Halkbank

Participated in a scheme to violate U.S. economic sanctions imposed against Iran involving billions of dollars’ with of Iranian oil proceeds held at Atilla’s employer.

Guidant Corporation

Between July 2000 and July 2004, involving its vascular intervention and cardiac surgery business units, Guidant acted without an OFAC license or outside the scope of its license by exporting goods for the ultimate resale to Iran and Iraq.