Financial Services

"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).

--

According to its Annual Report filed with the SEC for fiscal year 2018: " During the fourth quarter of 2018, Citibank Europe plc, a subsidiary of Citibank, acting as an intermediary bank processed a transaction between two Irish banks involving the Iranian Embassy in Ireland. The total value of the payment was EUR 90.00 (USD 104.24). This transaction was for visa-related fees and is exempt pursuant to the travel exemption of the Iranian Transactions and Sanctions Regulations. Citibank Europe plc realized nominal fees for the processing of this payment."

--

According to its 2017 SEC filing – “During the third quarter of 2017, Bank Handlowy w Warszawie S.A., a Citibank subsidiary located in Poland, processed three funds transfers involving the Iranian Embassy in Poland.  The value of the funds transfers was EUR 50, EUR 50, and EU 100 (approximately $60.00, $60.00 and $117.00), respectively.  In addition, a branch of Citibank N.A., located in India, processed a funds transfer involving the Iran Consulate General in India.  The total value of this payment was INR 1,368 (approximately $21.00).  These payments were for visa-related fees and Iran-related travel respectively.”

--

According to its Annual Report filed with the SEC for fiscal year 2015: "In addition to Citi’s prior disclosures, a subsidiary of Citi, Banco Nacional de México (Banamex), identified that it inadvertently processed five domestic funds transfers to the Embassy of Iran in Mexico during the third quarter of 2015.  The total value of these five funds transfers was approximately MXP 3,320 (approximately $177.00).  Three of the payments were for visa services that are exempt under Office of Foreign Assets Control (OFAC) regulations and two were for consular services that going forward would be permissible under OFAC General License H for Banamex as a non-U.S. subsidiary of Citi.  The transactions, in aggregate, resulted in approximately MXP 10 (approximately $0.53) in revenue for Banamex."

--

Over the last three presidential administrations, the United States government has granted Citigroup 37 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

--

"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…Citibank disclosed that its branch in Bahrain made $4 in profit in the second quarter by processing ATM transactions involving Future Bank, a joint venture whose owners include two Iranian-linked banks barred from doing business with U.S. companies…And though Citibank’s ATM fees were minimal, the bank involved was partly owned by Bank Saderat, which has been on the Treasury Department’s sanctions list since 2006 for being a 'conduit' between Iran and Hezbollah, the militant Shiite Muslim movement based in Lebanon." (Washington Post, "Under new law, companies disclosing even tiniest dealings with Iran," 12/4/13)

--

"OFAC granted a license on Dec. 27, 2007, to Citibank authorizing it to make good on an agreement its Japanese subsidiary had entered into in October. The bank had agreed to confirm that certain conditions in a letter of credit had been meet, after which a Malaysian exporter of split-system air conditioners to Turkey would be paid. Then the bank discovered that the goods were to be shipped aboard a vessel called the Iran Ilam that was owned by the Iranian government-run shipping line known as Irisl, thus requiring that the transaction be licensed. The license was issued even though the Treasury Department and OFAC suspected that Irisl was being used to smuggle goods into Iran in contravention of various embargoes, including banned technology the government needed for its ballistic missile and nuclear programs. Moreover, at the time the license was issued, the United States had evidence that five months earlier, the Iran Ilam itself had delivered a lathe that could be used to make precise metal parts needed for nuclear centrifuges from China to Iran’s Shahid Bagheri Industrial Group, according to government officials who requested anonymity to speak about an intelligence matter. Indeed, within months of issuing the license, OFAC announced at a news conference that the United States was adding Irisl to a special blacklist, after an investigation found that Irisl had falsified cargo records, relied on front companies and used other trickery to mask the true nature and destination of shipments. At the September 2008 news conference announcing the decision, OFAC's director, Adam J. Szubin, warned that banks and companies worldwide should be aware that they could be unwittingly aiding Iran’s quest for banned technology by doing business with Irisl: 'Irisl’s deceptive practices make it nearly impossible to determine whether its shipments are licit or illicit,' he said. Mr. Szubin acknowledged in an interview that he was under no obligation to issue the license to Citigroup, given that banks were already prohibited generally from doing business with Iranian entities. But he said that OFAC had issued licenses in cases like this in the past in which the bank had no way of knowing that Irisl was involved and Irisl would have been paid by a foreign third party anyway. To depart from that norm in this case, he added, risked opening up his agency charges of unfair treatment and litigation, and tipping off Irisl that it was under investigation."

"This license is one of at least three that OFAC issued involving the China Great Wall Industry Corporation. The licenses were issued after the Chinese company was added to the United States' special blacklist for supplying components to Iran's ballistic missile development program and before it was removed from the list on June 19, 2008. In one case, the agency licensed the Chinese company's lawyers, who were challenging the blacklisting, to receive legal fees. Two other cases involved wire transactions to or from China Great Wall. OFAC could have forced Citigroup to seize the funds, but said it chose instead to authorize the bank to return the money because China was unlikely to agree that the funds should be seized and therefore the bank would have almost certainly lost a legal battle to keep the funds blocked." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Bank of America's 10-K filed with the SEC for fiscal year 2021 states: "Pursuant to a specific license from the U.S. Treasury Department’s Office of Foreign Assets Control issued on May 28, 2021, during the fourth quarter of 2021, Bank of America, National Association (BANA), a U.S. subsidiary of Bank of America Corporation, processed one authorized wire deposit totaling $327,257 on behalf of a U.S. client into its account at BANA. The wire deposit settled invoices owed to the U.S. client and consisted of unblocked funds belonging to Jammal Trust Bank, which at the time of the deposit was designated pursuant to Executive Order 13224 [because of its links to Hezbollah]."

