Banking

ABN AMRO is currently owned by the Royal Bank of Scotland Group.

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On its website, ABN AMRO states that it "has a stricter policy regarding trade with the countries below [including Iran]. Are you trading or are you going to trade with one of these countries? Then we ask you to always contact the bank in advance. We can then inform you about the (im)possibilities to carry out transactions for you. You limit the risk that we will not execute your transaction on the basis of legal or internal provisions. Regularly check the ABN AMRO website and the authorities such as the UN, EU and US. You will then be sure that you have the most up-to-date information."

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"Dutch bank ABN AMRO ABNd.AS said it had facilitated transactions [with Iran] related to food, healthcare, medical equipment and agriculture to a limited extent and with specific clients. But it also told Reuters 'the recent restrictive measures on Iranian banks do pose challenges.'" (Reuters, "Global traders halt new Iran food deals as U.S. sanctions bite - sources," 12/21/18)

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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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"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 Independent, “UK banks caught in Iran sanctions probe,” 2/5/06)

"An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Pioneer Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

According to its Iran Notice filed with the SEC for fiscal year 2019: UBS has a Group Sanctions Policy that prohibits transactions involving sanctioned countries, including Iran, and sanctioned individuals and entities. However, UBS maintains one account involving the Iranian government under the auspices of the United Nations in Geneva after agreeing with the Swiss government that it would do so only under certain conditions. These conditions include that payments involving the account must: (1) be made within Switzerland; (2) be consistent with paying rent, salaries, telephone and other expenses necessary for its operations in Geneva; and (3) not involve any Specially designated Nationals blocked or otherwise restricted under U.S. or Swiss law. In 2017, the gross revenues for this UN related account were approximately USD 15,580. UBS AG does not allocate expenses to specific client accounts in a way that tables it to calculate net profits with respect to any individual account. UBS AG intends to continue maintaining this account pursuant to the conditions it has established and consistent with the conditions it has established with the Swiss Government and its Group Sanctions Policy. UBS also maintains a rental surety (effectively a rental security deposit) account in relation to the Government of Iran’s UN Mission premises in Geneva; there were no revenues associated with this account."

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UBS has a Group Sanctions Policy that prohibits transactions involving sanctioned countries, including Iran, and sanctioned individuals and entities. However, UBS maintains one account involving the Iranian government under the auspices of the United Nations in Geneva after agreeing with the Swiss government that it would do so only under certain conditions. These conditions include that payments involving the account must: (1) be made within Switzerland; (2) be consistent with paying rent, salaries, telephone and other expenses necessary for its operations in Geneva; and (3) not involve any Specially Designated Nationals (SDNs) blocked or otherwise restricted under U.S. or Swiss law. In 2017, the gross revenues for this UN-related account were approximately USD 15,580.  We do not allocate expenses to specific client accounts in a way that enables us to calculate net profits with respect to any individual account.  UBS AG intends to continue maintaining this account pursuant to the conditions it has established with the Swiss Government and consistent with its Group Sanctions Policy. UBS also maintains a rental surety (effectively a rental security deposit) account in relation to the Government of Iran's UN Mission premises in Geneva; there were no revenues for this account.

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"When it comes to U.S. sanctions on Iran, no detail is too small to overlook these days. Since February, publicly traded companies have filed nearly 500 disclosure forms about their business ties to Iran…On Nov. 8, banking giant UBS said it had arranged trade financing for Swiss exporters involving four Iranian banks allegedly taking part in deals related to weapons of mass destruction. The bank said in its public filing that there had been no transactions since February 2012 but that it still maintained 'one existing account relationship' with one of the Iranian banks." (Washington Post, "Under new law, companies disclosing even tiniest dealings with Iran," 12/4/13)

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"In 2004 UBS, a Swiss bank, paid a $100m fine (without admitting any liability) for providing new banknotes to Cuba and Iran." (The Economist. "Patchy blockade; Cuba and the United States," 8/16/08)

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"US victims of attacks in Israel and their families are suing Swiss bank UBS for 500 million dollars, alleging it financed terrorism by doing business with Iran, their lawyer told AFP Tuesday." (AFP. "US families sue UBS over alleged terror links," 5/13/08)

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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," January 7, 2007) "Since January three European banks - UBS, Credit Suisse and ABN Amro - have curtailed their activities in Iran. The banks said that their decisions to cut back had been business ones." (The London Times, "American pressure threatens UK firms," May 27, 2006)

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UBS will no longer deal with individuals, companies or state institutions such as Iran's central bank, said company spokesman Serge Steiner. A similar policy is also being implemented in the case of Syria, he said.

All existing business with customers in Iran will be canceled, but Iranians in exile are not affected by the decision, Steiner said, confirming an article in Swiss weekly SonntagsZeitung.

