UK

The Persian Gold PLC website openly states that it "is an Irish based AIM quoted company in 2003 to examine and explore for large gold deposits in the altered volcanics of Iran... Largely unexplored in the last 30 years, Iran has low operating costs and excellent infrastructure with a highly educated and well trained workforce."

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A March 2009 company press release states, "John Teeling [Persian Gold PLC Chairman] is not one of those who shuns geo-political risk. Angels may fear to tread, but Colombia, Iran, Iraq, Zimbabwe and other “difficult” countries appear to be meat and drink to the Teeling team."

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In the third quarter of 2009, the Florida Retirement System Trust Fund (Pension) prohibited financial investment in the company due to its operations in Iran. ("Protecting Florida’s Investments Act (PFIA): Quarterly Report," 7/28/09)

In 2019, CalSTRS identified Royal Bank of Scotland as potentially having ties to Iran. CalSTRS subsequently removed Royal Bank of Scotland after reviewing the company’s internal controls to prevent sanction violations. 

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According to its Annual Report filed with the SEC for fiscal year 2019: "During 2019 affiliates of RBS Group (RBSG) facilitated 14 payments which were remitted by, or on behalf of, Iranian Government owned entities and/or entities designated under Executive Order 13382 or 13224, and received by RBSG customers (non-designated and located in the United Kingdom) in relation to legal fees.

All the payments described above were processed in full compliance with applicable sanctions and where relevant authorised under applicable licence.

The transactions described above resulted in £165,000 gross revenue to RBSG. Considering the processes in place to undertake such transactions, including enhanced due diligence processes, the profit from these transactions was negligible. RBSG has a restrictive risk appetite in relation to transactions involving Iran and will only continue to engage in transactions similar to those described above as long as such transactions are in compliance with applicable sanctions laws and within RBSG’s risk appetite.

RBS maintain one account for an Iranian Government entity located in the United Kingdom. The purpose of the account is to facilitate UK domestic transactions only for employees’ salaries and operating costs such as UK taxes and utilities. No commercial activity is processed through the account.

Guarantees

Under applicable licenses granted by appropriate authorities, affiliates of RBSG hold four legacy guarantees entered into between 1984 and 2005, which support arrangements lawfully entered into by affiliates of RBSG customers with Iranian counterparties. During 2019 a guarantee previously understood to have expired was identified as still active and is an addition to the three guarantees reported in 2018. These legacy guarantees are in favour of Iranian Government owned financial institutions. The affiliates of RBSG have made considerable efforts to exit and formally cancel the guarantees.

In 2019, one guarantee earned commission of EUR 24.00, and the other three guarantees received no revenue.

Iranian Petroleum Industry

Section 13(r) of the Securities Exchange Act (as amended) requires disclosure of any knowing engagement in activity described in section 5 (a) or (b) of the Iran Sanctions Act, including significant investments in or transactions that could develop the Iranian petroleum or petrochemical sectors.

During 2019, affiliates of RBSG received a number of payments on behalf of their clients in relation to services provided in connection to an oil and gas field located in the North Sea from a UK Company (non-Iranian party).  The UK Company manages the operation of the oil and gas field which they jointly own with a company owned and controlled by the Government of Iran. None of these transactions directly involved Iranian Government owned entities or Iranian Government owned financial institutions. All such payments were made in compliance with applicable sanctions and only attract a standard processing fee which generates negligible profit for RBSG."

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"During 2017, affiliates of RBS facilitated 10 payments which were remitted by Iranian government-owned entities. These payments were received by RBS customers (non-designated parties located in the United Kingdom) in relation to various matters, including legal fees and personal remittance. Five of these payments involved Iranian Government owned financial institutions. In addition, there were a total of two outward payments during 2017 where the beneficiaries were Iranian government owned entities. These two transactions were in relation to cancellation of outstanding guarantees and legal fees and involved Iranian Government owned financial institutions. During 2017, affiliates of RBS also received 39 payments from and to accounts of non-designated parties where financial institutions identified under Executive Order 13599 were involved in the transaction. These transactions related to various matters, including legal fees and personal remittance. All the payments described above were processed in full compliance with applicable sanctions and, where required, authorised under applicable licence. Transactions involving Iranian government owned entities totalled 51 and resulted in less than the equivalent of £16,500 in gross revenue to RBS. Considering the processes in place to undertake such transactions, including enhanced due diligence processes, RBS has not made any profit from these transactions. RBS intends to continue to engage in transactions similar to those described in this paragraph as long as such transactions are in compliance with applicable sanctions laws and within RBS’s risk appetite which became more restrictive during the course of 2017."

