Banking

"Austria’s Oberbank will withdraw from Iran because of increased risk for European companies in light of potential U.S. sanctions, it said on Wednesday." (June 13, 2018)

--

"Austria’s Oberbank, which, as a result of the 2015 nuclear deal became the first European bank to enter Iran’s financial system, announced it has not moved forward with business transactions in the Islamic Republic because of US sanctions." (5/31/2018).
 

--

"Oberbank (OBER.VI) on Thursday said it had signed a deal with Iran, enabling it to finance new ventures there and making it one of the first European banks to do so since sanctions were eased." (September 21, 2017)

--

UANI is now dismayed to learn Oberbank AG participated in the February 20, 2017 Vereinigung der Bayerischen Wirtschaft e. V. (“vbw”) meeting with Iranian Foreign Minister Dr. Mohammed Javad Zarif and Ambassador S. E. Ali Majedi. Prospective engagement with the vbw Economic Liaison Office in Tehran, where the Tehran Chamber will serve as a local partner. Troublingly, the Tehran Chamber is affiliated with the Iran Development and Renovation Organisation (“IDRO”). (vbw Website, “Round Table mit dem iranischen Außenminister Dr. Zarif”).

--

"Austrian Oberbank will continue its professional procedures and support transactions with Iran which have helped the bank to gain an excellent reputation in both countries. "As the first Austrian bank, we are signing a framework agreement for tied financial loans (G3) in US dollars, yen and euros. This agreement allows Oesterreichische Kontrollbank AG (OeKB) covered financing with maturities of more than 2 years. It also allows the financing of important projects, for example in infrastructure or health care. It is therefore urgently awaited by well-known Austrian exporters, who are also shortly before signing their export contracts. The agreement allows important Austrian exporters to start their projects in strategic Iranian sectors. Our range of services is only offered to customers from our markets," Alexander Türk, from the Austrian Oberbank, told Trend." (September 2017)

--

"Austria agreed on Wednesday to significantly increase its export guarantees for deals with Iran during a visit by the Islamic Republic's central bank chief, two people familiar with the matter said. It will raise the total amount of guarantees that Oesterreichische Kontrollbank, the body responsible, can provide to roughly 1 billion euros ($1.1 billion) from more than 200 million euros, the people said. "It is about saying that it is possible to do significantly more than before," said one of the people, who spoke on condition of anonymity because the talks between Iranian and Austrian officials were confidential." (Reuters, "Austria signals readiness to do more business with Iran," 9/28/2016).

--

--

Referenced as an international bank providing services to 'deficient' Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)

According to its Annual Report filed with the SEC for fiscal year 2019: "During a portion of the period covered by this disclosure, Mizuho Bank was a party to a legacy counter guarantee that was opened in connection with activity of its customer for the benefit of an Iranian bank. When the guarantee was entered into, the bank in question, which is related to the Government of Iran, had not been designated under U.S. Executive Orders (“E.O.”) 13224 or 13382, although it was subsequently so designated. Mizuho Bank maintained this guarantee post-designation only after confirming that such a transaction did not involve prohibited or sanctionable activity under U.S. or other economic sanctions. As contractual obligations, this guarantee could not be exited by Mizuho Bank unilaterally. In the fiscal year ended March 31, 2019, Mizuho Bank received fees of less than ¥1 million attributable to this guarantee and earned net profits of less than that amount. Mizuho Bank terminated the counter guarantee in July 2018 before the issuance of E.O. 13846.

In the fiscal year ended March 31, 2019, Mizuho Bank conducted a limited number of fund transfers through accounts it maintains for or at a limited number of Iranian banks related to the Government of Iran and a bank designated under E.O. 13224, or through other correspondent banking accounts on behalf of such Iranian banks. These transfers were mainly associated with requests by our customers after the relaxation of applicable sanctions pursuant to the Joint Comprehensive Plan of Action and prior to the full re-imposition of such U.S. sanctions on November 5, 2018. Mizuho Bank has policies and procedures to process transfers through these accounts only after confirming that such transactions do not involve prohibited or sanctionable activity. Our non-U.S. offices engage in transactions relating to the Designated Countries on a limited basis and in compliance with applicable laws and regulations, including trade financing with respect to our customers’ export or import transactions and maintenance of correspondent banking accounts. In addition, we maintain a representative office in Iran." 

--

"Will halt all iran transactions to comply with the reimposition of U.S. sanctions against Tehran later this year…The banking unit of Mizuho Financial Group Inc said later on Thursday it would take the same action..." (July 12, 2018).

--

”Three Japanese big banks, namely the Bank of Tokyo-Mitsubishi UFJ, Sumitomo Mitsui Bank and Mizuho Bank, have started interactions in the form of telegraphic transfer—an electronic method of transferring funds—and L/C at sight  with a number of Iranian banks." (May 2017)

--

Lists a representative office in Tehran, Iran on its company website. 

--

"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules. A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010).

Mitsubishi UFJ Financial Group (MUFG) "moved Japanese employees stationed at their representative offices in Tehran to locations outside of the country... and restricted travel to [Iran and Iraq]." (Japan Times, "Japan Firms Pull Staff Out of Iran and limit travel to Iraq amid high tensions," 1/9/20)

--

According to its Annual report filed with the SEC for fiscal year 2019: "During the fiscal year ended March 31, 2019, one of our non-U.S. subsidiaries engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, our non-U.S. banking subsidiary, MUFG Bank, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers. These transactions did not involve U.S. dollars nor clearing services of U.S. banks for the settlement of payments. For the fiscal year ended March 31, 2019, the aggregate interest and fee income relating to these transactions was less than ¥100 million, representing less than 0.005 percent of our total interest and fee income. Some of these transactions were conducted through the use of non-U.S. dollar correspondent accounts and other similar settlement accounts maintained with MUFG Bank outside the United States by Iranian financial institutions and other entities in, or affiliated with, Iran. In addition to such accounts, MUFG Bank receives deposits in Japan from, and provides settlement services in Japan to, fewer than 10 Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats in Japan, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations. For the fiscal year ended March 31, 2019, the average aggregate balance of deposits held in these accounts represented less than 0.1 percent of the average balance of our total deposits. The fee income from the transactions attributable to these account holders was less than ¥20 million, representing less than 0.005 percent of our total fee income. Although there was no outstanding balance as of March 31, 2019, MUFG Bank had, during the fiscal year ended March 31, 2019, loans that were arranged prior to changes in applicable laws and regulations to borrowers in, or affiliated with, Iran, including entities owned by the Iranian government. For the fiscal year ended March 31, 2019, the agent fee income relating to these loan transactions was less than ¥20 million, representing less than 0.005 percent of our total interest and fee income.

