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.

Engaged in hundreds of millions of dollars worth of transactions on behalf of the Government of Iran and other Iranian entities.

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.

GWC Valve International was sentenced to a criminal fine of $300,000 and five years of corporate probation and ordered to forfeit $410,833.82 in connection after pleading guilty to charges of violating restrictions on the export of industrial valves to Iran.

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.

2002 improper closure of Iranian accounts.

Conspired to facilitate the illegal export of technology to Iran.

Conspired to facilitate the illegal export of technology to Iran.