--

A proposed class action lawsuit "alleges Bank of America has discriminated against consumers of Iranian and Middle Eastern descent by arbitrarily restricting and closing their accounts." (10/21/21)

--

Over the last three presidential administrations, the United States government has granted Bank of America 19 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

--

"OFAC redacted so much of this license file that it is impossible to tell what exactly it authorized, though what is clear is that it was related to another license, granted to BNP Paribas, involving the acquisition of equipment that was of Iranian origin. Bank of America, which was financing the deal, contended that the sale should be licensed because the goods had already been exported to another country." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

According to Blackstone’s website, “Blackstone solicitors provide a wide range of expert legal services specifically to both Iranians living in the U.K. and Iran and to British citizens with Iranian backgrounds.”

--

In March 2017 Blackstone launches new Iran desk.

--

Blackstone Group LP is one of the world's largest financial service companies, specializing in private equity. It owns Hilton Worldwide (Company Website).

--

Hilton is a leading global hospitality with more than 3500 hotels in 81 countries and 130,000 employees. Hilton Worldwide encompasses 10 brands, including Hilton, Conrad, Doubletree, Embassy Suites, Hilton Garden Inn, Hampton Inn & Suites, Homewood Suites, Home2 Suites, and Hilton Grand Vacations (Company Website).

--

UANI has learned that the Hilton Manhattan East will host Iranian President Mahmoud Ahmadinejad's for his stay during the 2010 UN General Assembly.

"Zurich Insurance Group AG (ZURN) is among companies being questioned by New York’s insurance regulator in a widening probe into compliance with an Iran sanctions law, according to a person familiar with the matter. The state Department of Financial Services is asking insurers to explain their policies and procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to the person. The act took effect July 1. ‘The resulting sanctions could jeopardize the ability of any involved insurer to conduct business in the United States,’ the department said in a letter to the insurers obtained by Bloomberg News. ‘Recently, the Department learned that several companies have insured trades made with Iran.’ The regulator, led by Superintendent Benjamin Lawsky, contacted a group of insurers in June about compliance with the law. That group included Swiss Reinsurance Co. (SREN) and Lloyd’s of London. Besides Zurich, other companies contacted in the newest letter are American International Overseas Ltd., AXA Global Risks, and St. Paul Reinsurance Co. Ltd." (Bloomberg, "Zurich Among Insurers Said to Be Probed in Expanded N.Y. Inquiry," 7/24/13)

 --

Zurich Financial Services is an insurance-based financial services provider based in Switzerland, operating in over 170 countries (Company Website). 

Zurich Financial Services lists Iran in its Global Directory (Company Website), and is included in Business Monitor International's Iran Insurance Report (Business Monitor International, subscription required). 

Zurich Financial Services's corporate responsibility policy states that the company "proactively addresses social, environmental and governance issues of rightful concern to our stakeholders" (Company Website).

Lists an office in Tehran, Iran on its company website.

--

"The Health, Safety and Environment Association of Oil Industry Companies of Iran on Friday signed a memorandum of understanding in Tehran with a British corporation on expanding cooperation in the HSE department. Based on the agreement, Lloyd’s Register, a global engineering, technical and business services organization, will provide HSEAOIC with advanced HSE services and training programs, Shana reported." (November 26, 2016)

--

"After coming under pressure from the United States, the ship classification society Lloyd’s Register said in late April that it would close its office in Iran and stop certifying the safety of Iran’s ships." (The Washington Post, "Iran, unable to sell oil, stores it on tankers," 5/14/2012)
--
"Lloyd's Register, a leading maritime risk management firm, has shut its operations in Iran and can no longer vouch for the safety of the OPEC member's fleet due to Western sanctions, the head of the company told Reuters. Lloyd's Register, a classification society that verifies the safety and environmental standards of vessels, has stopped assessing around 60 tankers and container ships owned by Iran's NITC and Islamic Republic of Iran Shipping Lines following pressure from the United States... 'The Americans came to us and said that if we continued to work for the Iranians we would be blacklisted in America,' Richard Sadler, the London-based chief executive of Lloyd's Register, said on the sidelines of a conference in Singapore. 'There was a lot of confusion about the sanctions and actually the recommendations was that it was better for British classification societies within Europe not to be dealing directly with NITC,' he said." (Reuters, "Lloyd's Register withdraws from Iran due to sanctions," 4/26/12)

--

"However, other firms — notably Lloyd’s Register, Bureau Veritas and Germanischer Lloyd — continue to provide services to Iranian and other vessels working in Iranian ports or waters." (Washington Post, "Congress sees shipping-certification firms as tool to tighten Iran noose," 12/5/2011)

--

Lloyd's Register has offices in the Iranian cities of Bandar Abbas, Mahshahr and Tehran. (Lloyd's Register website "List of Offices by Country," February 2010)

--

In 2008, Lloyd's Register America, Inc. acquired Martec, which has performed business in Iran's energy sector. (Martec Press Release)

Has suspended any new marine insurance contracts with Iran; had insured shipping and shipments for Iran following the nuclear agreement. (Carolyn Cohn, Jonathan Saul, "U.S. sanctions seen barring IT platform of insurer Lloyd's for Iran trade," Reuters, July 13, 2018.)

--

Numerous subsidiaries provide insurance to Iran.