"It is a carefully prepared measure that has been under consideration since last fall," Steiner said.

Iran, under increasing international pressure over its nuclear program — and mindful of the freezing of its U.S. assets after the 1979 seizure of the American Embassy in Tehran — has already begun transferring its reserves from European banks to an undisclosed location.

Steiner declined to specify the volume of business affected by the bank's decision. (Fox News. "UBS Halts Business with Iran," 1/22/06)

“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)

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"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 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)

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“The broader banking sanctions still in place [under the interim deal] are creating some ambiguities. The senior banker said Iranian authorities told businessmen that seven European banks including Commerzbank and Société Générale had been designated to transfer the $4.2bn in blocked funds but 'some kind of dilemma' remained over which Iranian banks could receive the money as most are affected by the broader banking sanctions still in place.” (Financial Times, “Easing of sanctions raises hopes for Iranian economy,” 1/19/14)

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“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)

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"Societe Generale SA, France's second-largest bank by market value, is cooperating with U.S. authorities looking into dollar transfers for clients in countries targeted by American economic sanctions. 'Societe Generale has started discussions with the Office of Foreign Assets Control,' the Paris-based bank said in its annual report today, without naming the clients or countries involved. The bank said it has begun an internal audit." (Bloomberg, "SocGen Cooperating With U.S. Authorities on Dollar Transfers, 3/7/13)

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"Top-tier financial institutions including Societe Generale SA GLE.FR -0.74% and Rabobank Group have stepped back from business with Iran in recent months, citing increased political risk and logistical hassles that attend even legal trade with the country... In response, Rabobank and Société Générale say they have stopped servicing Iran deals or curbed their trade finance." (The Wall Street Journal, "Willing Banks Find Profits in Legal Trade With Iran," 4/8/2012)

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"Present in Iran since 1974, our rep office in Tehran is primarily active in trade and export finance." (Company website)

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"Societe Generale has done business in Iran since 1974. Spokesman Jim Galvin said the office in Tehran continues to be active in trade and export finance." From 2000-2009, the company was a recipient of $1.4 million US federal funds.  They currently have active business investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"The major French banks -- BNP Paribas, Calyon and Societe Generale -- have all stopped doing business with Tehran , while Total has frozen plans to invest in gas and LNG at the urging of its government." (Energy Compass, "Iran: Charm Mission," May 16, 2008)

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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", 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)

"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)

According to its Annual Report filed with the SEC for fiscal year 2019: "We had a representative office in Tehran, Iran, which we discontinued on December 31, 2007. Our remaining business with Iranian counterparties consisted mostly of participations as lender and/or agent in a few large trade finance facilities arranged before 2007 to finance the export contracts of exporters in Europe and Asia. As of December 31, 2018, those loans were fully paid back, subsequently the majority of the remaining Iranian business consists of legacy contractual obligations related to guarantees. We do not believe our business activities with Iranian counterparties are or had been material to our overall business, with the aforementioned guarantees having notional amounts of substantially less than 0.01 % of our total assets over recent years. As of December 31, 2019, the revenues from such activities represented substantially less than 0.01 % of our total revenues for the year ended December 31, 2019.

Payments Executed. Deutsche Bank continuous to severely restrict its policy on Iran and consequently the execution of such payments.

Incoming Payments. In 2019, we received 10 payments adding up to approximately € 2.0 million in favor of non-Iranian clients of which the majority were channeled through Iranian intermediary banks. Revenues for these incoming payments were less than € 100. These figures include relevant transactions for Iranian Embassy-related offices not included in the section on Iranian Consulates and Embassies below and in favor of our non-Iranian clients.

Outgoing Payments. In 2019, we executed 1 payment with an amount of € 100, in favor of an Iranian Embassy-related office not included in the section on Iranian Consulates and Embassies below. Revenues for this outgoing payment were less than € 10.

Operations of Iranian Bank Branches and Subsidiaries in Germany. Several Iranian banks, including Bank Melli Iran, Bank Saderat, Bank Sepah, and Europäisch-Iranische Handelsbank, have branches or offices in Germany, even though their funds and other economic resources had been frozen earlier under European law. As part of the payment clearing system in Germany and other European countries, when these branches or offices needed to make payments in Germany or Europe to cover their day-to-day operations such as rent, taxes, insurance premia and salaries for their remaining staff, or for any other kind of banking-related operations, fund transfers from these Iranian banks had been accepted through Target2.

In 2019, we executed approximately € 4.2 million in (almost only in-coming) transfers through Target2 across approximately 900 transactions and credited the relevant amounts to our non-Iranian clients. The gross revenues derived from these payments were approximately € 4,500."