MUFG Bank recognizes that following the withdrawal in May 2018 by the United States from the Joint Comprehensive Plan of Action, the United States has imposed secondary sanctions against non-U.S. persons who engage in or facilitate a broad range of transactions and activities involving Iran. MUFG Bank has taken the recent sanctions related developments into account and monitor any future transactions relating to Iran in order to comply with applicable U.S. and Japanese regulations as well as U.S., Japanese and other international sanctions."

--

"Will halt all iran transactions to comply with the reimposition of U.S. sanctions against Tehran later this year…" (July 12, 2018). 

--

According to its Annual Report filed with the SEC for fiscal year 2018: We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was less than ¥50 million representing less than 0.0001% of our total assets, as of March 31, 2018. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

--

As stated in its 2017 SEC disclosure: "During the quarter ended September 30, 2017, a non-U.S. subsidiary of MUFG engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, MUFG’s non-U.S. banking subsidiary, BTMU, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers.  In addition to such accounts, BTMU receives deposits in Japan from, and provides settlement services in Japan to, fewer than ten Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations."

--

”Three Japanese big banks, namely the Bank of Tokyo-Mitsubishi UFJ, Sumitomo Mitsui Bank and Mizuho Bank, have started interactions in the form of telegraphic transfer—an electronic method of transferring funds—and L/C at sight  with a number of Iranian banks." (May 2017).

--

According to its Annual report filed with the SEC for fiscal year 2016: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $0.8 million, representing less than 0.0001% of our total assets, as of March 31, 2016. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers."

--

The Bank of Tokyo-Mitsubishi UFJ is Japan's largest bank and serves as the core retail and commercial banking arm of the Mitsubishi UFJ Financial Group.

--

According to its Annual report filed with the SEC for fiscal year 2015: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $1.0 million, representing less than 0.0001% of our total assets, as of March 31, 2015. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

--

According to its Annual report filed with the SEC for fiscal year 2014: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.5 million, representing less than 0.001% of our total assets, as of March 31, 2014. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

--

"Mitsubishi UFJ Financial Group Inc. agreed to pay $250 million to the state of New York to settle claims it transferred billions of dollars for countries facing U.S. sanctions including Iran, Sudan and Myanmar. Bank of Tokyo-Mitsubishi UFJ Ltd., the main lending unit of Japan's biggest bank by market value, moved an estimated $100 billion through the state for government and privately owned entities on the Specially Designated Nationals list issued by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) between 2002 and 2007, the New York State Department of Financial Services (DFS) and New York Governor Andrew Cuomo said in a statement yesterday. The transfers involved about 28,000 clearing transactions and the bank routinely stripped information from wire transfer messages that could identify countries and people subject to international sanctions, the department said. The agreement follows HSBC Holdings Plc (HSBA)'s record settlement with the U.S. last year, stemming from sanctions aimed at pressuring Iran to halt its nuclear program. 'We have and will continue to take a hard line in rooting out misconduct at banks that threaten our national security,' Benjamin Lawsky, the superintendent of the department, said in the statement.” (Bloomberg, “Mitsubishi UFJ to Pay $250 million to NY Regulator,” 6/20/13)

--

"The Bank of Tokyo-Mitsubishi UFJ Ltd. was ordered to transfer funds belonging to Iran-based entities to the families of 17 U.S. Air Force service members killed in a 1996 attack in Saudia Arabia... The assets at issue total about $357,000 and Bank of Tokyo said it doesn’t oppose releasing them, according to the filing." (Bloomberg, "Bank of Tokyo-Mitsubishi Must Give Iran Funds to U.S. Families," 1/29/2013)

--

According to its Annual Report filed with the SEC for fiscal year 2012: "We, through our subsidiaries, engage in business activities with entities in or affiliated with Iran, including transactions with counterparties owned or controlled by the Iranian government, and our banking subsidiary has a representative office in Iran. The U.S. Department of State has designated Iran and other countries as “state sponsors of terrorism,” and U.S. law generally prohibits U.S. persons from doing business with such countries. We currently have business activities with entities in or affiliated with such countries in accordance with our policies and procedures designed to ensure compliance with regulations applicable in the jurisdictions in which we operate.

We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.7 million, representing less than 0.001% of our total assets, as of March 31, 2013. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure under Section 13(r) of the U.S. Securities Exchange Act of 1934.”

We are aware of initiatives by U.S. governmental entities and non-government entities, including institutional investors such as pension funds, to adopt or consider adopting laws, regulations or policies prohibiting transactions with or investment in, or requiring divestment from, entities doing business with Iran and other countries identified as state sponsors of terrorism. It is possible that such initiatives may result in our being unable to gain or retain entities subject to such prohibitions as customers, counter-parties or investors in our shares. In addition, depending on socio-political developments, our reputation may suffer due to our transactions with counterparties in or affiliated with these countries. The above circumstances could have an adverse effect on our business and financial condition.

