Communications and Power Industries LLC

Occurring on or about March 31, 2006, to on or about October 22, 2010. The Switzerland branch office of CPI’s U.S. subsidiary, Communications and Power Industries International Inc., sold, on 30 occasions, x-ray generators to an entity in Tehran, Iran; attempted to sell, on two occasions, x-ray generators and a medical digital imaging workstation to an entity in Tehran, Iran; at the request of an entity in Tehran, Iran, directed its affiliate in Canada, Communications & Power Industries Canada Inc.

Commerzbank AG

As early as 2002, bank employees deleted or omitted references to Iranian financial institutions, replaced the originating bank information with Commerzbank’s name, and later created a process to route payments involving Iranian counterparties to a payment queue requiring manual processing by bank employees rather than routine, automated processing.

Comasec SAS

In 2008 Comasec arranged for the transport of 35,000 pairs of Nitrotough N115 and Blue Nitrile gloves from the US to Iran via the UAE without the required US government authorization.

Clearstream Banking SA

From at least December 2007 through June 2008, Clearstream maintained an account at a U.S. financial institution in New York through which the Central Bank of Iran (“CBI”) maintained a beneficial ownership interest in 26 securities, with a nominal value of $2.813 billion, held in custody at a central securities depository in the United States.

Ali Sadr Hashemi Nejad

Sadr had been accused of violating American sanctions laws against Iran by moving millions of dollars in payments for his family business through the U.S. financial system. Participated in a scheme in which more than $115 million in payments for a Venezuela housing complex were funneled illegally through the U.S. financial system for the benefit of Iranian individuals and entities. A federal judge dismissed the case against Sadr in July 2020, vacating the jury's guilty verdict. The U.S.