--

"Zurich Insurance Group AG (ZURN) is among companies being questioned by New York’s insurance regulator in a widening probe into compliance with an Iran sanctions law, according to a person familiar with the matter. The state Department of Financial Services is asking insurers to explain their policies and procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to the person. The act took effect July 1. ‘The resulting sanctions could jeopardize the ability of any involved insurer to conduct business in the United States,’ the department said in a letter to the insurers obtained by Bloomberg News. ‘Recently, the Department learned that several companies have insured trades made with Iran.’ The regulator, led by Superintendent Benjamin Lawsky, contacted a group of insurers in June about compliance with the law. That group included Swiss Reinsurance Co. (SREN) and Lloyd’s of London. Besides Zurich, other companies contacted in the newest letter are American International Overseas Ltd., AXA Global Risks, and St. Paul Reinsurance Co. Ltd." (Bloomberg, Zurich Among Insurers Said to Be Probed in Expanded N.Y. Inquiry, 7/24/13)

--

In a correspondance with the SEC, AXA disclosed details regarding their investments in Iran.

“There are three non-US subsidiaries of the AXA Group provide insurance coverage to local subsidiaries or branches of entities known by AXA to be controlled by the government of Iran:  AXA UK has entered into insurance relationships with the UK operations of four state-controlled Iranian banks (three advisory relationships and one UK group pension relationship.  AXA Corporate Solutions, a French AXA subsidiary, has underwritten marine and aviation insurance policies for six companies based in Iran.  AXA Spain holds a 10% co-insurance participation in a marine insurance cover for an Iranian ship (AXA Spain took this 10% co-insurance participation under an insurance program covering the fleet of a Spanish fishing company which subsequently sold one of its boats –with its insurance cover- to an Iranian company.  The German branch of an AXA Assistance French subsidiary provides reinsurance coverage for 16 Iranian insurance companies. These reinsurance programs cover compulsory travel insurance for Iranian citizens entering the “Schengen area” (which consists of the European Union states where the free movement of persons is established). (CORRESP for AXA, 12/8/2009) 

"Western insurers are slowly reaching deals with Iran as they seek to re-enter a multi-billion dollar market although the pace of business is hampered by banking restrictions ten months on from the lifting of international sanctions...European export credit agencies are guaranteeing trade finance for Western companies doing business with Iran. Aviation and energy are two sectors in focus, industry executives say, along with political risk cover, even if there have been few deals so far.Other large insurers and reinsurers such as Hannover Re (HNRGn.DE) are looking closely at Iran, but say concerns about payments still prevent them from doing business there.(Reuters, "Cautious Western insurers rebuild business ties with Iran," 10/21/2016).

--

Reuters reported that Hannover Re “would evaluate potential opportunities in [Iran].”  (Reuters, “Global insurers plot cautious course to Iran,” 1/24/2016).  

--

"New York's top financial regulator has expanded a probe into whether reinsurance companies have written policies on international trade with Iran, which could potentially violate new U.S. sanctions. In a letter posted to its website on Wednesday, the state's Department of Financial Services asked reinsurers to explain their dealings with entities and people that have ties to Iran. The department also asked reinsurers to explain procedures in place to ensure compliance with the Iran Freedom and Counter-Proliferation Act of 2012, which took effect on July 1. Twenty reinsurers are getting the letter, including Hannover Re, Lloyd's of London and Swiss Re, a person familiar with the matter said. Those reinsurers were among those contacted last month by the regulator, whose superintendent is Benjamin Lawsky, over their dealings involving Iran… The new law bans financial services companies that do business in the United States, such as insurers and reinsurers, from providing services to companies that trade with Iran. Such a ban can make it harder for shippers to transact with Iran, because they need insurance to protect against the risk of losses on big shipments." (Reuters, "NY Regulator Expands Probe Into Reinsurers' Iran Ties," 7/24/13)

 --

"German reinsurer Hannover Re AG (HNR1.XE) said separately that it conducts a small amount of business in Iran and will only continue to do so if it complies strictly with United Nations and European Union sanctions.

The company said it 'conducts treaty business (proportional and non proportional) and a small amount of facultative business in the Republic of Iran,' without giving figures." (Dow Jones Newswires, "Allianz Suspends Iran Business, Hannover Re Honors Sanctions," 2/19/10)

German insurer Allianz (ALVG.DE) is preparing to wind down Iran-related business due to possible U.S. sanctions, a spokesman said on Tuesday. “We are analyzing our portfolio to identify Iran-related business,” he said in an e-mailed statement. “This analysis is ongoing and we are developing wind-down plans for relevant business to ensure appropriate termination within the defined periods.” (May 15, 2018).

--

Allianz participated in the Iran Post Sanctions Business forum (the “Forum”) in Berlin on January 24-25, 2017. 

--

In January 2016, however, Reuters reported that Allianz “would evaluate potential opportunities in the country [Iran].”  (Reuters, “Global insurers plot cautious course to Iran,” 1/24/2016). 

--

"Allianz SE (ALV.XE), Europe's largest primary insurer by gross premiums, said Friday it is suspending business in Iran amid calls for tighter sanctions against the country after the International Atomic Energy Agency censured Tehran for its nuclear enrichment program.

'Allianz has decided not to renew insurance treaty business in Iran because of political developments in the region. This business amounts to negligible premiums,' Allianz said in a statement, without being more specific." (Dow Jones Newswires, "Allianz Suspends Iran Business, Hannover Re Honors Sanctions," 2/19/10)

Glencore was listed on Texas' 2021 List of Companies Engaging in Scrutinized Business Operations in Iran.

--

As of June 8, 2020, Glencore is listed on the Pennsylvania Department of General Services Iran Free Procurement List. Entities included on this list are ineligible to enter into a contract with the Commonwealth of Pennsylvania for goods and services worth at least $1,000,000 per sections 3501-3506 of the Commonwealth Procurement Code, 62 Pa. C.S. §§ 3501-3506.  

--

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

--

In 2018 the U.S. state of Iowa listed Glencore on its Iran prohibited companies list rendering Glencore ineligible for investment and/or state contracting.