Global financial institutions, including us, have become subject to an increasingly complex set of sanctions laws and regulations in recent years, and this regulatory environment is expected to continue. Moreover, the measures proposed or adopted vary across the major jurisdictions, increasing the cost and resources necessary to design and implement an appropriate global compliance program. The U.S. federal government and some state governments in the United States have enacted legislation designed to limit economic and financial transactions with Iran by limiting the ability of financial institutions that may have engaged in any one of a broad range of activities related to Iran to conduct various transactions in the relevant jurisdictions. The U.S. federal government recently strengthened the Iran-related regulations with the enactment in August 2012 of the Iran Threat Reduction and Syria Human Rights Act, which, among other things, imposes additional disclosure requirements. The Japanese government has also implemented a series of measures under the Foreign Exchange and Foreign Trade Act, such as freezing the assets of designated financial institutions and others that could contribute to Iran’s nuclear activities, and our most recently modified policies and procedures take into account the current Japanese regulatory requirements. There remains a risk of potential U.S. regulatory action against us, however, if U.S. regulators perceive the modified policies and procedures not to be in compliance with applicable regulations."

--

"Japanese trading house Mitsubishi Corp has renewed its annual oil purchase deal with Iran but cut the loading volume to comply with U.S. sanctions against the Islamic nation, trade sources said on Friday…Mitsubishi's new contractual volume from April onwards remained unclear. The company had bought 15,000 barrels of crude per day (bpd), or more, last year."  (Reuters, "Japan's Mitsubishi renews Iran oil imports deal," 6/22/12)

--

"Bank of Tokyo-Mitsubishi UFJ, which handles most of Japan's payments for oil imports from Iran, on Thursday said it had frozen transactions with Iranian banks after being ordered to do so by the New York District Court earlier this month." (Reuters, "Japan looks to central bank to pay for Iran oil: Nikkei," 5/21/2012)

--

"The National Iranian Oil Co., the country’s state-run oil company, will stop Japanese refiners from picking up cargoes until it can find alternative ways to access payments received through accounts at the Bank of Tokyo unit of Mitsubishi UFJ Financial Group Inc. (8306), the officials said, declining to be identified because of company policies... A district court in New York told Mitsubishi UFJ this month to freeze at least $2.6 billion of Iranian assets held at the bank, Tomohiro Kosaka, a Tokyo-based spokesman for Mitsubishi UFJ, said today... Mitsubishi UFJ filed a petition of objection yesterday to the New York court, said Shinya Matsumoto, a spokesman for the lender in Tokyo." (Bloomberg Businessweek, "Iran Crude to Japan Said to Face Blocks After Court Order," 5/17/2012)

--
"Two additional challenges are also in the mix for Tokyo. The first is the financing of oil imports from Iran. Annually, Japan’s oil trade with Iran runs around one trillion yen, or $13.1 billion. On January 19 the Nikkei Shimbun reported that 80 to 90 percent of those transactions are done by the Bank of Tokyo Mitsubishi UFJ, and the remainder by the Sumitomo Mitsui Banking Corporation." (CFR. "Japan's Iran Sanctions Dilemma," 1/31/12)

--

"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules... A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010).

Credit Agricole is the largest retail bank in France and one of the largest in Europe, with 13,000 employees and 2.75 billion euros in net income (Company Report).

--

Credit Agricole notes that it "is present in Iran through a representative office which has a role of liasing and informing" (Company Website). 

--

"French banks Société Générale and Crédit Agricole are under U.S. investigation for alleged money laundering and sanction breaches involving Iran, Cuba and Sudan, according to a person with direct knowledge of the matter, the latest case in a series of probes of European banks related to embargo violations. The banks are being investigated by the U.S. Treasury Department, the Justice Department, the Manhattan district attorney, and the New York Department of Financial Services, the person said. It's unclear at this point whether any charges could be brought against the two banks or whether the continuing probes could lead to potential fines, the person added. Société Générale and Crédit Agricole had previously disclosed talks with U.S. authorities over potential sanction breaches in corporate filings last year and in early 2010 without providing further details. Spokeswomen for Crédit Agricole and Société Générale declined to comment on the probes beyond the previous statements…Last month, France's largest listed bank BNP Paribas SA said it had set aside $1.1 billion to cover potential penalties related to transactions in countries under U.S. sanctions. This provision was booked in addition to the bank's existing legal provision of €1.68 billion ($2.34 billion) as of Dec. 31, 2013. The bank is in talks with federal and New York state officials to settle investigations of money laundering and sanctions violations in countries including Iran and Cuba, according to people familiar with negotiations. A BNP Paribas spokeswoman had declined to comment on the details of the probe. Société Générale and Crédit Agricole, however, may not face as large a fine as BNP Paribas could, estimates AlphaValue analyst Christophe Nijdam. ‘The provisions set aside by Société Générale and Crédit Agricole for potential litigation point to a much lower risk,’ added Mr. Nijdam. Société Générale had total provision for potential litigation of €700 million on Dec. 31, 2013, according to corporate filings. Crédit Agricole had set aside €1.1 billion for potential litigation on Dec. 31, 2012 and didn't say how much it had set aside for possible litigations in 2013.” (Wall Street Journal, “Société Générale and Crédit Agricole Under U.S. Investigation for Alleged Money Laundering, Sanction Breaches,” 3/7/14)

--

“A delegation of some of France's biggest companies will visit Iran next month to seek business as relations thaw with western powers, the head of the employers' union said on Wednesday…The prospect of an easing of trade restrictions has whetted the appetite of French firms eager to win back business in a country where some used to have extensive operations. The French Medef bosses' association has organized the visit for February 2-5, its president Pierre Gattaz told a news conference, confirming a report about the trip in the Wall Street Journal…Former French ambassador to Iran Francois Nicoullaud told Reuters that French firms that operated in Iran before the sanctions wanted to return. He cited Renault, PSA Peugeot Citroen, Airbus Group , Credit Agricole, Societe Generale and BNP Paribas.” (Reuters, “French trade delegation to visit Iran next month,” 1/15/14)

--

"French banks BNP Paribas (BNP) and Credit Agricole are conducting internal inquiries into U.S. dollar payments to check whether they are potentially in breach of American sanctions, the banks said on Monday... Credit Agricole, which used similar wording in its own annual report, is also reviewing payments linked to countries and entities potentially subject to U.S. sanctions, a spokeswoman said. 'The review is ongoing,' she said." (Reuters, "French banks investigate potential breach of U.S. sanctions," 8/27/12) 

According to a U.S. congressional report updated February 2, 2022, Standard Chartered Bank paid $639 million in a settlement in April 2019 after its Dubai branch processed Iran-related transactions to or through Standard Chartered-NY. 