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"Germany’s Deutsche Bank passed a new financial policy on Wednesday which will prevent any money transfer to Iran in cash." (8/2/2018)

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"Iran says Germany’s Deutsche Bank has started to provide financial services related to the country’s oil trade – an announcement that could show the ice in doing business with the Islamic Republic in a post-sanctions era is already thawing. Iran’s Deputy Petroleum Minister for International Affairs Amir-Hossein Zamaninia was quoted by domestic media as saying that the new phase of cooperation between Deutsche Bank and Iran had started last week after a halt of about 10 years. Zamaninia added that Iran expects to see several other major European banks to follow suit and resume cooperation with the country over its oil-related financial transactions. “Previously, merely certain small European banks were ready to cooperate with Iran over its oil-related transactions,” the official told Mehr News Agency. Still, a larger number of European banks – particularly major ones – are today approaching Iran, he added. Zamaninia further emphasized that several important European banks are set to start providing services to Iran “within the next few days.” (Press TV, "Iran, Deutsche Bank resume oil partnership," 10/24/2016).

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On October 23, 2016, Iranian press, in quotes attributed to Iran’s Deputy Petroleum Minister for International Affairs Amir-Hossein Zamaninia, had reported a “new phase of cooperation between Deutsche Bank and Iran had started last week after a halt of 10 years.” (Press TV (Tehran), “Iran, Deutsche bank resume oil partnership,” 10/23/2016).

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"Deutsche Bank is bracing for more than 300 million euros (256 million pounds) in charges linked to suspected violations of U.S. sanctions on Iran, a German weekly reported on Sunday. Deutsche Bank, Europe's biggest bank by assets, on Wednesday increased its provisions for litigation by 600 million euros to 2.4 billion euros, citing mortgage-related lawsuits and other regulatory investigations... Deutsche Bank on Wednesday declined to lay out in detail why it had increased provisions. On Sunday, it would not comment on the magazine report... Der Spiegel said that apart from the Iran probe, Deutsche Bank's 2.4-billion-euro legal provisioning included 500 million for a probe of suspected manipulation of interbank lending rates. Several sources familiar with the investigation told Reuters on Thursday that German markets watchdog Bafin is set to rebuke Deutsche Bank over how it supervised its contribution to the setting of the lending rates." (Reuters, "Deutsche Bank braced for £256 million Iran sanctions charges - report," 3/24/2013)

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"Federal and state prosecutors are investigating Deutsche Bank and several other global banks over accusations that they funneled billions of dollars through their American branches for Iran, Sudan and other sanctioned nations, according to law enforcement officials with knowledge of the cases . . . The Deutsche Bank investigation is the latest in a series of cases against global financial firms since 2009 that suggests the practice of transferring money on behalf of Iranian banks and corporations flourished under a loophole in United States policy that ended in 2008. A spokesman for Deutsche Bank declined to comment, but noted that the German bank decided in 2007 that it would “not engage in new business with counterparties in countries such as Iran, Syria, Sudan and North Korea and to exit existing business to the extent legally possible . . . The investigation into Deutsche Bank is still in its very early stages, according to the law enforcement officials. So far, there is no suspicion that the bank moved money on behalf of Iranian clients through its American operations after 2008, the officials said.” (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"President Barack Obama signed into law new sanctions on Iran that, for the first time, will bar from the American market foreign companies that work with Iranian businesses charged with aiding Tehran's nuclear program and the suppression of democracy.

Among those that could face legal challenges and fines are Japan's Big Three banks—Mitsubishi UFJ Financial Group Inc., Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc.—as well as European firms such as Commerzbank Bank AG and Deutsche Bank AG, all of whom have businesses inside Iran.

A Deutsche Bank spokesman said most of its existing contracts in Iran have durations of more than 10 years and the bank is legally obligated to fulfill them.

A recent report by Avi Jorisch, a former Treasury Department intelligence official, details how the Big Three Japanese banks, Deutsche Bank and Commerzbank continue to maintain bank accounts for Bank Sepah, Iran's oldest financial institution.

Bank Sepah has been blacklisted by both the U.N. and the U.S. in recent years for its alleged role in assisting Tehran's development of weapons of mass destruction.

Ronald Weichert, the spokesman for Deutsche Bank, said the bank is or has been 'engaged in a limited amount of business with counterparties, including government-owned or controlled counterparties, in certain countries which the U.S. State Department has designated as state sponsors of terrorism, including Iran.'