--

“If the U.S. does decertify the nuclear deal, and raises the tension, then inevitably some people will say, well, maybe that is a business that I shouldn’t be involved in,” said Glencore’s (GLEN.L) global head of oil, Alex Beard.

He said dealing with Iran was complex enough without any new U.S. sanctions because of a lack of dollar clearing, as the global banking system is sensitive to the U.S. view on transacting with Iran.

Glencore and Vitol, the world’s No.2 and No.1 oil trading houses, have resumed dealings with Iran since last year." (Reuters, 10/13/2017).

--

"A delegation from European commodities trading giant, Glencore, will visit Iran in the coming weeks to study grounds for mutual cooperation in the mining sector, Mehdi Karbasian, president of state-owned IMIDRO (Iranian Mines and Mining Industries Development and Renovation Organization), said." (November 2017)

--

"Glencore is seeking to increase oil trading with Libya, Iran and Iraq to beat what looks to be a much tougher trading environment compared with last year, Glencore's global head of oil Alex Beard told the Reuters Commodities Summit... Beard said Glencore would be seeking to trade more crude from the Middle East, including Iraq and Iran, as well as from Libya and Russia. "We are currently lifting products from (Iran's) NIOC and private firms and are looking to expand into crude," Beard said, adding he was looking into pre-financing Iranian exports." (Reuters, "Glencore pursues more deals wiht Libya, Iran to beat tough oil trading year," 10/12/2016). 

--

Glencore is listed as an attendee at the Foucs Iran Summit & Exhibition that took place from September 26-27, 2016, in Tehran, Iran. (Participating Companies) 

--

Glencore is listed as an attendee at the Iranian Base Metals Conference that took place from September 6-7, 2016 in Tehran, Iran. (Iranian Base Metals Conference Attendees, 2016).

--

"Glencore PLC and Vitol Group, the world's two largest independent oil traders, are close to signing a long-term deal to purchase Iranian crude, a top Iranian official said. The potential deal would mark the return of two of Iran's biggest oil trading partners before Western sanctions over the country's nuclear program were tightened in 2012... Iran and the two Swiss-based companies are close to reaching separate agreements with state-owned National Iranian Oil Co., said Mohsen Ghamsari, the company's director of international affairs, in an interview. Mr. Ghamsari said one of the main issues to iron out is that the state company wants to choose the destination of the crude that it sells Glencore and Vitol. It isn't unusual for Iran's state oil company-or those in other countries --to dictate where oil traders market their crude. In a separate interview, Iran's deputy oil minister Amir Hossein Zamaninia said Glencore and Vitol have purchased mostly oil products from Iran until now. Glencore-which trades large quantities of oil in addition to the copper, coal and other commodities it mines and sells-became the first Western company to load Iranian oil products since the end of sanctions, but the cargo was made of fuel oil, rather than more expensive crude. It has struggled to find financing for the crude purchase, according to an Iranian trader involved in the deal.” (The Wall Street Journal, "Glencore, Vitol Near Deal to Buy Iranian Crude,” 5/12/2016)

--

"The world's largest commodity trading houses are first in line to profit from the much expected return of Iran to global markets as Tehran and Washington enter into the final three-months of nuclear talks. While the global oil industry has been seen as the biggest beneficiary of a thaw, commodities traders including Cargill Inc. Glencore Plc, Vitol BV, Trafigura Beheer BV and Louis Dreyfus Commodities BV have a long history in Iran, helping to export its oil and import daily basics like gasoline, wheat and rice... 'We like other people have talked to the Iranians,' Vitol CEO Ian Taylor said in an interview. 'They used to be major players in the markets, but obviously none of us will do anything unless sanctions are actually lifted.'" (Bloomberg, "Top Commodity Trading House Line Up for Iran's Return to Market," 4/20/15)

--

"While Western powers have identified a small group of sectors for Iranian sanction relief, a much wider set of European and U.S. companies—from pharmaceutical firms and medical-equipment makers to food companies and traders—also stands to regain lost Iranian trade as soon as relief measures are formally adopted next month…Affiliates of Switzerland-based commodities company Glencore Xstrata sold as much as $111 million in agricultural goods and metals to Iranian state entities in the second quarter of this year, according to disclosures by one of these affiliates to the SEC. A spokesman for Glencore Xstrata declined to comment on its Iranian plans." (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13)

--

"Glencore Xstrata Plc (GLEN), the largest publicly traded commodities supplier, is conducting business with Iran even as competitors abandon the country, potentially drawing scrutiny from regulators. Documents filed with the U.S. Securities and Exchange Commission by Century Aluminum Co. (CENX), in which Glencore owns 41.8 percent, show non-U.S. affiliates of Glencore 'entered into sales contracts for agricultural products as well as purchase contracts for metals with Iranian entities' last quarter…Foreign companies have abandoned Iran after the country’s nuclear program prompted U.S., European Union and United Nations trade sanctions. Glencore competitors Trafigura Beheer BV and Vitol SA have halted crude-oil purchases from Iran as regulators move to end transactions with the Islamic republic. The Iranian entities conducting business with affiliates of Glencore were either fully or majority owned by the government, according to the SEC filing, which was first reported by American Metal Market. Glencore said it’s not violating laws. 'Glencore Xstrata does comply with applicable laws and regulations, including applicable sanctions,' the Baar, Switzerland-based company said in a statement. 'We are closely monitoring all new legal developments to ensure that we continue to be in compliance.' Maintaining trading ties to Iran may draw scrutiny not only of Glencore but of its banks and insurers as well, according to Biersteker. 'They are taking a gamble,' he said. The company may face difficulty insuring transactions and shipping materials, he said…Glencore hasn’t disclosed the names of the companies it’s conducting business with in Iran." (Bloomberg, "Glencore Trades With Iran Even AS Competitors Depart," 8/30/13)