--

"Standard Chartered bank is being fined $1.1bn (£843m) for violating US sanctions against Iran and over inadequate financial crime controls. The penalties, imposed in connection with a range of different investigations in the US and the UK, all date back to before 2014. The London-based banking firm set aside $900m in February in preparation for the settlements. Standard Chartered has also undertaken to improve its compliance procedures. The bulk of the settlement, $639m, relates to breaches of US sanctions against Burma (Myanmar), Cuba, Iran, Sudan and Syria." (BBC, "Standard Chartered to pay $1bn for breaching Iran sanctions," 4/9/19)

--

Standard Chartered expects it will remain under U.S. supervision for several more years over lapses in Iran-related anti-money laundering efforts because it needs more time to improve its internal standards, sources with knowledge of the matter said. Under a deferred prosecution agreement it reached with U.S. authorities in 2012, the bank is due to remain under supervision by an independent monitor until the end of 2017. The sources said the bank now expects that date to be extended, possibly by several years… StanChart rival HSBC also has a deferred prosecution agreement with the DoJ set to expire next year, after it reached a $1.92 billion (1.44 billion pounds) settlement in December 2012 on charges tied to money laundering. U.S. authorities have since 2004 imposed more than $16 billion in fines on banks worldwide for breaching sanctions related to Cuba, Iran, Libya, Myanmar, Sudan and terrorism. (Reuters, "StanChart faces extension of U.S. money-laundering vigilance," 9/2/2016)

--

Standard Chartered Bank has a network of over 1,700 branches and outlets and 5,600 ATMs in more than 70 countries worldwide (Company Website).

--

"Nine years on, after paying nearly $1bn in fines to US regulators and law enforcement agencies for sanction breaches and compliance failures, StanChart seems no closer to ending its legal problems. A Financial Times investigation has identified transactions involving Iran that could put the bank at risk of severe penalties ranging from further fines to suspension or loss of its crucial dollar clearing licence. Documents seen by the FT suggest that StanChart continued to seek new business from Iranian and Iran-connected companies after it had committed in 2007 to stop working with such clients. These activities include foreign exchange transactions that, people familiar with StanChart operations say, would have involved the US dollar. The documents suggest the bank - a few months after a costly settlement with US authorities in 2012 - was still internally reviewing its client list and was unable to determine in certain cases whether customers were Iranian or not... The US Department of Justice, the Manhattan district attorney, the Federal Reserve, the New York Department of Financial Services (DFS) and most recently, the New York attorney-general's office, are all investigating StanChart for potential new sanctions breaches. The probes, most of which became public late last year, are scrutinising whether StanChart breached sanctions after the period covered by its 2012 settlement, when the bank declared it had 'ceased all new business with Iranian customers in any currency' five years earlier. A pivotal issue is whether senior executives condoned the bank's continuing business with Iran, according to people familiar with the investigations. (Financial Times, "Standard Chartered: The Iranian connection," 9/20/15)

--

"Standard Chartered will face another three years of scrutiny by U.S. prosecutors for compliance with government sanctions against certain countries, according to documents filed on Tuesday that also noted another probe of the bank is underway. The original deferred prosecution agreements, struck with the U.S. Justice Department and the Manhattan district attorney over the bank's violations related to U.S. sanctions on Iran and other countries, was due to expire on Wednesday. The agreement to extend the deals means that the bank will face enhanced oversight for a longer period of time and could be hit with harsher penalties. The deferred prosecutions could be pulled back in the next three years and criminal charges against the bank could be filed, said Joan Vollero, a spokeswoman for the Manhattan district attorney. In a statement, the bank said it agreed to the extension and would work with authorities to reach the standard required." (Reuters, "U.S. Extends Scrutiny of Standard Chartered on Sanctions Compliance," 12/9/14)

--

"U.S. authorities are investigating London-based Standard Chartered Plc for potential U.S. sanctions violations connected to its banking for Iranian-controlled entities in Dubai, according to people familiar with the probe. The latest investigation involving the bank is based, in part, from evidence that emerged during a separate probe of BNP Paribas, the French bank that pleaded guilty this summer to charges related to sanctions-busting and agreed to pay $8.9 billion in penalties, the people said. During the course of the BNP case, U.S. federal and state investigators received evidence the French bank had done business with a Dubai-registered corporation that was a front for an Iranian entity, one source said. Investigators also learned that the company used to have an account with Standard Chartered, according to the source. Such an account would have been covered by U.S. sanctions laws that ban dealings with Iran because activity in the account involved U.S. dollar transactions... Standard Chartered in 2012 paid $667 million to U.S. authorities and entered into deferred prosecution agreements with the Manhattan District Attorney and U.S. Department of Justice over violations stemming from Iran and other sanctioned countries." (Reuters, "Exclusive: U.S. probing Standard Chartered over Dubai banking - sources," 10/31/14)

--

“As part of talks in Geneva over the nuclear question, Tehran is pressing world powers to speed up trade finance arrangements on humanitarian deals involving both Western and Iranian banks, according to an Iranian government document seen by Reuters and sources familiar with the initiative. Iranian government officials and international trade sources say Tehran wants to simplify complex trade finance arrangements potentially worth billions of dollars, which would alleviate pressure on the country's sanctioned banking system…Iranian government officials said the document, which has been sent to Iran's Supreme National Security Council, tasked with safeguarding Tehran's interests, listed the following banks as ‘available for further actions’: Standard Chartered Bank (London), Societe Generale (Paris), Banque de Commerce et de Placements (BCP) (Geneva), UniCredit Bank(Munich), Commerzbank (Frankfurt), United Bank (Zurich) and BHF Bank (Frankfurt). It was not clear whether these banks had been approached to provide finance. Two business executives familiar with the initiative said they were aware that Standard Chartered, Societe Generale, Commerzbank were among those on the wish list. Commerzbank, Societe Generale, United Bank and BCP all declined to comment. A spokeswoman for Standard Chartered said the bank was not involved and would not get involved in any transaction with any party from Iran.” (Reuters, “Western banks cold-shoulder Iran trade finance scheme,” 3/13/14)