He said the bank's 'existing business with Iranian counterparties consists mostly' of participation 'as lender and/or agent in a few large trade finance facilities arranged some years ago to finance the export contracts of exporters in Europe and Asia.'" (Wall Street Journal, "U.S. Adds Its Own Sanctions on Iran," 7/2/2010)

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"Deutsche Bank announced in July 2007 that it had cut all ties to Iran, saying that it had deemed its business there too time consuming and expensive. While the bank was operating in Iran, RREEF Alternative Investments, a global alternative investment management business of Deutsche Bank's Asset Management division, rented properties to the U.S. government." The Company has received $2.6 million from the US government for their investments in Iran during 2000-2009.  They have withdrawn their investments from Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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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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"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 Germanys Deutsche Bank and Commerzbank, Englands 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)

According to its 2019 Annual Report filed with the SEC: "During 2019, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and related to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible."

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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." (3/29/2019)

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As stated in its 2018 form filed with the SEC: "During 2018, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and related to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law and is performed with the consent of Swiss authorities, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible. Credit Suisse AG also continued to hold funds from two wire transfers to non-Iranian customers which were blocked pursuant to Swiss sanctions laws because Iranian government-owned entities had initiated the transfers. Such funds, in a total amount of EUR 4,460, were maintained in blocked accounts opened in accordance with Swiss sanctions laws and, in September 2018, released to the non-Iranian customers after Switzerland had lifted its sanctions against the relevant Iranian government-owned entities. Credit Suisse AG derived no revenues or profits from maintenance of these previously blocked accounts or the release of the funds."

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As stated in its 2017 20-F form filed with the SEC: “During 2016, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law and is performed with the consent of Swiss authorities, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible. Credit Suisse AG also continues to hold funds from two wire transfers to non-Iranian customers which were blocked pursuant to Swiss sanctions because Iranian government-owned entities have an interest in such transfers. Such funds are maintained in blocked accounts opened in accordance with Swiss sanctions requirements. Credit Suisse AG derives no revenues or profits from maintenance of these blocked accounts.”

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According to its Annual Report filed with the SEC for fiscal year 2014: "During 2014, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law and is performed with the consent of Swiss authorities, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible.
Credit Suisse AG also continues to hold funds from two wire transfers to non-Iranian customers which were blocked pursuant to Swiss sanctions because Iranian government-owned entities have an interest in such transfers. Such funds are maintained in blocked accounts opened in accordance with Swiss sanctions requirements. Credit Suisse AG derives no revenues or profits from maintenance of these blocked accounts."

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According to its Annual Report filed with the SEC for fiscal year 2013: "During 2013, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law and is performed with the consent of Swiss authorities, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible.
Credit Suisse AG also continues to hold funds from two wire transfers to non-Iranian customers which were blocked pursuant to Swiss sanctions because Iranian government-owned entities have an interest in such transfers. Such funds are maintained in blocked accounts opened in accordance with Swiss sanctions requirements. Credit Suisse AG derives no revenues or profits from maintenance of these blocked accounts."

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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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According to its Annual Report filed with the SEC for fiscal year 2012: "During 2012, Credit Suisse AG processed a small number of de minimis payments related to the operation of Iranian diplomatic missions in Switzerland and to fees for ministerial government functions such as issuing passports and visas. Processing these payments is permitted under Swiss law and is performed with the consent of Swiss authorities, and Credit Suisse AG intends to continue processing such payments. Revenues and profits from these activities are not calculated but would be negligible.

Credit Suisse AG also holds funds from two wire transfers to non-Iranian customers which were blocked pursuant to Swiss sanctions because Iranian government-owned entities have an interest in such transfers. Such funds are maintained in blocked accounts opened in accordance with Swiss sanctions requirements. Credit Suisse AG derives no revenues or profits from maintenance of these blocked accounts."

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"Credit Suisse AG agreed to pay $536 million in penalties to the United States and  New York State on Dec. 16, 2009  to settle charges that it violated sanctions by helping Iran and other countries secretly funnel hundreds of millions of dollars through American banks. According to the government, from 1995 through 2006, Credit Suisse branches removed information, such as customer names and bank names, from American-bound wire transfers that would have signaled that the money originated in Iran. Before exiting Iran and other countries under sanctions in 2006, the bank received some small contracts from the Departments of Veterans Affairs and Energy."  The company received $2 million from the US government for their business in Iran during 2000-2009.  They have withdrawn their business investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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They referred to banks with code names like “Iron” and “Wood.” Sometimes they just used initials.

For nearly two decades, employees of Credit Suisse, Switzerland’s second-largest bank after UBS, helped their clients in Iran and other countries avoid sanctions by concealing their identities when they did business with the United States, federal and New York State authorities said at separate news conferences on Wednesday. Credit Suisse ended the practicing of helping its clients skirt sanctions in 2006 and agreed to pay federal and state authorities $536 million to settle the charges.