--

"New York's top financial regulator has expanded a probe into whether reinsurance companies have written policies on international trade with Iran, which could potentially violate new U.S. sanctions. In a letter posted to its website on Wednesday, the state's Department of Financial Services asked reinsurers to explain their dealings with entities and people that have ties to Iran. The department also asked reinsurers to explain procedures in place to ensure compliance with the Iran Freedom and Counter-Proliferation Act of 2012, which took effect on July 1. Twenty reinsurers are getting the letter, including Hannover Re, Lloyd's of London and Swiss Re, a person familiar with the matter said. Those reinsurers were among those contacted last month by the regulator, whose superintendent is Benjamin Lawsky, over their dealings involving Iran. Lawsky opened his probe after news reports that Switzerland-based Glencore Xstrata Plc and Trafigura AG had supplied thousands of tons of alumina to an Iranian firm that provided aluminum for Iran's nuclear program. The new law bans financial services companies that do business in the United States, such as insurers and reinsurers, from providing services to companies that trade with Iran." (Reuters, "NY Regulator Expands Probe into Reinsurers' Iran Ties," 7/24/2013)

--

"Glencore, a commodity trading house run by the billionaire Ivan Glasenberg, traded $659m (£430m) of goods, including aluminium oxide, to Iran last year, the Guardian has established... At the time of the Glencore and Trafigura trades with Iralco, it was not illegal or a breach of sanctions to supply Iran with alumina. It is unknown whether Glencore or Trafigura's alumina passed from Iralco to Tesa, or whether it was used in centrifuge construction... Glencore said it 'ceased transactions' with Iralco immediately when it learned of its links with Tesa, and the last trade was in October 2012. 'Prior to EU sanctions in December 2012, we were not aware of a link/contract between Iralco and Tesa,' the company said in a statement. Glencore said it is 'reliant on the relevant regulatory bodies/governments to advise us on developments in who we can/can't do business with'... The question surrounding Glencore's role in unintentionally potentially helping arm a nuclear Iran comes as Obama ramps up pressure on Tehran to end its atomic weapons programme... Mark Wallace, a former US ambassador to the UN, said Glencore's dealings with Iran were 'completely unacceptable', adding: 'We might expect this from a Russian or Chinese company, but the truth is that even those companies usually stay away from this sort of exposure.' Glencore said it 'complies with applicable laws and regulations, including applicable sanctions. We closely monitor all new legal developments to ensure that we continue to be in compliance with applicable laws and regulations, including applicable sanctions.'... The Guardian has learned that Glencore traded $659m worth of metals, wheat and coal with Iranian entities during 2012. Buried deep in its annual report, one of Glencore's US affiliates, Century Aluminum 46% owned by Glencore, states: 'During 2012 non-US affiliates of the largest stockholder of the company [Glencore] entered into sales contracts for wheat and coal as well as sale and purchase contracts for metal oxides and metals with Iranian entities, which are either fully or majority owned by the GOI [government of Iran].' Glencore declined to state how much of the $659m it dealt with Iran in 2012 was related to alumina/aluminium. The trades were not illegal or against sanctions at the time. It is not the first time Glencore's activities have attracted controversy. Last year the head of its food trading business said the worst drought to hit the US since the 1930s would be 'good for Glencore' because it would lead to opportunities to exploit soaring prices." (The Guardian, "Glencore traded with Iranian supplier to nuclear weapon's programme," 4/21/2013) 

--

"Affiliates of Glencore International PLC, the world’s largest publicly traded commodity supplier, entered into sales contracts last year with entities controlled by Iran, according to Century Aluminum Corp. Non-U.S. affiliates of Glencore, Century’s largest shareholder, entered into sales contracts for wheat and coal and sale and purchase contracts for metals and metal oxides, Monterey, California-based Century said today in filing with the U.S. Securities and Exchange Commission...  Century was spun off from Glencore in 1996. Glencore owned 47 percent of Century as of Dec. 31, according to the filing." (Bloomberg, "Glencore Affiliates Sold Commodities to Iran, Century Says," 3/18/2013)

--

"Commodities giant Glencore had supplied thousands of tons of alumina to an Iranian firm that provided aluminum to Iran's nuclear program, Reuters reported last week, citing intelligence and diplomatic sources... Switzerland-based Glencore also said last week that its deal had ended when EU sanctions targeting Iralco came into force. It said its barter contract was legal and denied any wrongdoing by the firm or attempts to help Iran bypass sanctions." (Reuters, "Second trading firm says it supplied Iranian firm linked to atomic work," 3/5/2013)