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"The Royal Bank of Scotland has rebuffed efforts by the British government, a major shareholder, to coax the lender into facilitating trade with Iran as it seeks to avoid risky business, sources with knowledge of the discussions say. In recent months British officials have sought to boost business ties with Iran - a year on from the lifting of international sanctions - as Britain tries to forge new trade ties following June's vote to leave the European Union. The sources said Britain's finance ministry had tried to use the government's influence with RBS and to a lesser extent Lloyds, in which it holds a minority stake, to help speed up trade finance with Iran, including clearing services for Iranian banks in pounds... A Lloyds spokesman said it was a UK-focused retail and commercial bank, adding that it was "mindful that Iran remains a higher risk country with which to do business". "We therefore consider all requests on a case-by-case basis in order to protect the bank and our customers," the spokesman said... Major global lenders like HSBC which have large operations in Britain have reiterated they have no intention of doing any new business involving Iran, questioning why the United States has encouraged them to do so when U.S. financial firms are restricted." (Reuters, "State-Backed British Bank Rebuffs Government Push to Boost Iran Trade: Sources," 1/19/2017).

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"Royal Bank of Scotland Group PLC agreed to pay $100 million in penalties over allegations that it violated U.S. sanctions against Iran, Sudan and other nations, in the latest move by regulators to crack down on money laundering. Federal and state agencies said Wednesday that RBS took steps to prevent payments it processed from being flagged as subject to sanctions. In many cases, RBS removed 'material references' to U.S.-sanctioned locations or individuals from payment messages, according to the U.S. Treasury Department. 'This action demonstrates our continuing efforts to aggressively enforce U.S. sanctions laws against Iran and other sanctioned parties,' Adam Szubin, director of the Treasury's Office of Foreign Assets Control, said in a statement. In addition to the Treasury, RBS also settled with the Federal Reserve and the New York Department of Financial Services. The Financial Conduct Authority, RBS's U.K. regulator, assisted in the agencies' investigation of the bank. RBS said Wednesday that the fines stemmed from an investigation it initiated in 2010. The bank said it 'deeply regrets these failings' and has taken several steps to "address the shortcomings" in its controls, including reviewing all customer relationships in relevant countries, terminating certain client relationships, beefing up its anti-money-laundering compliance teams and other steps. RBS will pay $50 million to the federal agencies and $50 million to the New York agency, which agreed to not take further action against the bank over the alleged violations covered by the agreement. The agreement also calls for RBS to beef up its policies to prevent such activity from occurring. RBS has terminated several employees who allegedly engaged in the misconduct, including its former head of Asia, Middle East & Africa global banking services and the former head of its money-laundering prevention unit for corporate markets, according to New York officials. The bank declined to comment or assist a reporter in contacting those people. In addition, eight employees had bonuses taken back…The Treasury Department said RBS interfered with U.S. sanctions from at least 2005 to 2009. Separately, the New York Department of Financial Services said in a consent order that, from at least 2002 to 2011, RBS conducted more than 3,500 transactions through New York banks involving Sudanese and Iranian customers and beneficiaries. The U.S. Justice Department and U.S. District Attorney's Office in New York have completed criminal investigations of RBS and aren't taking action against the company, RBS said." (Wall Street Jounral, "RBS to Pay $100 Million Over Alleged Violations of U.S. Sanctions," 12/11/13)

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The Royal Bank of Scotland Group owns ABN AMRO, which also does business with Iran. U.S.-based Citizens Financial Group also is owned by The Royal Bank of Scotland Group.

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"ABN AMRO Bank, now owned by Royal Bank of Scotland Group, agreed in 2006 pay $70 million in penalties assessed by U.S. regulators related to alleged dealings with entities from Iran and Libya." (Daily Mail, "Obama to target Lloyd's of London in plan for tougher sanctions on Iran," 10/2/09)

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"A new line of investigation has focused on banking relationships. In December, ABN Amro paid $80m in penalties after it was found to have violated rules on dealing with Iran and Libya, while UBS paid $100m in 2004 after admitting breaches of rules on transactions with Iran, Libya, Cuba and Serbia. Both ABN Amro and UBS have reduced their Iran operations, as has Credit Suisse. But it has emerged that the Justice Department is probing three more banks - HSBC, Standard Chartered and France's BNP Paribas... The Royal Bank of Scotland also operates in Iran, but it is not believed to be the subject of any US regulatory interest." (The Independent, “UK banks caught in Iran sanctions probe,” 2/5/06)

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Iran’s carmaking and shipbuilding sectors are growing quicker than domestic banks can keep up with. In order to function, these industries rely on European loans. Banks providing them include HSBC, BNP Paribas, Deutsche Bank, Commerzbank, Standard Chartered and Royal Bank of Scotland. Some, however, have begun to show caution. Swiss bank UBS has said it was stopping business in Iran because the commercial climate looked unattractive. Credit Suisse has said it will not offer loans to new Iranian clients. (Daily Times, “Iran’s bravado on UN sanctions may ring hollow,” 2/2/06)

"Iran’s apparent use of 20 U.S.-based hotel properties [and InterContinental Hotels Group] as polling sites for its recent presidential election has raised questions about the hotel owners’ compliance with U.S. sanctions and the appropriateness of their involvement in a vote that Washington criticized as neither free nor fair. The 20 hotel properties whose addresses were listed by Iran belong to six U.S. companies ... and British-based InterContinental Hotels Group." (Voa News, "Iran’s Absentee Voting Events at US Hotels Raise Sanctions, Ethics Questions," 6/25/21).

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InterContinental Hotels Group (“InterContinental”) Hotel, Crowne Plaza Berlin - Potsdamer Platz, has agreed to host the Iran Post Sanctions Business Forum (the “Forum”) in Berlin on January 24-25, 2017.  