“Credit Suisse abused its standing as a leader in international banking by intentionally processing these illegal payments through U.S. banks,” Robert M. Morgenthau, theManhattan district attorney, told reporters in his office. (The New York Times, "Credit Suisse Settles Inquiry Over Iran Sanctions," 12/17/09)

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"Credit Suisse is expected to pay a fine of $536 million to settle accusations by the United States government and New York State authorities that it violated sanctions by helping Iran and other countries secretly funnel hundreds of millions of dollars through American banks, people involved in the negotiations said Tuesday.

Investigators found that the bank, the second-largest in Switzerland, removed information from American-bound wire transfers that would have signaled that the money originated in Iranian banks, according to a law enforcement official briefed on the case.

Two of the organizations that Credit Suisse facilitated transactions for, the official said, were the Atomic Energy Organization of Iran and the Aerospace Industries Organization, both of which are designated as proliferators of weapons of mass destruction by the United States Office of Foreign Assets Control. Both are barred from doing business with the United States.

In a statement released Tuesday, Credit Suisse confirmed that it would most likely pay $536 million in a settlement. The release did not provide details about the case, other than to say that it involved dollar payments from 2002 through April 2007 for 'parties that are subject to U.S. economic sanctions.'

Credit Suisse said it began an internal investigation into the situation in December 2005 and had since changed its practices, including termination of all business with organizations that have been subject to sanctions by the Office of Foreign Assets Control, closing an office in Tehran and appointing a global sanctions compliance officer...

The authorities identified more than 7,000 illicit transactions that Credit Suisse facilitated, worth about $700 million, a law enforcement official said. Investigators found an additional $1.1 billion in transactions that had been manipulated, but they have not deemed them as violating sanctions in this case, the official said.

Investigators found that Credit Suisse’s employees violated both state and federal laws by falsifying outgoing dollar payment messages that involved Iran. The bank’s employees removed reference to Iran or its banks, a practice called stripping.

Not only did Credit Suisse employees strip the wire transfers, but they also advised the Iranian banks on how to format their transfers to avoid detection, according to the official. As a result, investigators say, Iranian banks like Bank Saderat and Bank Melli were able to use Credit Suisse to send more than a billion dollars through New York banks.

The Atomic Energy Organization is said to have ties with Iran’s nuclear weapons program, while Aerospace Industries works with long-range missiles, the authorities said. Law enforcement officials said they thought the organizations had been buying materials for their programs. The sellers, most of whom were outside the United States, wanted dollars, and so the money passed through Manhattan banks, law enforcement officials said." (The New York Times, "Iranian Dealings Lead to a Fine for Credit Suisse," 12/16/09)

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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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"Commerzbank AG, Germany's second-largest lender, will pay at least $1.4 billion to settle federal and state claims that it violated U.S. sanctions, a person briefed on the matter said. The settlement, part of a deferred-prosecution agreement that would also resolve a separate money-laundering matter, may come as soon as this month, said the person, who asked not to be identified because the discussions aren't public... The accord is the latest settlement with a global bank over dealings with blacklisted countries, including Iran and Sudan. In June, BNP Paribas SA pleaded guilty to violating U.S. sanctions laws and agreed to pay a record $8.9 billion to resolve the case." (Bloomberg, Commerzbank Said to Near $1.4 Billion U.S. Settlement, 3/5/15)

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"Commerzbank AG's expected settlement with authorities over alleged violations of U.S. sanctions and anti-money laundering laws is likely to exceed $1 billion (636.42 million pounds) in penalties, according to a person familiar with the probes. The settlement is still being negotiated, and a deal before the end of the year is unlikely, two sources said. Margarita Thiel, a spokeswoman for Commerzbank, Germany's second-largest lender, declined to comment. Commerzbank was close to an agreement in September with U.S. prosecutors and regulators over its dealings with Iran and other countries subject to U.S. sanctions, Reuters has reported, citing sources." (Reuters, "Commerzbank settlement with U.S. likely to exceed $1 billiion - source," 12/11/14)

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“German lender Commerzbank AG is expected to pay between $600 million and $800 million to resolve investigations into its dealings with Iran and other countries under U.S. sanctions, sources familiar with the matter said. The penalty, previously reported to be more than $500 million, includes a demand from New York's top banking regulator, Benjamin Lawsky, for more than $300 million from the bank, the sources said… Among the violations being investigated are Commerzbank's transactions for the Islamic Republic of Iran Shipping Lines, one of the sources said. The state-sponsored shipping company was designated for economic sanctions by the United States in 2008 for allegedly supporting Iran's proliferation of weapons of mass destruction. The source said Commerzbank was alleged to have done business with the company despite knowing that it was sanctioned.” (Reuters, "Exclusive: Commerzbank may pay $600 million-$800 million to settle U.S. probe - sources," 7/9/14)

