Between May 24, 2006, and October 10, 2008, HSBC Bank USA, N.A. failed to appropriately block or reject a book-entry transfer of 32,000 ounces of gold bullion for the ultimate benefit of a bank-owned or controlled by the Government of Iran.

Advice of letter of credit relating to Iran in 2000.

2001 Funds Transfer

Facilitated the illegal export of high-tech microelectronics, uninterruptible power supplies and other commodities to Iran.

On February 2, 2006, HM attempted to export water testing equipment to an entity located in Iran.

In June 2012, Hetran caused the peeling machine to be shipped from Pennsylvania to Dubai in the United Arab Emirates, fraudulently listing Crescent as the end-user, knowing that the shipment was ultimately being sent by FIMCO to Iran in violation of federal law.

Between 2001 and 2003, Schein exported dental equipment to Iran without the required license.

2000 and 2001 failure to respond to requirement to furnish information.

Participated in a specialty aviation insurance policy that covered commercial flight operations in Iran during the period of April 2005 – April 2006. Specifically, HCC participated in the hull portion of an aircraft hull and liability insurance placement by a foreign insurance broker that insured a foreign-owned commercial airline that leased aircraft to an air charter company that operated in Iran.

1999 failure to reject a letter of credit relating to Iran.