HSBC Holdings plc

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.

Hetran, Inc.

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.