--

"Commodities giant Glencore supplied thousands of tons of alumina to an Iranian firm that has provided aluminum to Iran's nuclear program, intelligence and diplomatic sources told Reuters. The previously undisclosed barter arrangement between Glencore, the world's biggest commodities trader, and the Iranian Aluminum Company (Iralco) illustrates how difficult it is for Western powers to curb Iran's ability to trade with the rest of the world. Even as the West imposes stringent restrictions on banks that do business with Iran, United Nations diplomats say that Tehran keeps finding new ways to do business with willing partners. Reuters first learned about Glencore's barter deal with Iralco, and an aluminum supply contract that Iralco had with Iran Centrifuge Technology Co (TESA), from a Western diplomatic source in early November. That was about six weeks before the European Union's December 2012 decision to levy sanctions on Iralco for supplying aluminum metal to TESA, which is a subsidiary of the Atomic Energy Organization of Iran (AEOI). The source showed Reuters a Western intelligence report concerning Glencore's arrangement with Iralco. It described how Baar, Switzerland-based Glencore provided Iralco with thousands of tons of alumina last year in exchange for a lesser amount of aluminum metal... It is not known whether any of the aluminum produced by Iralco from Glencore's alumina raw material actually ended up with TESA... In a statement to Reuters, Glencore said it first learned about the TESA-Iralco relationship in December and immediately 'ceased transactions' with Iralco. It said its last actual trade as part of the barter arrangement was in October 2012, two months before the EU move. Glencore acknowledged that it did sign the barter deal with Iralco in August 2011, saying it was perfectly legal and denied any wrongdoing by the firm or attempts to help Iran bypass sanctions. It declined to provide details about the barter deal, the value of which is unclear... Glencore had supplied Iralco with about five tons of alumina for every ton of aluminum that Glencore received in return, according to the intelligence report. Given that on average it takes only about two tons of alumina to produce one ton of aluminum, the barter deal may have left Iralco with more aluminum after processing the alumina than it supplied to Glencore. Iralco covered costs inside Iran, while all activity involving foreign currency payments was covered by Glencore, including shipping costs and insurance, according to the intelligence report. In its statement, Glencore said: 'Glencore complies with applicable laws and regulations, including applicable sanctions. We closely monitor all new legal developments to ensure that we continue to be in compliance with applicable laws and regulations, including applicable sanctions.'... Swiss authorities said they saw no evidence of U.N. or Swiss sanctions violations by Glencore. Iralco is not under U.S. or U.N. sanctions. The intelligence report described the Glencore deal as a good way for Tehran to get around global financial restrictions, though it did not say that Glencore violated sanctions... United Against Nuclear Iran, a U.S.-based lobby group that puts pressure on companies to cut off business with Iran, said Glencore's Iran business was 'reckless and improper' and urged the U.S. government to take action against the trading firm. 'Foreign entities that engage in improper business in Iran should be barred from U.S. markets  and have any U.S. assets frozen,' said Nathan Carleton, the group's spokesman. A banker in London who declined to be identified said the news about Iralco was unlikely to have a direct effect on Glencore's financing... A source close to Glencore said that Iralco received its last alumina shipment from Glencore in September while Glencore received its last delivery of aluminum from Iralco in October. The source declined to comment when asked if the firm continued to do other business with Iran. Glencore announced an end to its fuel sales to Iran in January 2010 to avoid breaching U.S. sanctions. The U.S. Treasury Department declined to comment specifically on Glencore's dealings with Iralco, though a Treasury official told Reuters anyone providing alumina to Iran can face U.S. sanctions under new rules taking effect on July 1... Glencore has been involved in controversies before. It was founded as ‘Marc Rich & Co' in 1974 by Marc Rich, who was charged by the U.S. authorities in the early 1980s with evading taxes and selling oil to Iran during the 1979-81 hostage crisis." (Reuters, "Exclusive: Glencore bartered with firm linked to Iran nuclear program," 3/1/2013)

--

"Switzerland has previously expressed displeasure about sanctions against Iran, largely becaues it has represented U.S. interests in Iran for over 30 years. And, while Switzerland no longer imports Iranian oil, estimates show that one third of the world’s oil deals are brokered by five Swiss-based commodity-trading firms – Glencore GLEN.LN +1.25%, Gunvor, Vitol, Trafigura and Mercuria." (The Wall Street Journal, "Treasury’s Cohen Heads to Switzerland, Turkey for Sanctions Talks," 8/31/2012)

--

"Open sources reported that Glencore sold gasoline to Iran in 2009, but subsequently stopped in 2009." (U.S. Government Accountability Office, Report: "Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009 and June," September 3, 2010)

--

"Glencore, a commodity trading house run by the billionaire Ivan Glasenberg, traded $659m (£430m) of goods, including aluminium oxide, to Iran last year, the Guardian has established... At the time of the Glencore and Trafigura trades with Iralco, it was not illegal or a breach of sanctions to supply Iran with alumina. It is unknown whether Glencore or Trafigura's alumina passed from Iralco to Tesa, or whether it was used in centrifuge construction... Glencore said it 'ceased transactions' with Iralco immediately when it learned of its links with Tesa, and the last trade was in October 2012. 'Prior to EU sanctions in December 2012, we were not aware of a link/contract between Iralco and Tesa,' the company said in a statement. Glencore said it is 'reliant on the relevant regulatory bodies/governments to advise us on developments in who we can/can't do business with'... The question surrounding Glencore's role in unintentionally potentially helping arm a nuclear Iran comes as Obama ramps up pressure on Tehran to end its atomic weapons programme... Mark Wallace, a former US ambassador to the UN, said Glencore's dealings with Iran were 'completely unacceptable', adding: 'We might expect this from a Russian or Chinese company, but the truth is that even those companies usually stay away from this sort of exposure.' Glencore said it 'complies with applicable laws and regulations, including applicable sanctions. We closely monitor all new legal developments to ensure that we continue to be in compliance with applicable laws and regulations, including applicable sanctions.'... The Guardian has learned that Glencore traded $659m worth of metals, wheat and coal with Iranian entities during 2012. Buried deep in its annual report, one of Glencore's US affiliates, Century Aluminum 46% owned by Glencore, states: 'During 2012 non-US affiliates of the largest stockholder of the company [Glencore] entered into sales contracts for wheat and coal as well as sale and purchase contracts for metal oxides and metals with Iranian entities, which are either fully or majority owned by the GOI [government of Iran].' Glencore declined to state how much of the $659m it dealt with Iran in 2012 was related to alumina/aluminium. The trades were not illegal or against sanctions at the time. It is not the first time Glencore's activities have attracted controversy. Last year the head of its food trading business said the worst drought to hit the US since the 1930s would be 'good for Glencore' because it would lead to opportunities to exploit soaring prices." (The Guardian, "Glencore traded with Iranian supplier to nuclear weapon's programme," 4/21/2013) 

