Lloyds TSB

Banking
28
LON: LLOY
UK
Lloyds TSB

The Lloyds Bank Group’s businesses, being reported below, are conducted in compliance with applicable laws in respect of Iran and Syria sanctions and, except as noted below, the Lloyds Bank Group intends to continue these historic activities until it is able to legally terminate the contractual relationships or to maintain/manage them in accordance with prevailing sanctions obligations. The nature of these activities is as follows: Limited and infrequent payments made to and received from entities directly or indirectly linked to the Government of Iran. Such payments are only made if they comply with UK regulation and legislation and/or licence from the U.S. Treasury Department’s Office of Foreign Assets Control. Since the introduction of an enhanced financial sanctions policy, the Lloyds Banking Group (including the Bank) has been proactive in reducing its dealings with Iran and individuals and entities associated with Iran. There remain a small number of historic Iran-related business activities which the Lloyds Banking Group has not yet been able to terminate for legal or contractual reasons. (3/26/2020)

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In 2018 and 2019 Lloyds was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  
 

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Lloyds Banking Group PLC (a U.K. company) disclosed that, despite “reducing its dealings with Iran and individuals and entities associated with Iran,” two of its non-U.S. affiliates (Lloyds Bank PLC and Bank of Scotland PLC) received or made payments involving entities owned or controlled by the Iranian Government. Lloyds asserts that these payments (related to “historic guarantees”) were credited to blocked or frozen accounts, and specifically authorized under U.K. and EU sanctions laws. (SEC Disclosure)  

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN AmroBarclaysCredit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"Lloyds TSB agreed to pay a $350 million fine to the United States government last year after an investigation found that the company had stripped information from transactions in order to channel Sudanese and Iranian money into the American banking system in violation of United States sanctions. Prior to the bank's decision to leave Iran in 2008, Lloyds received federal grants from the Farm Service Agency."  From 2000-2009, the company was the recipient of $20 million US federal funds.  They have withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Lloyds Banking Group PLC on Tuesday became the latest bank to reach a settlement with American authorities over the handling of funds for countries under U.S. sanctions such as Iran.  The U.S. Treasury's Office of Foreign Assets Control announced a $217 million settlement related to Lloyds's 'intentional manipulation and deletion' of information in wire-transfer instructions that were routed through third-party banks located in the U.S." (The Wall Street Journal, "Lloyds Settles U.S. Case Over Iranian Transactions," 12/23/09)

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“Evidence of Iran's efforts to acquire sensitive materials also is emerging from investigations by state and federal prosecutors in New York into whether a number of major Western banks illegally handled funds for Iran and deliberately hid Iranian transactions routed through the U.S….Documents detailing Iran's metals acquisition efforts are being reviewed by U.S. law-enforcement and intelligence officials, people involved in the matter said. Manhattan District Attorney Robert Morgenthau said he is conducting a broad inquiry into illegal transactions by Iran. Last week, Lloyds TSB of London agreed to pay $350 million to settle U.S. sanctions-busting charges with Mr. Morgenthau's office and the Justice Department. The bank admitted it violated U.S. law but said the practice has ceased. There are nine other banks that we think were doing this, said Mr. Morgenthau in an interview, including Barclays PLC of the U.K.  A Barclays spokesman had no comment beyond a prior disclosure confirming the inquiry. Other banks under scrutiny in the probe include Credit Suisse and Deutsche Bank, people with knowledge of the inquiries said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)

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"Lloyds TSB has agreed to forfeit $350m (£231m) to law enforcement authorities in the US after admitting breaking ­international sanctions by secretly channelling Sudanese and Iranian money into the American banking system. In the biggest penalty ever levied for a breach of US sanctions, the British bank has accepted responsibility for criminal conduct in a case involving" (The Guardian, "Lloyds forfeits $350m for disguising origin of funds from Iran and Sudan," 1/10/09)

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"It also emerged at the end of March that three European banks--Barclays and Lloyds TSB, both of the UK, and Credit Suisse of Switzerland--face investigation by the US Justice Department and the New York district authorities over whether they purposely hid the origins or destinations of transactions in order to circumvent sanctions against Iran, Cuba, Sudan and Libya. The investigations follow a federal probe into a Dutch bank, ABN Amro, in 2005, after it was fined for obscuring references in wire transfers and processing payments involving Iran and Libya. The US Treasury Department said in a warning to financial institutions in March that banks in Iran disguised their involvement in proliferation and terrorism. Like many other European banks, Credit Suisse moved to cut ties with Iran at the end of 2005." (Economist Intelligence Units Country)

Response: ""Thank you for bringing this to our attention and I can confirm that this use of our brand and name is spurious as we do not operate out of Iran." (March 28, 2018)" 
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Response: " “[Our] review took into account many individual risk factors, including those you cite as items 1-11 in your letter, and we remain fully aware of the multiple ongoing risks of doing business in Iran.” ; “…the Group’s current stance towards Iran remains one of extreme caution.”" (June 2016).