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InterContinental London Park Lane Hotel has agreed to serve as the venue for the Euromoney Iran Conference (the “Conference”) on May 19, 2016. (Euromoney Iran Conference Website, “Iran: Reconnecting with the International Financial Community”).

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"On Tuesday, United Against Nuclear Iran (UANI) called on the InterContinental Hotels Group to reverse its decision to host Iran's delegation during this month's meeting of the United Nations Human Rights Council (HRC) in Geneva, Switzerland. UANI recently learned of InterContinental's decision, which comes as Ahmed Shaheed, UN Special Rapporteur on the Situation of Human Rights in Iran, released a new report which found that Iran executed 670 individuals last year, including ethnic minorities, juveniles, and homosexuals." (UANI, "UANI Calls on InterContinental Hotels Group to Reverse Decision to Host Iranian Delegation During Human Rights Council Meeting in Geneva," 3/13/12)

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"The Permanent Representative of the Islamic Republic of Iran 'requests the pleasure' of my company to dine with H.E. Dr. Mahmoud Ahmadinejad. The dinner is at the Intercontinental Hotel with names carefully written out at all the place settings around a rectangular table. (Time, "My Dinner with Ahmadinejad," 9/26/07)

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"In a day of pure New York drama at Columbia University yesterday, Ahmadinejad expressed skepticism of the Holocaust, questioned 'who truly was involved' in the Sept. 11 attacks, denied oppressing women and claimed there are no gays in Iran....He was on ABC, CNN and PBS and met a group of anti-Zionist Jewish rabbis in his InterContinental The Barclay New York Hotel suite.... 8 a.m. Gives an interview to Charlie Rose of PBS and to Italian television at InterContinental The Barclay New York Hotel." (NY Daily News, "Grinning madman squirms at Columbia," 9/25/07)

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"The warmer tone colored most of the approximately two-hour meeting, held at the Barclay Intercontinental Hotel in midtown Manhattan. Ahmadinejad then hosted a meeting for American religious figures from Christian, Jewish, and Muslim groups, and tonight he will meet with policy watchers and former U.S. officials in a meeting organized by the New York-based Council on Foreign Relations. The unusual efforts appear aimed at de-demonizing the hard-line Ahmadinejad's image in the West, and particularly in the United States, which is leading an effort to seek economic sanctions at the U.N. for Iran's defiance of a Security Council order to halt the enrichment of uranium." (US News, "Iran's Ahmadinejad: 'Can't we just be friends?'", 9/20/06)

"Much of the growth in international air traffic is due to airlines increasing capacity or frequency of existing routes. But it also includes many European airlines, such as Air France and British Airways, that have been able to restart flights to Iran after long hiatuses... “Iran went from a marginalized and difficult place in the world economy in 2013 to a place of growth,” said Ray Takeyh, a fellow at the Council on Foreign Relations specializing on Iran." (The Washington Post, "Iran's nuclear deal divided: Skies full of planes," 11/2/2016).

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"Foreign airlines, including Malaysia's AirAsia and Britain's BMI, are ceasing services to Iran amid its mounting economic problems spurred on by Western sanctions... BMI will halt its flights from Saturday because of its full takeover by British Airways, a spokeswoman for the parent airline told AFP in London, adding that 'customers will be offered a full refund.'" (The Daily Star, "Airlines stop Iran flights as currency crisis bites," 10/9/2012)

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"Deutsche Lufthansa AG (LHA.XE) and its U.K.-based airline British Midland International said Wednesday it faces refueling issues after Iranian authorities said there were fuel shortages, but Iran's state-run newspaper reported it was a retaliatory move... The decision comes after some European countries last year refused to refuel Iranian aircraft. That led to Iran warning it would take action if their planes continued to be refused fuel... A spokeswoman for bmi, said: 'Due to fuel supplies being restricted by the authorities in Iran, bmi is having to reschedule its services between Tehran and London Heathrow. The new schedule will now include a stop en route for additional fuel.'She said the airline hopes that the situation "will be resolved as quickly as possible." (Dow Jones, "European Airlines Face Refueling Issues in Iran," 4/13/11)

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"In retaliation for an agreement between the United States and European oil companies that has made it impossible for Iran's national airline to refuel its planes in most of Europe, the Islamic Republic has stopped fully providing the only British airline flying to Tehran with fuel. British Midlands International (BMI), which operates daily flights between London and Tehran, said Monday that Iranian airline authorities have stopped fully refueling their planes for about a week, forcing the airline to make stops in third countries. 'We are currently not getting all the fuel we need at Tehran's main airport,' said a spokeswoman for BMI." (Washington Post, "Iran stops fully refueling British planes in retaliation against oil agreement," 10/25/2010)