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“State and federal authorities have begun settlement talks with Commerzbank, Germany’s second-largest lender, over the bank’s dealings with Iran and other countries blacklisted by the United States, according to people briefed on the matter. The bank, which is suspected of transferring money through its American operations on behalf of companies in Iran and Sudan, could strike a settlement deal with the state and federal authorities as soon as this summer, said the people briefed on the matter, who were not authorized to speak publicly… The contours of a settlement, which the authorities have only begun to sketch out, are expected to include at least $500 million in penalties for Commerzbank, the people added.” (New York Times, "U.S. Scrutiny for Banks Shifts to Commerzbank and Germany", 7/7/14)

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“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)

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“The broader banking sanctions still in place [under the interim deal] are creating some ambiguities. The senior banker said Iranian authorities told businessmen that seven European banks including Commerzbank and Société Générale had been designated to transfer the $4.2bn in blocked funds but 'some kind of dilemma' remained over which Iranian banks could receive the money as most are affected by the broader banking sanctions still in place.” (Financial Times, “Easing of sanctions raises hopes for Iranian economy,” 1/19/14)

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"Several other banks - including Deutsche Bank, Germany's second biggest lender Commerzbank, UniCredit's German unit HVB, and French banks BNP Paribas and Credit Agricole - have said they have received inquiries from U.S. authorities or are reviewing transactions to check whether they are potentially in breach of U.S. sanctions, suggesting any investigations are at an early stage." (Reuters, "Analysis: StanChart hit may not dog other banks as much as feared," 9/4/2012)

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"President Barack Obama signed into law new sanctions on Iran that, for the first time, will bar from the American market foreign companies that work with Iranian businesses charged with aiding Tehran's nuclear program and the suppression of democracy.

Among those that could face legal challenges and fines are Japan's Big Three banks—Mitsubishi UFJ Financial Group Inc., Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc.—as well as European firms such as Commerzbank Bank AG and Deutsche Bank AG, all of whom have businesses inside Iran.

A spokesman for Commerzbank declined to comment on the effect of the law, saying the bank wasn't familiar with its details. He said Commerzbank has been reducing its exposure to Iran since 2007.

A recent report by Avi Jorisch, a former Treasury Department intelligence official, details how the Big Three Japanese banks, Deutsche Bank and Commerzbank continue to maintain bank accounts for Bank Sepah, Iran's oldest financial institution.

Bank Sepah has been blacklisted by both the U.N. and the U.S. in recent years for its alleged role in assisting Tehran's development of weapons of mass destruction.

Spokesman Reiner Rossman declined to comment on any relationship Commerzbank had or has with Bank Sepah."

(Wall Street Journal, "U.S. Adds Its Own Sanctions on Iran," 7/2/2010)

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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 Irans energy sector. This effort has led such major firms as Germanys Deutsche Bank and Commerzbank, Englands 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 Irans 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: Germanys 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," 10/26/07

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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,"  5/27/06)

"New details about the U.S. sanctions-busting case against Huawei Technologies Co. emerged in court filings in Canada, including about the Chinese telecom giant’s alleged dealings in Iran, Syria and Sudan. The filings also detailed discussions Huawei held with Citigroup Inc. C +0.68% and BNP Paribas SA BNPQY +0.08% about its Iran business. The documents released Tuesday allege that Huawei also had discussions with two other banks, Citigroup and BNP, about its Iran business, following the publication by Reuters of articles in 2012 and 2013 alleging that Huawei sold U.S.-made computer equipment in Iran via Skycom in violation of U.S. sanctions. They allege that Huawei representatives—including the company’s treasurer and Ms. Meng—told Citigroup that the company was in compliance with all sanctions, according to a 2017 email described in the filings. They also describe a 2014 BNP document in which Huawei described Skycom as “one of the business partners of Huawei.” HSBC and Standard Chartered have cut business ties with Huawei, deeming working with the company too risky, The Wall Street Journal reported in December. As of the end of last year, Citigroup continued to provide day-to-day banking services with Huawei outside the U.S., the Journal reported. A spokesman for Citigroup declined to comment. A Standard Chartered spokeswoman and a BNP spokeswoman declined to comment. An HSBC spokesman didn’t immediately respond to a request for comment."  (The Wall Street Journal, "Huawei Discussed Iran Business with Citi and BNP Paribas, Court Documents Show," 8/22/2019).