--

"Affiliates of Glencore International PLC, the world’s largest publicly traded commodity supplier, entered into sales contracts last year with entities controlled by Iran, according to Century Aluminum Corp. Non-U.S. affiliates of Glencore, Century’s largest shareholder, entered into sales contracts for wheat and coal and sale and purchase contracts for metals and metal oxides, Monterey, California-based Century said today in filing with the U.S. Securities and Exchange Commission...  Century was spun off from Glencore in 1996. Glencore owned 47 percent of Century as of Dec. 31, according to the filing." (Bloomberg, "Glencore Affiliates Sold Commodities to Iran, Century Says," 3/18/2013)

--

"Commodities giant Glencore had supplied thousands of tons of alumina to an Iranian firm that provided aluminum to Iran's nuclear program, Reuters reported last week, citing intelligence and diplomatic sources... Switzerland-based Glencore also said last week that its deal had ended when EU sanctions targeting Iralco came into force. It said its barter contract was legal and denied any wrongdoing by the firm or attempts to help Iran bypass sanctions." (Reuters, "Second trading firm says it supplied Iranian firm linked to atomic work," 3/5/2013)

--

"Commodities giant Glencore supplied thousands of tons of alumina to an Iranian firm that has provided aluminum to Iran's nuclear program, intelligence and diplomatic sources told Reuters. The previously undisclosed barter arrangement between Glencore, the world's biggest commodities trader, and the Iranian Aluminum Company (Iralco) illustrates how difficult it is for Western powers to curb Iran's ability to trade with the rest of the world. Even as the West imposes stringent restrictions on banks that do business with Iran, United Nations diplomats say that Tehran keeps finding new ways to do business with willing partners. Reuters first learned about Glencore's barter deal with Iralco, and an aluminum supply contract that Iralco had with Iran Centrifuge Technology Co (TESA), from a Western diplomatic source in early November. That was about six weeks before the European Union's December 2012 decision to levy sanctions on Iralco for supplying aluminum metal to TESA, which is a subsidiary of the Atomic Energy Organization of Iran (AEOI). The source showed Reuters a Western intelligence report concerning Glencore's arrangement with Iralco. It described how Baar, Switzerland-based Glencore provided Iralco with thousands of tons of alumina last year in exchange for a lesser amount of aluminum metal... It is not known whether any of the aluminum produced by Iralco from Glencore's alumina raw material actually ended up with TESA... In a statement to Reuters, Glencore said it first learned about the TESA-Iralco relationship in December and immediately 'ceased transactions' with Iralco. It said its last actual trade as part of the barter arrangement was in October 2012, two months before the EU move. Glencore acknowledged that it did sign the barter deal with Iralco in August 2011, saying it was perfectly legal and denied any wrongdoing by the firm or attempts to help Iran bypass sanctions. It declined to provide details about the barter deal, the value of which is unclear... Glencore had supplied Iralco with about five tons of alumina for every ton of aluminum that Glencore received in return, according to the intelligence report. Given that on average it takes only about two tons of alumina to produce one ton of aluminum, the barter deal may have left Iralco with more aluminum after processing the alumina than it supplied to Glencore. Iralco covered costs inside Iran, while all activity involving foreign currency payments was covered by Glencore, including shipping costs and insurance, according to the intelligence report. In its statement, Glencore said: 'Glencore complies with applicable laws and regulations, including applicable sanctions. We closely monitor all new legal developments to ensure that we continue to be in compliance with applicable laws and regulations, including applicable sanctions.'... Swiss authorities said they saw no evidence of U.N. or Swiss sanctions violations by Glencore. Iralco is not under U.S. or U.N. sanctions. The intelligence report described the Glencore deal as a good way for Tehran to get around global financial restrictions, though it did not say that Glencore violated sanctions... United Against Nuclear Iran, a U.S.-based lobby group that puts pressure on companies to cut off business with Iran, said Glencore's Iran business was 'reckless and improper' and urged the U.S. government to take action against the trading firm. 'Foreign entities that engage in improper business in Iran should be barred from U.S. markets  and have any U.S. assets frozen,' said Nathan Carleton, the group's spokesman. A banker in London who declined to be identified said the news about Iralco was unlikely to have a direct effect on Glencore's financing... A source close to Glencore said that Iralco received its last alumina shipment from Glencore in September while Glencore received its last delivery of aluminum from Iralco in October. The source declined to comment when asked if the firm continued to do other business with Iran. Glencore announced an end to its fuel sales to Iran in January 2010 to avoid breaching U.S. sanctions. The U.S. Treasury Department declined to comment specifically on Glencore's dealings with Iralco, though a Treasury official told Reuters anyone providing alumina to Iran can face U.S. sanctions under new rules taking effect on July 1... Glencore has been involved in controversies before. It was founded as ‘Marc Rich & Co' in 1974 by Marc Rich, who was charged by the U.S. authorities in the early 1980s with evading taxes and selling oil to Iran during the 1979-81 hostage crisis." (Reuters, "Exclusive: Glencore bartered with firm linked to Iran nuclear program," 3/1/2013)