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"Britain's bmi chief executive here Tuesday expressed the group's willingness to cooperate with Iranian airlines. Leasing airplanes to Iran comes among the topics on the agenda to start bilateral cooperation," Nigel Turner told MNA. He pointed to launch of direct round flights between Tehran and London on October 8, dismissing probable sanctions on Iran. 'Iran has a potentially lucrative market,' Turner said, concluding bmi seeks its long-term interests, closing the eyes to troubles caused by sanctions in the short run.
He also announced the cancellation of British Airways flights to Iran, adding, 'Having acquired British Mediterranean Airways (BMED), an affiliate of British Airways, bmi organizes Tehran-London-Tehran flights.' 'The flights are launched from Mehrabad International Airport up to November 3 and from Imam Khomeini International Airport (IKIA) afterward.'" (Payvand News, "British bmi keen to cooperate with Iran," 10/10/07)

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Daily flights from Tehran's Imam Khomeini Airport(IKA) to London's Heathrow Airport (Company Website)

According to its Annual Report filed with the SEC for 2019: "Unilever operates in Iran through a non-US subsidiary. In 2019, sales in Iran were significantly less than one percent of Unilever’s worldwide turnover. During the year, this non-US subsidiary had approximately €1,334 in gross revenues and less than €547 in net profits attributable to the sale of food, personal care and home care products to the Hotel Homa Group, which is owned by the Social Security Organization of Iran, and IRR Mohammad Rasoullah Pharmacy & Kowsar ‘Veterans of IRGC’, which are affiliated with the Islamic Republic Revolutionary Guard Corps. Income, payroll and other taxes, duties and fees (including for utilities) were payable to the Government of Iran and affiliated entities in connection with our operations. Our non-US subsidiary maintains bank accounts in Iran with various banks to facilitate our business in the country and make any required payments to the Government of Iran and affiliated entities. While we currently continue our activities in Iran, we are continuously evaluating such activities in the light of the evolving regulatory environment."

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Unilever N.V. (a Dutch company) disclosed in 2016 that its non-U.S. subsidiary, among other relevant transactions, “advertised our products on television networks that are owned by the Government of Iran or affiliated entities,” and further noted that “[i]ncome, payroll and other taxes, duties and fees (including for utilities) were payable to the Government of Iran and affiliated entities in connection with our operations” in the country.

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"Unilever, acting through its Iranian subsidiary, has signed a joint venture partnership with Golestan Company, the makers of Golestan tea and one of Iran’s best known consumer goods companies. The agreement was signed on November 29, but was formally announced this week." (December 2017)

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Unilever is one of the companies listed as a speaker at the HR Trends Summit taking place from October 18-19, 2016 in Tehran, Iran. (Speakers).

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"Unilever, which manufactures products like Dove soap, has been in the Iranian market since at least 2003, operating factories there and maintaining an office in Tehran, according to news reports and the company's Web site. It also sells its products to the American military."

From 2000-2009, the company was the recipient of $842.1 million US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Several renowned German companies are involved in major Iranian infrastructure projects, especially in the petrochemical sector, like Linde, BASF, Lurgi, Krupp, Siemens, ZF Friedrichshafen, Mercedes, Volkswagen and MAN. (Thai Press Reports, IRAN/GERMANY IRANIAN-GERMAN TRADE UP 78%, December 8, 2008)

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Unilevers Turkish holdings, valued at YTL 100 million, are indicators of its faith in the Turkish economy, said local company spokesman Ebru Senel Erim. The Istanbul offices vast market ranges from Iran, Kazakhstan, Uzbekistan, Turkmenistan, Armenia, Georgia, Tajikistan and Azerbaijan in the East to Macedonia, Albania, Moldova, Romania, Kosovo and Bosnia in the West. (Turkish Daily News, ISTANBUL BECOMES MANAGEMENT HUB, December 17, 2007)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

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GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco. (The London Times, American pressure threatens UK firms, Christine Seib, May 27, 2006)

The Lloyds Bank Group’s businesses, being reported below, are conducted in compliance with applicable laws in respect of Iran and Syria sanctions and, except as noted below, the Lloyds Bank Group intends to continue these historic activities until it is able to legally terminate the contractual relationships or to maintain/manage them in accordance with prevailing sanctions obligations. The nature of these activities is as follows: Limited and infrequent payments made to and received from entities directly or indirectly linked to the Government of Iran. Such payments are only made if they comply with UK regulation and legislation and/or licence from the U.S. Treasury Department’s Office of Foreign Assets Control. Since the introduction of an enhanced financial sanctions policy, the Lloyds Banking Group (including the Bank) has been proactive in reducing its dealings with Iran and individuals and entities associated with Iran. There remain a small number of historic Iran-related business activities which the Lloyds Banking Group has not yet been able to terminate for legal or contractual reasons. (3/26/2020)

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In 2018 and 2019 Lloyds was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  
 

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Lloyds Banking Group PLC (a U.K. company) disclosed that, despite “reducing its dealings with Iran and individuals and entities associated with Iran,” two of its non-U.S. affiliates (Lloyds Bank PLC and Bank of Scotland PLC) received or made payments involving entities owned or controlled by the Iranian Government. Lloyds asserts that these payments (related to “historic guarantees”) were credited to blocked or frozen accounts, and specifically authorized under U.K. and EU sanctions laws. (SEC Disclosure)  