--

"Standard Chartered Chairman John Peace apologized on Thursday for inaccurate comments he made earlier this month about his bank breaching U.S. sanctions over Iran. The highly unusual retraction indicated U.S. regulators had put pressure on the bank to clarify the comments following a high-profile settlement last year which cost Standard Chartered $667 million. The London-based bank agreed to deferred prosecution agreements with the U.S. Department of Justice and District Attorney of New York as part of the settlement. Peace said on March 5 at a press conference with reporters that Standard Chartered 'had no willful act to avoid sanctions'. But in a statement on Thursday, he said those comments were 'both legally and factually incorrect' and he retracted them. He said they directly contradicted the bank's acceptance of responsibility. 'To be clear, Standard Chartered Bank unequivocally acknowledges and accepts responsibility ... for past knowing and willful criminal conduct in violating U.S. economic sanctions laws and regulations,' Peace said in the statement. He said he 'very much' regretted his earlier comments, which 'were at best inaccurate.'" (Reuters, "Standard Chartered says it made false comments on sanction breaches," 3/21/13)

--

"Standard Chartered Plc agreed to pay $327 million to resolve allegations that it violated U.S. sanctions against Iran, Sudan and two other countries, capping months of legal headaches for the British bank. The U.S. Justice Department and the New York District Attorney's office said on Monday the bank moved millions of dollars through the U.S. banking system on behalf of customers in the four sanctioned countries. The fine came on top of a separate payment of $340 million made in August by Standard Chartered to New York's state banking regulator over Iranian sanctions. Taken together, the two penalties could almost wipe out the bank's profit growth this year. Nevertheless, its shares nudged higher after Monday's announcement, which was in line with payment provisions the bank disclosed last week." (Reuters, "Standard Chartered to pay $327 million in U.S. sanctions case," 12/10/12)

--

"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 . . . Standard Chartered has said it expects to pay about $330 million to settle claims by federal regulators that its money- clearing operations violated rules related to U.S. sanctions against Iran. The London-based bank agreed in August to pay $340 million to resolve charges brought by New York’s banking regulator that it hid the identity of Iranian customers involved in dollar-clearing transactions." (Bloomberg News, "HSBC, Standard Chartered Close to Resolving Iran Claims," 12/8/12)

--

"Standard Chartered expects to pay $330 million to settle a case with U.S. regulators who accused the Asia-focused bank of failing to comply with sanctions against Iran, further denting profit growth this year. The settlement will be on top of the $340 million it paid to New York's Department of Financial Services in the third quarter, which pushed its before tax profit growth in 2012 to a mid-single-digit percentage from more than 10 percent, StanChart said in a statement on Thursday... Standard Chartered said it expected talks with U.S. Federal regulators to conclude shortly, confirming a Reuters report earlier in November." (Reuters, "Standard Chartered sees $330 million Iran fine, profit hit,"12/6/12)

--

"Standard Chartered said it was aiming for a wider year-end settlement with U.S. authorities investigating its Iran-linked transactions... Standard Chartered, which is negotiating with the Manhattan District Attorney, the U.S. Treasury Department, the Justice Department and the New York Federal Reserve, said last month it could not predict the outcome or quantify potential liabilities...Standard Chartered was bogged down by rising costs in much of 2010 and 2011 as it expanded across Asia. Standard Chartered is one of few still expanding its headcount, which totalled about 85,000 at end-June... Weighing on Standard Chartered's earnings was weakness in India, Singapore's wholesale banking and South Korea's consumer banking, it said... Antos said he expects analysts to revise down Standard Chartered's full-year earnings forecast by another 5-10 percent, given the external headwinds. Despite the slowdown, Standard Chartered said it reduced the amount of money put aside in case of bad loans - its impairment charge - by tens of millions of dollars. In the first half, the bank set aside $583 million for impairment charges. A $1 billion loan Standard Chartered made to the Indonesian chairman of London-listed coal miner Bumi Plc - which is probing alleged financial irregularities at its Indonesian units - triggered some concern over the bank's asset quality and lending practices. Standard Chartered shares were down 0.6 percent in London, lagging a 1.1 percent gain in the European bank index." (Reuters, "Standard Chartered eyes wider Iran settlement by year end," 10/30/12)

--

"Minutes after New York State’s Department of Financial Services announced a $340 million settlement with British bank Standard Chartered for doing business in Iran, the main lobby group pushing for increased sanctions against anyone doing business with the Islamic Republic issued a statement of its own on Tuesday. Former U.S. Ambassador to the United Nations Mark Wallace, CEO of United Against a Nuclear Iran, said 'given the reports of Standard Chartered’s egregious actions the penalty should have been more severe.' Benjamin Lawsky, the head of New York’s Department of Financial Services accused Standard Chartered of conducting '60,000 secret transactions, involving at least $250 billion and reaping millions of dollars in fees' from its Iranian business ties. The New York DFS also said executives at Standard Chartered lied to them about their dealings with Iran... 'This is no time for a slap on the wrist,' he said. 'We think they should get the equivalent of the financial death penalty — meaning losing their license to do business in the United States and New York.' Wallace and his group are calling for a 'complete and total economic blockade of Iran.' Standard Chartered’s records indicate the bank had operating income of $17 billion dollars in 2011. Critics of settlements with other banks and businesses in similar cases claim millions in fines for companies making billions of dollars isn’t the right message to send. Many members of congress and in the diplomatic community have been arguing companies like Standard Chartered should be forced to make a choice: Do business in the United States or in Iran, but not in both. It’s still unclear if Standard Chartered will have to deal with federal consequences as well." (CNBC, "Standard Chartered's Penalty Not Severe Enough: Fmr. Ambassador," 8/14/12)

