Banking

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In 2018, the U.S. state of Michigan listed Barclays on its state lists of Companies Doing Business with Iran rendering Barclays ineligible for investment and/or state contracting.

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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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"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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"While operating in Iran, the bank received a small contract from the United States Navy. In 2007, the company disclosed to the Securities and Exchange Commission that it was the subject of a Justice Department  investigation into its operations in countries where the United States maintains sanctions, and a spokesperson said the bank terminated all of its business in Iran and other countries subject to sanctions that year. The company, which said in a 2010 disclosure that it was cooperating with the inquiry, declined to comment on the investigation."  The company received $47,381 in revenue and benefits from the US government for their business in Iran during 2000-2009.  The company has since withdrawn their investments in 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)

"Bank of Tokyo-Mitsubishi UFJ (BTMU), Sumitomo Mitsui Banking Corporation and Mizuho Bank have already started transactions with the Iranian banks," said Farhad Taqizadeh Hesari, a senior associate to the head of the Asian Development Bank Institute (ADBI). (5/13/2017).

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Bank of Tokyo-Mitsubishi “has resumed transactions with Iranian banks, including payments for Iranian crude oil bought by Japanese refiners. To avoid transactions in the U.S. Dollar, Bank of Tokyo-Mitsubishi is using Japanese Yen and Euros to handle transactions involving Iranian oil."   (Platts, “Japan's Bank of Tokyo-Mitsubishi UFJ restarts Iran oil transactions,” 2/9/2016).

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

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"More than a year after paying a steep penalty for doing business with Iran, one of the world's biggest banks is back in regulators' cross hairs. New York State's chief banking regulator on Tuesday announced a $315 million settlement with the Bank of Tokyo-Mitsubishi UFJ, accusing the bank of 'misleading regulators' about its business with Iran and other countries blacklisted by the United States. The latest action is an outgrowth of a separate settlement, reached in June of last year, that took aim at the Japanese bank for routing transactions with Iran through New York. The initial settlement drew a $250 million penalty, a sum that was based in part on a report that assessed the extent of the bank's wrongdoing. The report, conducted by the consulting firm PricewaterhouseCoopers, was supposed to be objective." (The New York Times, "Bank of Tokyo Fined for ‘Misleading’ New York Regulator on Iran," 11/18/14)

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"Commerzbank on Thursday warned shareholders it may face considerable fines from U.S. authorities as a result of investigations into alleged embargo breaches with countries like Iran, Sudan and North Korea." (Reuters, "Commerzbank says may pay big to settle Iran case with U.S.," 11/6/14) 

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"New York's banking regulator has demanded $300 million from Bank of Tokyo-Mitsubishi UFJ as part of a potential agreement over sanctions-related violations, according to people familiar with the matter. The demand comes on top of a $250 million settlement Japan's largest bank negotiated with the regulator last year for deleting information from $100 billion in wire transfers that authorities could have used to police transactions with Iran, Sudan, Myanmar and other entities subject to U.S. sanctions. The new penalty stems from the discovery after the June 2013 settlement that the bank had submitted a report that allegedly whitewashed a scheme to falsify transactions for entities subject to the sanctions." (Reuters, "Exclusive - New York demands another $300 million from Bank of Tokyo-Mitsubishi - sources," 11/5/14)

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“Iran will receive $4.2 billion from its oil sales to be transferred in instalments if it fulfils its commitments in a landmark nuclear deal struck between world powers and Tehran in Geneva. Here is a look at where Iranian oil payments are held in the countries in Asia that are still importing crude from the OPEC producer…

COUNTRY: Japan

BANK: Bank of Tokyo-Mitsubishi UFJ

ESTIMATED AMOUNT: The total amount held is unclear, but Japan imported about $4.7 billion worth of Iranian crude between February and September, according to data from the Finance Ministry.” (Reuters, “FACTBOX-Iran's oil fund stash in Asia,” 11/25/13)

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“On Thursday, the state’s top financial authority, Benjamin M. Lawsky, imposed a $250 million fine on the Bank of Tokyo-Mitsubishi UFJ — nearly 30 times what the federal government extracted last year.  The bank, which agreed to settle the New York case, was accused of routing 28,000 payments worth about $100 billion on behalf of Iran and other countries blacklisted from doing business in the United States. In contrast, federal authorities at the Treasury Department cited the bank for processing 97 fund transfers, worth about $6 million…In the Bank of Tokyo-Mitsubishi UFJ case, the bank initially proposed settling with Mr. Lawsky’s agency for roughly $20 million, according to several people briefed on the matter. But Mr. Lawsky balked, the people said, pushing for a bigger fine and additional requirements, like an independent third party to keep an eye on the bank’s activities.  ‘We have and will continue to take a hard line in rooting out misconduct at banks that threatens our national security,’ Mr. Lawsky said in a statement announcing the Bank of Tokyo-Mitsubishi UFJ deal… In the Bank of Tokyo-Mitsubishi UFJ case, he seized on the bank’s attempts to disguise the transfers from Iran. To avoid detection, Mr. Lawsky said, the bank told employees to omit information from wire transfers that could have exposed how the bank was working with an ‘enemy country.’  The bank, Mr. Lawsky said, approved the illegal transfers over at least five years, ending in 2007. The transfers involved ‘government and privately owned entities’ in Iran.  Additionally, the bank had dealings with Sudan and Myanmar. At the time, those countries were all operating under United States sanctions.  In a statement, the Bank of Tokyo-Mitsubishi UFJ said it was ‘committed to conducting business with the highest levels of integrity and regulatory compliance.’ The bank also noted that it voluntarily alerted regulators to its activity and has since moved to bolster its internal controls.” (NYT, “Regulator in New York Sets Tough Bank Fine,” 6/20/13)

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

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

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Bank of Tokyo-Mitsubishi announced that “it had frozen transactions with Iranian banks after being ordered to do so by the New York District Court.”  (Reuters, “Bank of Tokyo-Mitsubishi freezes Iran transactions,” 5/17/2012).  

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

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

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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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"Three Japanese major banks will refrain from doing business with Iran's state-run bank in line with US financial sanctions, reports said Saturday. The Bank of Tokyo-Mitsubishi UFJ, Mizuho Corporate Bank and Sumitomo Mitsui Banking Corp. will not deal with Bank Saderat Iran, the Jiji and Kyodo news agencies said." (Kurdish Globe, "Japan banks to refrain from deals with Iran bank," 9/16/06)

We note the following online reference to an ANZ Bank office apparently
located in Tehran, Iran (http://www.privatebanking.com/directory/middle-east-iran-tehran/banksrep-
offices/anz-bank-26).

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In August 2016 ANZ refused Australian customers’ transactions with Iran, fearing US Treasury’s reaction.

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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 2007)