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"Lloyds TSB agreed to pay a $350 million fine to the United States government last year after an investigation found that the company had stripped information from transactions in order to channel Sudanese and Iranian money into the American banking system in violation of United States sanctions. Prior to the bank's decision to leave Iran in 2008, Lloyds received federal grants from the Farm Service Agency."  From 2000-2009, the company was the recipient of $20 million US federal funds.  They have withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Lloyds Banking Group PLC on Tuesday became the latest bank to reach a settlement with American authorities over the handling of funds for countries under U.S. sanctions such as Iran.  The U.S. Treasury's Office of Foreign Assets Control announced a $217 million settlement related to Lloyds's 'intentional manipulation and deletion' of information in wire-transfer instructions that were routed through third-party banks located in the U.S." (The Wall Street Journal, "Lloyds Settles U.S. Case Over Iranian Transactions," 12/23/09)

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“Evidence of Iran's efforts to acquire sensitive materials also is emerging from investigations by state and federal prosecutors in New York into whether a number of major Western banks illegally handled funds for Iran and deliberately hid Iranian transactions routed through the U.S….Documents detailing Iran's metals acquisition efforts are being reviewed by U.S. law-enforcement and intelligence officials, people involved in the matter said. Manhattan District Attorney Robert Morgenthau said he is conducting a broad inquiry into illegal transactions by Iran. Last week, Lloyds TSB of London agreed to pay $350 million to settle U.S. sanctions-busting charges with Mr. Morgenthau's office and the Justice Department. The bank admitted it violated U.S. law but said the practice has ceased. There are nine other banks that we think were doing this, said Mr. Morgenthau in an interview, including Barclays PLC of the U.K.  A Barclays spokesman had no comment beyond a prior disclosure confirming the inquiry. Other banks under scrutiny in the probe include Credit Suisse and Deutsche Bank, people with knowledge of the inquiries said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)

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"Lloyds TSB has agreed to forfeit $350m (£231m) to law enforcement authorities in the US after admitting breaking ­international sanctions by secretly channelling Sudanese and Iranian money into the American banking system. In the biggest penalty ever levied for a breach of US sanctions, the British bank has accepted responsibility for criminal conduct in a case involving" (The Guardian, "Lloyds forfeits $350m for disguising origin of funds from Iran and Sudan," 1/10/09)

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"It also emerged at the end of March that three European banks--Barclays and Lloyds TSB, both of the UK, and Credit Suisse of Switzerland--face investigation by the US Justice Department and the New York district authorities over whether they purposely hid the origins or destinations of transactions in order to circumvent sanctions against Iran, Cuba, Sudan and Libya. The investigations follow a federal probe into a Dutch bank, ABN Amro, in 2005, after it was fined for obscuring references in wire transfers and processing payments involving Iran and Libya. The US Treasury Department said in a warning to financial institutions in March that banks in Iran disguised their involvement in proliferation and terrorism. Like many other European banks, Credit Suisse moved to cut ties with Iran at the end of 2005." (Economist Intelligence Units Country)

Now known as Imperial Brands Plc.

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"According to the Ukrainian National Association of Tobacco and Alcohol Producers and Distributors SOVAT, cigarette export may grow by 8-10% in 2006 year-on-year. Last year Ukraine exported 6.5bn cigarettes. Export totalled 2.57bn cigarettes in the first five months of 2006. Main importers were Iran, Taiwan, Moldova, Belarus, Armenia, and Georgia. The company Reemtsma/Imperial Tobacco is still an export leader. In January-May 2006 it supplied over 1.56bn cigarettes overseas. Then follow the companies JTI, PM and Gallaher. They exported 467bn, 246.6bn and 162bn cigarettes, respectively." (Tobacco Journal International, "Ukraine: Cigarette export to increase by 8-10% in 2006," 5/01/08) Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

"Lawyers representing Meng Wanzhou tried to discredit evidence presented by U.S. officials in her extradition hearing, arguing a banker at HSBC Holdings Plc knew that a company doing business with Iran was actually an affiliate of Huawei Technologies Co. One of Meng’s lawyers, Frank Addario, told the Supreme Court of British Columbia that the Department of Justice presented “misleading and unreliable” evidence when it described a meeting Meng had with an HSBC executive in a Hong Kong tea room in 2013." (Bloomberg, "HSBC Banker Knew About Dealings With Iran, Meng's Defense Argues," 3/1/2021). 

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"Barclays Plc, BNP Paribas SA, Commerzbank AG, Credit Agricole SA, Credit Suisse Group AG, Deutsche Bank AG, HSBC Holdings Plc, Royal Bank of Scotland Group Plc and Standard Chartered Plc had been sued by military personnel who survived the attacks, and relatives and estates of those killed. The plaintiffs accused the banks in a 533-page complaint of concealing their work for Iran through such practices as altering wire transfers, and masking the identities of those transferring funds. But the judge found the complaint “devoid” of allegations that the banks knew they were enabling attacks in Iraq linked to Hezbollah, al Qaeda and other groups that the U.S. government has designated as foreign terrorist organizations." (Reuters, "Nine banks win dismissal of Iran terrorism financing lawsuit: U.S. judge," 3/29/19).