"Standard Chartered has settled allegations that it helped Iranian clients dodge US sanctions, announcing a fine of $340 million from a New York Banking watchdog... Standard Chartered CEO Peter Sands was in New York at the time the deal was struck. New York state's Department of Financial Services had questioned whether Standard Chartered should lose its banking license, effectively cutting off access to the US market. 'Standard Chartered had offered to settle for $5 million, so (it is) clearly an increase,' said Morningstar analyst Erin Davis... But Standard Chartered remains in the sights of other US regulators... 'Our investigation continues. Treasury will continue working with our regulatory and law enforcement partners to hold Standard Chartered accountable for any sanctionable activity that occured,' an official said... Standard Chartered hinted that settlements may also be reached with those agencies, saying 'the timing of any resolution will be communicated in due course.' The 'United Against Nuclear Iran' lobby group said New York authorities had been to lenient, and federal investigators should not make the same mistake. 'Any financial institution that is found to be in violation of Iran sanctions should receive the financial equivalent of the death penalty and lose its license to do business in the United States,' the group said in a statement." (AFP, "Standard Chartered fined $350 mn over Iran deals," 8/14/12) 

--

"New York’s financial-services regulator has grounds to shut Standard Chartered Plc (STAN) in the state even if he accepts the firm’s argument that it illegally laundered only a fraction of the $250 billion he claims.

As the state’s top banking regulator, Benjamin Lawsky has power to act in his discretion against any financial institution he deems untrustworthy, according to the charter of his year-old department.

Penalties he could impose include fines and the revocation of the bank’s license to operate in the state. Lawsky is said to be considering a settlement figure as high as $700 million, according to person familiar with the case. That would match the amount HSBC Holdings Plc set aside last month to resolve allegations of similar behavior.

Since the Aug. 6 issuance of an order from Lawsky’s Department of Financial Services threatened to revoke Standard Chartered’s license, the bank has focused its defense on the amount it laundered, saying it involved less than one percent of the 60,000 Iranian wire transfers asserted by Lawsky.

Even if Standard Chartered’s position is legally sound, the order’s disclosure of internal e-mails suggesting a conspiracy to hide the identity of Iranian clients from regulators has given Lawsky grounds to act when the two sides face off at an administrative hearing Aug. 15, according to experts on both sides of the Atlantic.

'I don’t care whether it is a half of one percent that weren’t right,' said Arthur Levitt, former chairman of the Securities and Exchange Commission, in an interview yesterday on Bloomberg Radio…Standard Chartered’s apparent effort to conceal the identity of its Iranian counterparties violated the terms of a 2004 settlement between it and the state of New York, in which the London bank pledged 'to ensure compliance with all record keeping and reporting requirements,' according to the order.

For almost a decade starting in 2001, Standard Chartered operated under what Lawsky’s order called a 'deceptive business plan' designed to conceal from regulators that it was processing money transfers for Iranian clients, including the central bank’s U.S. dollar transactions related to oil sales. The order cites bank e-mails and other internal documents to support its accusations…In addition to evading federal controls, Standard Chartered covered up its plan to grab market share in the Iranian funds market by falsifying business records, making false statements to the department, maintaining inaccurate books, obstructing department oversight and failing to report misconduct promptly, according to the order.

The bank stripped out references to Iranian clients in directions for Society of Worldwide Interbank Financial Telecommunications (SWIFT) wire payments made in U.S. dollars through its New York branch, according to the order.

The bank’s outside legal counsel advised that this system was not in compliance with U.S. economic sanctions and that the New York branch needed to be able to verify that transfers were permissible, according to the order…Accusing the bank of 'being motivated by greed,' the department’s order concludes that Standard Chartered’s 'most senior management designed and implemented an elaborate scheme by which to use its New York branch as a front for prohibited dealngs with Iran -- dealings that indisputably help sustain a global threat to peace and stability. By definition, any banking institution that engages in such conduct is unsafe and unsound.'" (Bloomberg, "Standard Chartered’s Fitness Is Key Grounds for Shutdown," 8/10/12)

 --

"The U.S. Treasury told the British government on Wednesday that it takes financial sanctions violations 'extremely seriously' and is coordinating with federal and state agencies in an investigation of the UK's Standard Chartered bank.

Adam Szubin, director of Treasury's Office of Foreign Assets Control, told the British Treasury in a letter obtained by Reuters that his office is investigating the bank for 'potential Iran-related violations as well as a broader set of potential sanctions violations.'

The letter, dated August 8, was in response to a British request for clarification of U.S. sanctions laws and comes after New York State authorities alleged that Standard Chartered hid $250 billion of Iranian banking transactions, in violation of U.S. law.

Szubin told British authorities that in 2008 the Treasury Department outlawed the so-called U-turn transaction license - licenses the New York banking regulator accused Standard Chartered of using to evade sanctions.

