a Malaysian exporter of split-system air conditioners to Turkey would be paid. Then the bank discovered that the goods were to be shipped aboard a vessel called the Iran Ilam that was owned by the Iranian government-run shipping line known as Irisl, thus requiring that the transaction be licensed. The license was issued even though the Treasury Department and OFAC suspected that Irisl was being used to smuggle goods into Iran in contravention of various embargoes, including banned technology the government needed for its ballistic missile and nuclear programs. Moreover, at the time the license was issued, the United States had evidence that five months earlier, the Iran Ilam itself had delivered a lathe that could be used to make precise metal parts needed for nuclear centrifuges from China to Iran’s Shahid Bagheri Industrial Group, according to government officials who requested anonymity to speak about an intelligence matter. Indeed, within months of issuing the license, OFAC announced at a news conference that the United States was adding Irisl to a special blacklist, after an investigation found that Irisl had falsified cargo records, relied on front companies and used other trickery to mask the true nature and destination of shipments. At the September 2008 news conference announcing the decision, OFAC's director, Adam J. Szubin, warned that banks and companies worldwide should be aware that they could be unwittingly aiding Iran’s quest for banned technology by doing business with Irisl: 'Irisl’s deceptive practices make it nearly impossible to determine whether its shipments are licit or illicit,' he said. Mr. Szubin acknowledged in an interview that he was under no obligation to issue the license to Citigroup, given that banks were already prohibited generally from doing business with Iranian entities. But he said that OFAC had issued licenses in cases like this in the past in which the bank had no way of knowing that Irisl was involved and Irisl would have been paid by a foreign third party anyway. To depart from that norm in this case, he added, risked opening up his agency charges of unfair treatment and litigation, and tipping off Irisl that it was under investigation."

"This license is one of at least three that OFAC issued involving the China Great Wall Industry Corporation. The licenses were issued after the Chinese company was added to the United States' special blacklist for supplying components to Iran's ballistic missile development program and before it was removed from the list on June 19, 2008. In one case, the agency licensed the Chinese company's lawyers, who were challenging the blacklisting, to receive legal fees. Two other cases involved wire transactions to or from China Great Wall. OFAC could have forced Citigroup to seize the funds, but said it chose instead to authorize the bank to return the money because China was unlikely to agree that the funds should be seized and therefore the bank would have almost certainly lost a legal battle to keep the funds blocked." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Over the last three presidential administrations, the United States government has granted Bank of America 19 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"OFAC redacted so much of this license file that it is impossible to tell what exactly it authorized, though what is clear is that it was related to another license, granted to BNP Paribas, involving the acquisition of equipment that was of Iranian origin. Bank of America, which was financing the deal, contended that the sale should be licensed because the goods had already been exported to another country." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Egypt is expanding its financial ties with Iran through a jointly owned financial institution: the Misr Iran Development Bank. MIDB was founded in 1975, four years before Iran's Islamic revolution, and has somehow endured the tumult since. Today, the MIDB may have become a vehicle for Iran to circumvent economic sanctions with extensive help from Egypt, one of America's closest allies in the region. It is a testament to how difficult it can be for the U.S. to enforce international sanctions, even among countries that appear to be natural allies in the effort to deter Iran.

Egypt controls 59.86 percent of MIDB, split evenly between the state-owned National Investment Bank and Misr Insurance Company, which is partially owned by the state. Iran's 40.14 percent share in MIDB, worth about $80 million, is held by the Iran Foreign Investment Company. The IFIC is the investment arm of Iran's Oil Stabilization Fund, a sovereign wealth vehicle that generates profits for the Iranian government, with investments in the Middle East, Africa, South America, and beyond.

Tehran created the stabilization fund in 1999 to help insulate it from the gyrations of the oil market. When oil was up, the regime threw money into the fund and invested it through the IFIC. When oil was down, Iran withdrew money from the IFIC's investments to make up the shortfall. In the face of severe international sanctions, Iran has been withdrawing heavily of late. This August, when it became clear that the stabilization fund enabled the Iranians to resist international sanctions, the U.S. Treasury Department placed it on the Iranian Transactions Regulation (ITR) list, an administrative designation that made it unlawful for Americans to do business with the company because it is "wholly owned by the Government of Iran....

In 2009, as the international community began to discuss ways to punish the Islamic Republic for its illicit nuclear program, the bank transferred $50 million to Iran, according tot he govenrment-controleld Tehran Times." (The Atlantic, "How Egypt is Helping Iran to Circumvent Sanctions," 11/15/10)

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Listed as providing services for Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010) 

Woori Bank is the lending unit of South Korea's third-largest financial company, the state-owned Woori Finance Holdings Co. The firm is currently undergoing privatization negotiations and came under investigation for fraud during the summer of 2010. (Businessweek).

In October 2010, Woori Bank, along with Industrial Bank of Korea, have been appointed by the South Korean government to "finance legitimate trade with Iran in sectors unaffected by sanctions, channelled through Iran's central bank." The deal will allow Iran's central bank to deposit oil proceeds in Woori Bank, which will then use the funds to pay South Korean firms exporting to Iran. South Korean trade to Iran amounts to $10 billion annually. A Woori Bank spokesman explained that "Iran's central bank is not the target of sanctions, so transactions through the bank are legal. We do not worry about any possibly sanctinons by the US against us" (Financial Times). 

Industrial Bank of Korea is one of South Korea's largest banks. It is a publicly-owned institution specializing in loans for small and medium-sized corporations. IBK is also involved in consumer banking, investment banking, and asset management (Google Finance).

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In October of 2010, the South Korean government appointed IBK to "finance commerce with Iran and revive business ties damaged by sanctions." The deal allows the Iranian central bank to deposit proceeds from oil sales at IBK, which will use the funds to pay South Korean firms exporting to Iran. South Korean trade with Iran amounts to $10 billion annually (Financial Times). 

• Conducts business with Iranian banks
• Operates banks in Iran