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According to its Annual Report filed with the SEC for fiscal year 2019: "Legacy contractual obligations related to guarantees Between 1996 and 2007, the HSBC Group provided guarantees to a number of its non-Iranian customers in Europe and the Middle East for various business activities in Iran. In a number of cases, the HSBC Group issued counter indemnities in support of guarantees issued by Iranian banks as the Iranian beneficiaries of the guarantees required that they be backed directly by Iranian banks. The Iranian banks to which the HSBC Group provided counter indemnities included Bank Tejarat, Bank Melli, and the Bank of Industry and Mine. The HSBC Group is seeking to cancel all relevant guarantees and counter indemnities, and does not currently intend to provide any new guarantees or counter indemnities involving Iran. None were cancelled in the first quarter of 2020 and approximately 16 remain outstanding.

Other relationships with Iranian banks Activity related to U.S.-sanctioned Iranian banks not covered elsewhere in this disclosure includes the following:

• The HSBC Group acts as the trustee and administrator for a pension scheme involving eight employees of a U.S.-sanctioned Iranian bank in Hong Kong. Under the rules of this scheme, the HSBC Group accepts contributions from the Iranian bank each month and allocates the funds into the pension accounts of the Iranian bank’s employees. The HSBC Group runs and operates this pension scheme in accordance with Hong Kong laws and regulations. Estimated gross revenue, which includes fees and/or commissions, generated by this pension scheme during the first quarter of 2020 was approximately $495.

For the Iranian bank related-activity discussed above, the HSBC Group does not allocate direct costs to fees and commissions and, therefore, has not disclosed a separate net profit measure.

The HSBC Group has been holding a safe custody box for the Central Bank of Iran. For a number of years, the box has not been accessed by the Central Bank of Iran, and no fees have been charged to the Central Bank of Iran."

"U.S. prosecutors overlooked apparent violations of U.S. sanctions against Iran by HSBC Holdings in exchange for the British bank's cooperation with a government investigation of Huawei Technologies, lawyers for the Chinese telecoms giant said

``The government agreed to overlook HSBC's continued misconduct, electing not to punish the bank, prosecute its executives or even extend the monitorship,'' Huawei's lawyers wrote in a Feb. 10, 2020 letter filed in U.S. District Court in Brooklyn, New York. The letter was seen by Reuters on Tuesday.

In return, ``HSBC agreed to cooperate with the government's efforts to depict Huawei as the  mastermind of HSBC's sanctions violations and supply witnesses to the government's stalled investigation of Huawei,'' the lawyers wrote." (Fox Business, "Huawei accuses U.S. of overlooking HSBC misconduct with Iran," 2/19/2020).

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According to its 2019 SEC disclosure, "The HSBC Group is seeking to cancel all relevant guarantees and counter indemnities, and does not currently intend to provide any new guarantees or counter indemnities involving Iran. None were cancelled in the third quarter of 2019 and approximately 16 remain outstanding."

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HSBC provided disclosure of its Iran related activities in its 2018 Annual Report filed with the SEC.
 

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"HSBC Cuts Loose UK-Licenses Bank as Pressure Builds Over Iran Sanctions." (2/20/2019)

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"HSBC and Standard Chartered, two British banks that have taken heat for anti-money laundering violations in the past decade, may have been used to facilitate alleged illicit transactions between Iran and Chinese technology giant Huawei, The Wall Street Journal reported on Sunday." (CNBC, 12/10/2018).

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At September 30, 2017, the HSBC Group had five loans outstanding to an Iranian petrochemical company. These loans are supported by the official export credit agencies of the following countries: the United Kingdom, South Korea and Japan. The HSBC Group continues to seek repayments from the Iranian company under the outstanding loans in accordance with their original maturity profiles. The HSBC Group maintains several accounts in the United Kingdom for an Iranian-owned, U.K.-regulated financial institution. These accounts are generally no longer restricted under U.K. law, though HSBC maintains restrictions on the accounts as a matter of policy. The HSBC Group is seeking to exit these accounts and has begun transferring the funds to the client's accounts at other financial institutions. Estimated gross revenue in the third quarter of 2017 on these accounts, which includes fees and/or commissions, was approximately $27,180. (2016)

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HSBC provided disclosure of its Iran related activities in its 2014 Annual Report filed with the SEC.
 

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HSBC provided disclosure of its Iran related activities in its 2013 Annual Report filed with the SEC.
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"For Syrian and Iranian citizens living in the Gulf, finding a bank to deal with just became a little tougher. Banks like Barclays and HSBC have begun turning away new customers from countries that are facing sanctions. They are closing down some existing accounts, further isolating Syrian and Iranian citizens from the global financial industry... Also under the new measures, Syrian or Iranian customers with bank balances of less than 100,000 dirhams, or $27,225, will be asked to close their accounts within 30 days. Customers with salaries of less than 15,000 dirhams will also be affected. This is because the cost to the bank of making the enquiries necessary to enforce compliance is higher than the benefit or 'profit potential' of keeping a customer with a small bank balance. It is cheaper for HSBC to close an account or not to open a new one with a balance of less than 100,000 dirhams." (The New York Times, "Sanctions Chill Reaches Banking Clients in the Persian Gulf," 2/13/13)