The New York State Department of Financial Services order alleged that even as some banks exited the U-turn transactions, Standard Chartered hustled to 'take the abandoned market share.'" (Reuters, "U.S. Treasury tells UK it is probing Standard Chartered," 8/8/12)

--

"Standard Chartered Plc (STAN) fell the most in almost 24 years as an analyst estimated it may face costs of $5.5 billion after being accused of violating U.S. money laundering laws over its dealings with Iranian banks. The shares fell 16 percent to 1,228.5 pence in London trading, their biggest decline since 1988, the earliest date for which data are available. Standard Chartered may lose its license to operate in New York after the state’s Department of Financial Services found the bank conducted $250 billion of deals with Iranian banks over seven years and earned hundreds of millions of dollars in fees for handling transactions for institutions subject to U.S. economic sanctions. The London-based lender today denied the allegations, saying it 'strongly rejects the position and portrayal of facts' made by the regulator. The bank may be fined $1.5 billion by U.S. regulators, lose about $1 billion of revenue from its Iranian operation and a further $3 billion in market value if senior managers quit, Cormac Leech, an analyst at London-based Liberum Capital Ltd. who rates the stock a buy, wrote in a note to investors today . . . While Standard Chartered doesn’t have any domestic U.S. banking operations, the loss of the New York license would hinder its ability to process dollar payments for clients with businesses in the U.S. and in emerging markets, said Gary Greenwood, an analyst at Shore Capital in Liverpool, who rates the stock a buy. Pretax profit from Standard Chartered’s U.S., U.K. and European unit increased 90 percent in the first half to about $464 million, for about 12 percent of the bank’s total." (Bloomberg, "Standard Chartered Falls Most In 24 Years On Iran Probe," 8/7/12)

--

"A New York bank regulator’s broadside against Standard Chartered Plc for allegedly hiding US$250-billion in transactions tied to Iran left investors and the bank questioning the motive for the ambush, which wiped US$17-billion off its value. London-based Standard Chartered hit back at the New York State Department of Financial Services (DFS) threat to tear up its state banking licence on Tuesday, dismissing the charge that it was a 'rogue institution' that 'schemed' with the Iranian government as a distortion of the facts. Bank insiders were as shocked as investors by the ferocity of the DFS accusations over its involvement with Iran, which is subject to U.S. sanctions over its nuclear program . . . The U.S. agency said Standard Chartered hid 60,000 secret transactions to generate hundreds of millions of dollars in fees over nearly 10 years. Shares in Standard Chartered closed down 16.4% at 12.28 pounds, taking their losses to 24% since the news surfaced just before Monday’s close. They had earlier slumped as low as 10.92, their lowest for three years." (Reuters, "Iran accusations wipe US$17-billion off Standard Chartered shares," 8/7/12)

--

"Standard Chartered, the British bank accused of covering up billions of dollars of sanctions-busting transactions with Iran, has come out fighting against the allegations . . . There were no excuses from Standard Chartered, however, on Monday after the New York State Department of Financial Services claimed that the bank’s alleged illicit dealings had left the U.S. financial system 'vulnerable to terrorists, weapons dealers, drug kingpins and corrupt regimes' . . . Standard Chartered was itself among the targets of a 'name and shame' campaign by United Against Nuclear Iran (U.A.N.I.), a non-profit group headed by Mark Wallace, a former U.S. ambassador to the United Nations. U.A.N.I., which gave Standard Chartered a clean bill of health in May after it pulled out of Iran, returned to the attack on Monday by saying the penalties the bank now faced in the light of the latest allegations 'should serve as notice to all entities and financial institutions that they will be held accountable for their business with such an unscrupulous regime.' The pro-sanctions lobby can certainly argue that the measures against Iran are having an impact. The Iranian currency, the rial, is in free fall as the country braces for a fresh devaluation brought on by the economic restrictions . . . Leon Panetta, the American Secretary of Defense, has insisted sanctions against Iran were working, even if 'the results of that may not be obvious at the moment.'" (New York Times, "British Bank Fights U.S. Charges of Dealing With Iran," 8/7/12)

--

"A British bank schemed with the Iranian government to launder $250 billion from 2001 to 2007, leaving the United States' financial system 'vulnerable to terrorists,' New York's financial regulator charged Monday. State Financial Services Superintendent Benjamin Lawsky signed an order that requires London-based Standard Chartered Bank to answer his questions following an investigation into "wire stripping," the practice of removing crucial identifiers in financial transactions. The state agency called the bank a rogue institution and quoted one of its executives as saying: 'You (expletive) Americans. Who are you to tell us, the rest of the world, that we're not going to deal with Iranians.' The bank conspired with its Iranian clients to route nearly 60,000 different U.S. dollar payments through Standard Chartered's New York branch 'after first stripping information from wire transfer messages used to identify sanctioned countries, individuals and entities,' according to agency's order. The order said the transactions provided the bank with millions of dollars in fees at a time when such trade was restricted . . . If proven, the scheme would violate state money-laundering laws. The order also accuses the bank of falsifying business records, obstructing governmental administration, failing to report misconduct to the state quickly, evading federal sanctions and other illegal acts." (Associated Press, "Standard Chartered Bank Accused Of Scheming With Iran To Launder $250 Billion," 8/6/12)  

--

"Standard Chartered PLC has pulled out of Iran after decades of having a presence, the latest bank to exit the lucrative market amid mounting international pressure. The departure of the bank comes as sanctions have forced most western banks to sever or downgrade ties with Iran. Though Standard Chartered had signaled in 2007 it would stop taking any new business in the Islamic Republic after coming under U.S. pressure, it had continued to retain offices in Tehran and on the island of Kish... Kristen Silverberg, the newly appointed president of New York-based pressure group United Against Nuclear Iran, welcomed Standard Chartered's decision to end its business in Iran. 'We call on other banks around the world to follow Standard Chartered by pulling out of Iran, and completely cut off the regime's access to international markets,' said Ms Silverberg, a former U.S. ambassador to the European Union." (The Wall Street Journal, "UK Bank Standard Chartered Exits Iran Amid International Pressure," 5/10/12) 

--

Its Middle East division has a contact listing for its Tehran office (Company Website), and a Middle Eastern development brochure extensively discusses the Iranian economy (Brochure). Business Monitor International notes that "Standard Chartered Bank (Iran) provides international correspondent banking services to Iranian banks and corporate customers around the world. Standard Chartered specialises in structuring trade transactions involving customers and Iranian counterparties" (Business Monitor International - subscription needed).

Wincor Nixdorf, according to its website, is one of the world’s leading providers of IT solutions and services to retailers and retail banks.  Their IT solutions "help boost process efficiency in banking and retail industries High levels of availability and quality Solutions for cost-efficient operation of IT systems Banking."

