BTMU’s Tokyo operations engaged in practices designed to conceal the involvement of countries or persons subject to U.S. sanctions, including Iran, in transactions that BTMU processed through financial institutions in the United States.

On May 18, 2010, Bank of Guam originated a $2,265 wire transfer on behalf of a customer, destined for a trading company in the United Arab Emirates. The payment was for delivery charges related to the shipment of furniture and other items to Iran.

2003 Funds transfer.

1999 - 2000 Funds transfers & 1995 - 2000 operation of accounts.

2003 Funds transfer.

On June 7, 2010, BBNY manually added Isfahan Internacional Importadora Ltda (“Isfahan”), a customer of Banco do Brasil, S.A., Brazil (“BB-Brazil”), to its “Good Guy Exception List” after its Office of Foreign Assets Control (OFAC) interdiction software generated alerts on a recurring basis due to the word “Isfahan”—a location in Iran—in the company’s name.

2001 Funds transfer.

Illegal export of commercial Boeing 747 aircraft from the US to Iran.

From October 2005 to October 2007, the Kraaipoels received orders from customers in Iran for US-origin goods, including various aircraft components that were restricted from being transshipped to Iran.

Conspired to illegally export U.S. origin 7075 T7 Aluminum tubing from Illinois to Iran.