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"HSBC Holdings Plc's Dubai-based Middle East unit will stop personal-banking services to some customers with links to countries subject to European Union and U.S. sanctions, such as Syria and Iran. HSBC Bank Middle East Ltd. will only serve citizens of the affected nations that qualify for Advance and Premier accounts, which require a minimum balance of 100,000 U.A.E. dirhams ($27,225) and 350,000 dirhams respectively, if they 'completely satisfy' due-diligence requirements, according to a statement e-mailed by a Dubai-based spokeswoman for the bank. Customers started receiving letters at the beginning of February, and have been given 30 days' notice of the changed policies. London-based HSBC, Europe's largest bank by market value, agreed in December to pay $1.92 billion to settle U.S. probes of money laundering after Senate testimony indicated it handled so-called U-turn transactions through U.S. financial institutions that involved funds from Iran to non-U.S. banks." (Bloomberg,"HSBC Says It Will Stop Serving Some Syrian, Iranian Citizens," 2/7/13)

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"HSBC Holdings Plc (HSBA), Europe’s largest bank, agreed to pay $1.92 billion to settle U.S. probes of money laundering in the largest such accord ever.The settlement includes a deferred prosecution agreement with the U.S. Department of Justice, the London-based bank said in an e-mailed statement today. The U.K.’s Financial Services Authority said the bank will have to employ an independent monitor to oversee compliance with anti-money laundering requirements. Chief Executive Officer Stuart Gulliver’s attempts to reduce costs and improve profitability have been hurt by the U.S. probes and by compensation claims from U.K. clients. A Senate committee said in July that lax oversight by top HSBC executives gave terrorists and drug cartels access to the U.S. financial system. The settlement is the biggest reached in the U.S. over such allegations, topping the $619 million in penalties paid in June by the Netherlands’ ING Group NV. 'This has removed an uncertainty, though it doesn’t clear the path completely for HSBC,' said Lewis Wan, Hong Kong-based chief investment officer at Pride Investments Group Ltd., which doesn’t hold HSBC shares. 'Regulators have been tightening oversight of banks. Lenders like HSBC will have to continue to strengthen their compliance'. . .'We accept responsibility for our past mistakes,' Gulliver said in the statement. 'We have said we are profoundly sorry for them, and we do so again. The HSBC of today is a fundamentally different organization from the one that made those mistakes.'In a range of measures, the bank has to have a group money laundering reporting officer and establish a board to oversee anti-money laundering controls, the FSA said in a statement today. HSBC will also spend $700 million over five years on a 'know your customer' review, it said." (Bloomberg, "HSBC to Pay $1.92 Billion in U.S. Money-Laundering Probe," 12/11/12)

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"HSBC Holdings Plc (HSBA) and Standard Chartered Plc (STAN) may settle U.S. charges involving money-laundering violations and dollar-clearing transactions on behalf of Iranian clients as soon as next week, two people familiar with the negotiations said . . . HSBC announced last month that it had added an $800 million provision to an existing $700 million reserve to cover the costs of a potential settlement, and warned investors that the final payment could 'significantly' exceed the $1.5 billion total. A Senate committee said in July that failures in London- based HSBC’s money-laundering controls allowed terrorists and drug cartels access to the U.S. financial system." (Bloomberg News, "HSBC, Standard Chartered Close to Resolving Iran Claims," 12/8/12)

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"HSBC said at its half-year results in the summer that it had set aside $700m to cover the cost of the scandal ... But Stuart Gulliver, HSBC’s chief executive, admitted the actual total could be higher. The final bill is now expected to have more than doubled to $1.5bn, forcing the bank to make a further provision of up to $800m in its third quarter results tomorrow, according to Sky News. HSBC is understood to have held talks with US authorities over the past few months to settle the claims, which came to light following a year-long investigation by a powerful US senate committee. The Senate Committee on Homeland Security in July branded HSBC as having been 'pervasively polluted for a long time' by allowing funds to be moved to and from its US branches to countries including Mexico, Syria, the Cayman Islands, Iran and Saudi Arabia. The scandal forced David Bagley to step down as HSBC’s head of compliance, while the bank’s chief, Mr Gulliver, issued a humbling apology... The bank has since initiated an overhaul of its compliance operations and hired a number of big hitters to raise standards, including Preeta Bansal, a former senior official in the Obama administration, who has been appointed global general counsel for litigation and regulatory affairs at HSBC... In addition to the increased money laundering bill, analysts at Nomura have warned that HSBC might have to make a new provision for the mis-selling of Payment Protection Insurance (PPI) of about £150m." (The Telegraph, "HSBC to face £1bn fines over money-laundering," 11/4/2012)

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"HSBC, for example, has a national charter rather than a New York state charter. So it is not subject to supervision by Lawsky's New York State Department of Financial Services (DFS), which has only been in existence since October... Two more banks, Standard Chartered and HSBC, are expected to settle related cases in the coming weeks, according to the source familiar with those probes." (Reuters, "Analysis: StanChart hit may not dog other banks as much as feared," 9/4/2012)