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"A US judge Friday ordered BNP Paribas to pay a record $8.9 billion fine to settle violations of US sanctions linked to Iran and other countries. Judge Lorna Schofield finalized a sentence that also included a five-year probation and the imposition of a monitor at France's largest bank. In June 2014, BNP Paribas agreed to plead guilty to criminal charges that it had violated the sanctions, deliberately hiding thousands of transactions with Iran, Sudan and Cuba during 2004-2012 that senior bank officials knew broke US law. At the time, the bank also agreed to the record penalty. In July the court approved the plea agreement. Most of the penalty is based on the amount of the illegal transactions BNP handled: $6.4 billion in Sudan, $1.7 billion in Cuba and $650 million in Iran. In addition, BNP Paribas will pay $140 million in fines. BNP Paribas 'has taken many steps' to address the violations, the bank's chief counsel, Georges Dirani, told the court." (AFP, US orders BNP Paribas to pay $8.9 bn in sanctions case, 5/1/15)

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“BNP Paribas SA pleaded guilty in Manhattan federal court to violating U.S. sanctions after agreeing last week to pay a record $8.97 billion to resolve state and federal probes that reached the highest echelons of French and American diplomacy. BNP, France’s largest bank, admitted it violated the International Emergency Economic Powers Act and the Trading with the Enemy Act by processing almost $9 billion in banned transactions from 2004 to 2012 involving Sudan, Iran and Cuba. U.S. District Judge Lorna Schofield in Manhattan, accepted the plea entered today by Georges Dirani, the company’s top lawyer. She set the bank’s sentencing for Oct. 3… Assistant U.S. Attorney Andrew Goldstein outlined the totality of the bank’s crimes for the judge, citing evidence including banking records, interviews with employees and communications.’BNP engaged in a long-running conspiracy to violate the U.S. embargoes against the Sudan, Iran and Cuba,’ Goldstein said.” (Bloomberg, "BNP Paribas Pleads Guilty in U.S. to Violating Sanctions," 7/9/14)

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"French bank BNP Paribas (BNPP.PA) has pleaded guilty to two criminal charges and agreed to pay almost $9 billion to resolve accusations that it had violated U.S. sanctions against Sudan, Cuba and Iran, in a severe punishment aimed at sending a clear message to other financial institutions around the world…In an unprecedented move, regulators banned BNP for a year from conducting certain U.S. dollar transactions, a critical part of the bank's global business, in addition to the fine which was a record for violating American sanctions.U.S. authorities said the severe penalties reflected BNP's violations going back to at least 2004 and through to 2012 and its drive to put profits first, even after U.S. officials warned the bank of its obligation to crack down on illegal activity." (Reuters, "U.S. imposes record fine on BNP in sanctions warning to banks," 7/1/14)

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"BNP Paribas SA and U.S. prosecutors have agreed to broad terms of a deal in which the bank would pay $8 billion to $9 billion and accept other punishment based on what investigators say is evidence the bank intentionally hid $30 billion of financial transactions that violated U.S. sanctions, according to people close to the probe... A majority of those transactions involved Sudan, though BNP also facilitated such transfers for Iran and other sanctioned countries... About a decade ago, BNP became the preferred bank for Sudanese companies and government officials seeking to do business in dollars without running afoul of U.S. sanctions, according to investigators. In 2007, the bank announced it would no longer do business in Sudan. In the case of Iranian transactions, the bank had to admit as recently as last year that it had found additional transactions for sanctioned entities." (WSJ, "BNP Near Settlement With U.S. for Up to $9 Billion," 6/23/14)

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"U.S. Treasury officials granted BNP Paribas permission to do limited business in Iran earlier this year, as federal prosecutors were negotiating a potentially stiff penalty to resolve the French bank's alleged violations of U.S. sanctions against Iran, Sudan and other countries, according to government records reviewed by The Wall Street Journal. BNP Paribas was granted two licenses allowing the bank to conduct certain commercial and financial transactions in Iran, according to documents obtained through a Freedom of Information Act request. The licenses were granted in February and March as prosecutors sought to punish the bank with a hefty fine, which may ultimately exceed $10 billion, according to people familiar with the matter. Prosecutors are also seeking a guilty plea and a restriction on the company's ability to move cash in the U.S., these people said. It is unclear why BNP sought the Iran licenses or why Treasury officials granted them at a time when authorities were seeking to punish the bank over alleged sanctions violations in that country. Treasury declined to comment." (WSJ, "U.S. Granted BNP Iran Licenses During Penalty Talks," 6/11/14)

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“BNP Paribas SA shares fell Friday, as investors reacted negatively to the prospect of the bank facing more than $10 billion in fines to settle allegations it skirted U.S. sanctions.  Shares in the bank lost as much as 6% in early trading in Paris, dropping below €50 a share ($68).  The push to secure a high-dollar penalty, along with a guilty plea from BNP, stems in part from what prosecutors viewed as the bank's longtime flouting of U.S. economic sanctions against Iran, Sudan and other countries, the people said… ‘We are used to seeing penalties wipe out a quarter's profits, but $10 billion will wipe out a full year for BNP so market reaction will probably be somewhat greater,’ Mizuho credit strategist Roger Francis said. BNP Paribas reported a $6.5 billion net profit for 2013. Excluding one-off losses, including a $1.1 billion provision booked to cover potential U.S. penalties, net profit stood at $8.1 billion in 2013.” (Wall Street Journal, “BNP Paribas Shares Drop After U.S. Pushes for Huge Settlement,” 5/30/14)