The company has subsidiaries in over 41 countries and has an overall market presence in over 100 countries. (Company Website)

--

Wincor Nixdorf is listed on the website of Iranian company Informatics Services Corporation (ICS) as a business partner (ICS Company Website).  Likewise, WN lists ICS as one of its banking partners on its own website.  (Company Website) 

--

The company's policy on "Social Corporate Responsibiliy" is as follows:

“Success …depends on…achieving a balance between economic, environmental and social objectives – one that is indispensable if we wish to enjoy the confidence of the public over the long term.”  The policy also cites three key values: Caring for the environment, Focus on people, and Social responsibility.  (Company Website)

According to its Annual Report filed with the SEC: In 2019, the following activities are disclosed in response to Section 13(r) with respect to Santander UK and certain other affiliates of Santander (collectively, the Group). During the period covered by this report:

• Santander UK holds two savings accounts and one current account for two customers resident in the U.K. who are currently designated by the U.S. under the Specially Designated Global Terrorist (SDGT) sanctions program. Revenues and profits generated by Santander U.K. on these accounts in the three months ended March 31, 2019 were negligible relative to the overall profits of Santander.
• Santander UK held one savings account and one current account for another customer resident in the UK who is currently designated by the US under the SDGT sanctions program. The United Nations and European Union removed this customer from their equivalent sanctions lists in 2008. The customer relationship predated the designations of the customer under these sanctions. Santander UK determined to put a block on the accounts and the accounts were closed on January 14, 2019. Revenues and profits generated by Santander UK on these accounts in the three months ended March 31, 2019 were negligible relative to the overall profits of Santander.
• Santander UK holds two frozen current accounts for two U.K. nationals who are designated by the U.S. under the SDGT sanctions program. The accounts held by each customer have been frozen since their designation and have remained frozen through the three months ended March 31, 2019. The accounts are in arrears (£1,844.73 in debit combined) and are currently being managed by Santander UK Collections & Recoveries department. No revenues or profits were generated by Santander UK on these accounts during the three months ended March 31, 2019.

The Santander Group has undertaken significant steps to withdraw from the Iranian market such as closing its representative office in Iran and ceasing all banking activities therein, including correspondent relationships, deposit taking from Iranian entities and issuing export letters of credit, except for the legacy transactions described above. The Santander Group is not contractually permitted to cancel these arrangements without either (i) paying the guaranteed amount (in the case of the performance guarantees), or (ii) forfeiting the outstanding amounts due to it (in the case of the export credits). As such, the Santander Group intends to continue to provide the guarantees and hold these assets in accordance with company policy and applicable laws.

--

SAMIH affiliate—Santander U.K. plc—held savings accounts for two SDNs during the year, even as it noted that SAMIH’s activity does not relate to any activity conducted by Laredo or Laredo’s affiliates. (SEC Disclosure)

--

Santander is "the third largest bank in the world in terms of profits." In 2008, the Santander Group acquired the US-based Sovereign Bank. (Company Website)

--

Banco Santander is also part of the Royal Bank of Scotland led consortium that owns ABN AMRO, which reportedly has done business with Iran. (ABN AMRO Company Website)

--

"In July 2007, it was reported that Santander “was doing business with Teheran-based Sepah as recently as March [2007]… Trading with businesses that are blacklisted for alleged links to terrorism is a serious breach of US law and can have draconian consequences...Santander is thought to have opened accounts for Sepah in various European countries and in Teheran. Allegations have also been made that Santander had a banking relationship with another Iranian bank that the US is targeting for its alleged links to terrorists. Santander said: ‘Neither of these institutions has an open account with Santander.’ The Spanish bank appears to have ended its relationship with Sepah after March. No details are known about the nature of its contact with the other bank.

Santander said: ‘Banco Santander is confident that it complies with all relevant banking regulations in the territories in which it operates, and with international requirements placed on banks, including those concerning money-laundering and the financing of terrorism.’ Sepah, which is owned by the Iranian state, was placed on the US blacklist in January. At the time, Stuart Levey, under-secretary for terrorism and financial intelligence, said: ‘Sepah is the financial linchpin of Iran's missile procurement network and has actively assisted Iran's pursuit of missiles capable of carrying weapons of mass destruction.’" (The Daily Telegraph, "Santander Traded with Blacklist Iranian Bank," 7/23/07)

Sovereign Bank is a subsidiary of Banco Santander, "the third largest bank in the world in terms of profits." (Santander Company Website)

--

Banco Santander is also part of the Royal Bank of Scotland led consortium that owns ABN AMRO, which reportedly has done business with Iran. (ABN AMRO Company Website)

--

• "In July 2007, it was reported that Santander “was doing business with Teheran-based Sepah as recently as March [2007]… Trading with businesses that are blacklisted for alleged links to terrorism is a serious breach of US law and can have draconian consequences... Santander is thought to have opened accounts for Sepah in various European countries and in Teheran. Allegations have also been made that Santander had a banking relationship with another Iranian bank that the US is targeting for its alleged links to terrorists. Santander said: ‘Neither of these institutions has an open account with Santander.’ The Spanish bank appears to have ended its relationship with Sepah after March. No details are known about the nature of its contact with the other bank. Santander said: ‘Banco Santander is confident that it complies with all relevant banking regulations in the territories in which it operates, and with international requirements placed on banks, including those concerning money-laundering and the financing of terrorism.’ Sepah, which is owned by the Iranian state, was placed on the US blacklist in January. At the time, Stuart Levey, under-secretary for terrorism and financial intelligence, said: ‘Sepah is the financial linchpin of Iran's missile procurement network and has actively assisted Iran's pursuit of missiles capable of carrying weapons of mass destruction.’" (The Daily Telegraph, "Santander Traded with Blacklist Iranian Bank," 7/23/07)

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. 

--

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."

--

"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."

--

"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).

--

"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)

--

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.

--

"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)

--

"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)

--

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)