Credit Suisse had standard procedures for using cover payments to avoid referencing parties subject to U.S. sanctions and omitting information, removing information, or providing incorrect information in payment messages in order to conceal the identities of U.S.

For a number of years, up to and including 2008, CA-CIB and certain of its predecessor banks, and CA-CIB’s subsidiary located in Switzerland, Crédit Agricole (Suisse) S.A. (“CAS”), and its predecessors — including Crédit Lyonnais (Suisse) S.A. (“CLS”) and Crédit Agricole Indosuez (Suisse) S.A. (“CAIS”) — processed thousands of transactions to or through U.S. financial institutions that involved countries and/or persons (individuals and entities) subject to the sanctions regulations administered by OFAC, including Iran.

Export of petrochemical valves to Iran and Iraq through Australia in order to avoid the Export Administration Regulations.

Between the approximate dates of October 7, 2011, and February 20, 2013, when COSL Singapore, through its subsidiary companies COSL Drilling Pan-Pacific (Labuan) Ltd and COSL Drilling Pan-Pacific Ltd, exported or attempted to export 55 orders of oil rig supplies from the United States to Singapore and the United Arab Emirates, and then re-exported or attempted to re-export these supplies to four separate oil rigs located in Iranian territorial waters.

Between June 2007 and February 2008, Nam and Seng fraudulently purchased and caused 6,000 modules to be illegally exported from a Minnesota company through Singapore, and later to Iran.

Between June 2007 and February 2008, Nam and Seng fraudulently purchased and caused 6,000 modules to be illegally exported from a Minnesota company through Singapore, and later to Iran.

Illegally exported auto parts to Iran.

1999-2000 Facilitation of Trade with Iran

1999-2000 Facilitation of Trade with Iran

OFAC alleged that Confi-Dental acted without an OFAC license when it entered into contract with, and attempted to make shipments to, an Iranian company.