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"HSBC Holdings Plc (HSBA)’s head of group compliance, David Bagley, told a Senate hearing he will step down amid charges the bank gave terrorists, drug cartels and criminals access to the U.S. financial system by failing to guard against money laundering. Bagley was among at least six HSBC executives who testified before the Senate’s Permanent Subcommittee on Investigations today after the panel released a 335-page report describing a decade of compliance failures by Europe’s biggest bank. London- based HSBC enabled drug lords to launder money in Mexico, did business with firms linked to terrorism and concealed transactions that bypassed U.S. sanctions against Iran, Senate investigators said in the report . . . An article in the July 2005 issue documented the bank’s ties to Iran, Libya, Sudan and Syria. It reported the U.S. Treasury Department had fined HSBC for a transfer in April 2000 of $100,000 benefiting the Taliban, which at the time was running Afghanistan, and providing Osama bin Laden with the base from which he plotted the Sept. 11 attacks . . . The report also cited HSBC’s violations of Treasury Department sanctions on dealings with Iran, which the U.S. is working to isolate from the global banking system. The sanctions, enforced by the Office of Foreign Assets Control, or OFAC, seek to punish Iran for operating a nuclear program outside international inspection. Internal communications show the U.S. bankers were aware that some of the transactions were linked to Iran in violation of U.S. sanctions." (Bloomberg, "HSBC Executive Resigns at Senate Money Laundering Hearing," 7/17/12) 

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A scathing U.S. Senate report charges that Europe's largest bank exposed the U.S. financial system to money laundering by Mexican drug cartels as well as potentially illicit transactions involving Iran and other countries. The extensive report on London-based HSBC Holdings PLC by the Senate Permanent Subcommittee on Investigations was released ahead of a hearing on Capitol Hill Tuesday morning. The probe focused on the bank's key U.S. affiliate, HBUS, and also said U.S. regulators knew the bank had a poor system to detect problems but failed to take action. The sweeping allegations include accounts that two affiliates for years sent thousands of transactions through HBUS 'without disclosing links to Iran' even though they were supposed to. For that period from 2001 to 2007, an auditor so far has uncovered nearly 25,000 such transactions involving billions of dollars. It's unclear whether the transactions violated U.S. law, but the Senate report said that by evading safeguards, the affiliates 'may have facilitated transactions on behalf of terrorists, drug traffickers or other wrongdoers' . . . Ahead of the hearing, HSBC released a statement saying its executives will offer a formal apology at the hearing. 'We will apologize, acknowledge these mistakes, answer for our actions and give our absolute commitment to fixing what went wrong,' the statement said. The U.S. Justice Department said it is conducting a criminal investigation into HSBC's operations but declined to confirm that the bank is in settlement talks." (Fox News, "Senate report: European bank exposed US financial system to Iran, drug cartel transactions," 7/17/12)

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"HSBC, a banking and financial services giant headquartered in London, opened a representative office in Iran in November 1999. The bank has provided various loans to Iranian business over the decade, including a $108 million loan to the National Petrochemical Company of Iran in 2003. Dr. Nasser Homapour, senior representative for HSBC in Iran, said at the time, “The completion of this sizable transaction represents an important step in HSBC’s progressive engagement with Iran in general, and NPC in particular.' Due to pressure by the United States and other governments, the bank announced in 2007 that it would not seek any new business in Iran, but the company continues to maintain an office in Iran and service existing customers. “We will honor all existing binding commitments where permitted,” said HSBC spokesman, Ahmad Othman."  From 2000-2009, the company was the recipient of $404,500 US federal funds.  Their business in Iran is currently active, but there are no new plans for further invesment.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Another step the Obama administration should take is to sustain American pressure on foreign banks and oil companies to halt their dealings with Iran's energy sector. This effort has led such major firms as Germany's Deutsche Bank and Commerzbank, England's HSBC, Credit Suisse and Royal Dutch Shell to halt or limit their business with Iran." (The Baltimore Sun, "FACING THE IRANIAN THREAT," 12/9/08)

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"U.S. outreach to foreign banks and to oil companies considering investing in Iran's energy sector has reportedly convinced more than 80 banks and several major potential oil-field investors to cease all or some of their business with Iran. Among them: Germany's two largest banks (Deutsche Bank and Commerzbank), London-based HSBC, Credit Suisse, Norwegian energy company StatoilHydro, and Royal Dutch Shell." (The Wall Street Journal, "How To Put The Squeeze On Iran," 11/13/08)

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"European giants HSBC, Deutsche Bank and Credit Suisse have pulled out of Iran while BNP Paribas, Commerzbank and Dresdner Bank have severely curtailed their business with the Islamic republic. (Gulf Daily News, "US imposes sanctions on major Iran banks," 5/1/08)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

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"In late 2005, Dutch bank ABN Amro agreed to pay $80 million in fines stemming in part from improper transactions with Iran through its subsidiary in Dubai, United Arab Emirates. UBS Bank and Credit Suisse of Switzerland recently announced they were suspending most new business with Iran, and British-based HSBC said it would no longer accept dollar transactions from within Iran." (Los Angeles Times, "U.S. Puts The Squeeze On Iran's Oil Fields," 1/7/07)

Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)