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“BNP Paribas is in talks with U.S. authorities to pay more than $3 billion to resolve probes into whether the French bank violated U.S. sanctions on Iran, Sudan and other countries, people familiar with the matter said. The bank warned last month it faced fines in excess of $1.1 billion over the matter, but declined to provide a specific number. The probes are being conducted by the U.S. Justice Department, the U.S. Attorney's office in Manhattan, the U.S. Treasury Department, the Manhattan District Attorney's office, and the New York Department of Financial Services. BNP Paribas declined to comment on Tuesday on the size of any fine. Prosecutors have also pushed the bank to plead guilty to criminal charges as part of a resolution, sources have said. The Justice Department has faced criticism that it has shied away from prosecuting financial companies accused of engaging in misconduct…Last Thursday, BNP Paribas Chief Executive Officer Jean-Laurent Bonnafe and the bank's lawyers met with the New York Department of Financial Services, the state's banking regulator, and made a plea for leniency, one source said. The source said the regulator, led by Benjamin Lawsky, wouldn't revoke the bank's license if other stiff penalties were included in the settlement. Such penalties could include temporarily suspending dollar clearing through New York and terminating more than a dozen employees, though no final decision has been made, the source said.” (Reuters, “BNP Paribas may pay more than $3 billion to end probes: sources,” 5/13/14)

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“BNP Paribas, France’s biggest bank, warned that it might be hit with a fine in the United States “far in excess” of the $1.1 billion it set aside last year to cover litigation costs linked to a potential breach of American sanctions on countries including Iran. The warning is a fresh sign of mounting legal woes for the global banking industry, which has been hit with investigations for a string of alleged misdeeds, including fixing benchmark interest rates and manipulating foreign exchange markets. ‘There is uncertainty with respect to the amount and the nature of penalties the U.S. will impose,’ BNP’s chief financial officer, Lars Machenil, told Reuters Insider television. ‘It’s not impossible that the fine is far in excess of the provision,’ he added. When asked if the fine could reach $2 billion or $3 billion, Mr. Machenil said: ‘There is nothing more to say’…BNP otherwise reported a better-than-expected 5.2 percent rise in first-quarter net income on Wednesday, with the effects of its full takeover of its Belgian subsidiary Fortis last year helping to counterbalance write-downs on assets exposed to the crisis in Ukraine and rising loan losses in Italy.” (New York Times, “BNP Paribas Says U.S. Fine Could Be Much Bigger Than It Had Expected,” 4/30/14)

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"BNP Paribas, France's biggest listed bank, has set aside $1.1 billion for a possible fine for breaching U.S. sanctions on countries including Iran, the latest bank to take a hit to profit from a legal investigation. As well as facing tougher regulations in the wake of the financial crisis, banks across the world are under investigation for a string of alleged misdeeds, including fixing benchmark interest rates and manipulating foreign exchange markets. This month, Credit Suisse set aside 514 million Swiss francs ($570 million) to cover U.S. investigations, while in January Deutsche Bank blamed legal costs for a surprise quarterly loss. BNP said on Thursday it had set aside the funds after talks with the U.S. authorities, though it said there had been no discussion on the size of any potential penalty. ‘We've been doing a retrospective review for several years and we've basically now presented our findings to the U.S. authorities,’ BNP Chief Financial Officer Lars Machenil told Reuters Insider TV…BNP's provision - which was accompanied by restructuring costs and writedowns on the acquisition value of BNP's Italian unit BNL - dragged fourth-quarter net income down to 127 million euros ($173 million) from 519 million a year earlier, offsetting a rise in group revenue and gross operating profit. Analysts had been expecting a net profit closer to 1.0 billion euros, according to a Thomson Reuters poll of analysts.” (Reuters, “BNP sets aside $1.1 bln for possible U.S sanctions fine,” 2/13/14)

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“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)

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"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... 'We are conducting an internal review,' said a spokesman for BNP, citing a disclosure from its 2011 annual report that said the probe concerned 'certain U.S. dollar payments involving countries, persons and entities that could be subject to U.S. sanctions,' adding that hte bank had spoken to American regulators." (Reuters, "French banks investigate potential breach of U.S. sanctions," 8/27/12) 

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"BNP Paribas respects the embargo on Iran," spokesman Ilias Catsaros said. "The bank stopped writing new business in Iran as of 2007 and has since been winding down its existing activities."  The company has received $37.6 million in revenue and benefits from the US government for their investments in Iran during 2000-2009.  Their activities in Iran are currently active with no plan for new investments. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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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," 5/27/06)