--

"Switzerland has previously expressed displeasure about sanctions against Iran, largely becaues it has represented U.S. interests in Iran for over 30 years. And, while Switzerland no longer imports Iranian oil, estimates show that one third of the world’s oil deals are brokered by five Swiss-based commodity-trading firms – Glencore GLEN.LN +1.25%, Gunvor, Vitol, Trafigura and Mercuria." (The Wall Street Journal, "Treasury’s Cohen Heads to Switzerland, Turkey for Sanctions Talks," 8/31/2012)

--

"Open sources reported that Glencore sold gasoline to Iran in 2009, but subsequently stopped in 2009." (U.S. Government Accountability Office, Report: "Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009 and June," September 3, 2010)

--

"Glencore, a commodities trader, was a large supplier of gasoline to Iran, but stopped last year in the face of threatened new economic sanctions by the U.S. government.  The company, and its predecessor, Marc Rich and Co., had done business with Iran for more than three decades. It also has provided the United States military with transporation services, among other things."  From 2000-2009, the company has been the recipient of $20.2 million US federal funds.  They have withdrawn their activities in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

--

"Swiss commodities trader Glencore International AG halted gasoline shipments to Iran two to three months ago, people familiar with the matter said, a response in part to the rising prospect of heftier sanctions against the Islamic Republic for its nuclear program. Glencore declined to comment. Glencore has long been one of the biggest gasoline providers to Iran, and the move could frustrate Iran's ability to meet its country's fuel needs…The halt of Glencore's Iran business could also help the company prepare for an anticipated initial public offering. The U.S. House of Representatives last month passed legislation that bars any company that does more than $20 million in oil and gas business with Iran from doing business in the U.S. The Senate is expected to pass the bill early this year." (The Wall Street Journal, "Swiss Firm Halts Its Sales of Gas to Iran," 1/9/09)

--

"Iran typically gets the bulk of its gasoline from the following five firms: Vitol (Switzerland/Netherlands), Trafigura (Switzerland/Netherlands), Reliance Industries Ltd. (India), Glencore (Switzerland) and Total (France)." (Stratfor, "Special Series:Iran Sanctions," September 2009)

 --

"Due to limited refining capabilities, Iran imports approximately 40% of its domestic gasoline consumption. Iran is the second-largest importer of gasoline in the world. That gasoline is supplied primarily by five companies: the Swiss-Dutch energy trading giants Vitol and Trafigura, the Indian multinational Reliance Industries, the Swiss trader Glencore and the French energy firm Total." (The Wall Street Journal, "Hitting Tehran Where It Hurts," 7/13/09)

 --

"Because of a lack of domestic refining capacity, oil-rich Iran is dependent on gasoline imports to meet about 40 percent of domestic consumption. Iran gets most of its gasoline imports from the Swiss firm Vitol, the Swiss/Dutch firm Trafigura, France's Total, the Swiss firm Glencore and British Petroleum, as well as the Indian firm Reliance." (Agence-France Press, "US lawmakers target Iran gasoline imports," 6/23/09)

In 2017, CalSTRS designated Muenchener Rueck as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Muenchener Rueck after reviewing the company’s business with Iran and internal controls to prevent sanction violations.

--

“Meanwhile Munich Re has said it would withdraw from Iran in case of sanctions so as not to jeopardise its much larger US activities.” (France 24, "US pressuring German firms 'daily' over Iran sanctions," 9/20/2018).

--

"The chief executive of reinsurance group Munich Re said it may abandon its Iran business under pressure from the United States, but described the operation as very small." (“China, Germany Defend Iran Business Ties as US Sanctions Grip,” Reuters, August 8, 2018.)

--

"Germany-based Munich Re, the world's largest reinsurer, will stop reinsurance for ships carrying Iranian oil exports on July 1, a spokeswoman said. 'Munich Re will of course continue to monitor future international developments regarding sanctions against Iran and comply with all applicable sanction regulations,' she said."  (The Wall Street Journal, "Japan Seeks Delay to Adjust to Europe's Iran Sanctions," 6/13/12)

--

"On Thursday, Munich Re AG (MUV2.XE), one of the world's largest reinsurers, said it was suspending its business dealings with Iranian companies.

'Due to the political situation in Iran, Munich Re has decided to not renew existing business or write any new business with insurance companies there. This decision will have an impact on Munich Re's premium volume of around EUR10 million,' annually, the company said in a statement. Its total annual premium volume is around EUR41 billion." (Dow Jones Newswires, "Allianz Suspends Iran Business, Hannover Re Honors Sanctions," 2/19/10)

--

"U.S. officials are considering targeting big financial firms including Lloyd's of London in a bid to impose tougher sanctions on Iran over its nuclear programme... The White House is keen to concentrate on Iran's dependence on refined oil imports and insurance firms that underwrite the trade...

Mark Dubowitz, of the Foundation for Defence of Democracies policy institute, said: 'The key fulcrum is the insurance and reinsurance companies. 'It's difficult to ship without insurance and reinsurance...' 'If new sanctions were put in place, we would immediately take action to make sure underwriters were compliant.' Other companies which could be targeted include Munich Re." (Daily Mail, "Obama to target Lloyd's of London in plan for tougher sanctions on Iran," 10/2/09)

--

"The US and its allies are stepping up efforts to push through sanctions on companies that provide Iran with insurance following last week’s revelation that Tehran is building an undeclared nuclear facility.

The move could affect the business of groups such as Lloyd’s of London and Munich Re, hit Iran’s supply of refined oil and bypass the UN Security Council, where both Russia and China have signalled their misgivings about sweeping new sanctions...

Aipac, the pro-Israeli lobby group, has identified groups such as Lloyd’s and Munich Re as providing services to shipments of refined petroleum to Iran... Munich Re said it would review any new financial and trade sanctions." (Financial Times, "Insurers targeted in Iran sanctions push," 9/28/09)