Financial Services

Lloyd's of London

Industry
Financial Services
States
CA
IL
KY
NY
Country
UK
Contact Information

[email protected] (President of Lloyd’s North America)
[email protected] (Investor Relations Manager)
[email protected] (general)

Sources

New U.S. sanctions are likely to prevent the use of a Lloyd’s of London IT platform for any Iran insurance, adding to difficulties for European insurers providing cover for the country. (Reuters, "U.S. sanctions seen barring IT platform of insurer Lloyd's for Iran trade," 7/13/2018). 
 

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"A Lloyd’s of London spokesman, on May 10, said the company is also reviewing the implication of “re-imposition of previously suspended U.S. sanctions against Iran and will issue guidance to the Lloyd’s market in due course.”" (5/10/2018)

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On this page ‘http://www.iranianre.com/international-links/’, of the official website of “Iran Re“, there is a list of “Iran Re” business connections with international reinsurance companies, as “SCOR Group“, “Munich Re” and “Lloyd’s of London“, companies who have offices in U.S.

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"The Lloyd's of London insurance market has announced plans to launch offices in Iran – a move that could help the country’s efforts to open its economy to post-sanctions investments. Inga Beale, the CEO of the world's leading specialty insurer, was quoted by Iran’s domestic media as saying that Lloyd's of London would establish branches in Iran’s free trade zones. To the same effect, two Lloyd's directors will soon travel to Tehran to discuss the technicalities for this, Beale was quoted as saying by Iran’s state news agency IRNA.  She made the remarks in a meeting with Abdolnasser Hemmati, the head of Iran’s Central Insurance Company, during a visit to London on Friday. Beale further added that Lloyd's syndicates are interested in returning to the Iranian market." (Press TV, "Lloyd's to open branches in Iran," 11/20/2016)

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"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. Lloyd's of London had historically been active in Iran and chairman John Nelson said it was a "market we would like to get back into". "We have to just be clear, the U.S. sanctions are still very restrictive," Nelson told Reuters." (Reuters, "Cautious Western insurers rebuild business ties with Iran," 10/21/2016).
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"The New York state regulator has called on Lloyd’s of London to provide it with full details of its internal investigation into whether market insurers breached international sanctions by trading with Iran. A 'person familiar with the matter' said New York Department of Financial Services (DFS) superintendent Benjamin Lawsky had asked Lloyd’s for files on the internal probe, Bloomberg has reported. Lloyd’s had told the DFS on 30 July that it had contracts with two firms that were believed to have shipped thousands of tons of alumina to an Iranian firm that provided aluminium for Iran’s nuclear programme, according to the source. A DFS inquiry into whether 20 non-US entities including Lloyd’s were violating the US Iran Freedom and Counter-Proliferation Act of 2012 (IFCPA) was in progress on 1 July, US media reported. A Lloyd’s spokesman said: 'The New York regulator is engaged in an industry-wide review. Lloyd’s takes sanctions compliance very seriously and there is no evidence of any breach. Reviewing all aspects of managing agents’ performance is part of the day-to-day role of overseeing the Lloyd’s market. This includes conforming with all applicable international sanctions, which we have always done.'" (Financial Times, "New York regulator asks Lloyd's for Iran files," 8/30/13)
 
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"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," 7/24/2013)
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"Swiss Reinsurance Co. and Lloyd’s of London, the world’s oldest insurance market, are among companies being probed by a New York regulator about their compliance with an expanded Iran sanctions law. The state Department of Financial Services is asking the insurers about their procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to a letter from the department obtained by Bloomberg News. The department, led by Superintendent Benjamin Lawsky, said it learned that several insurers issued coverage that applied to trades made with Iran, including one policy issued by a group of European domiciled companies, according to the letter. The policy and the resulting claim payment 'would likely violate the IFCPA,' the department said, referring to the act. 'Lloyd’s will comply with any applicable sanctions, as it always has done' said a spokeswoman, Caroline Harris-Gibson, at Prosek Partners." (Bloomberg, "Insurers Quizzed by N.Y. Regulator Lawsky on Iran Links," 7/1/2013).
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"The insurance industry and prominent Democratic lawmakers are attempting to water down a new Iran sanctions bill that would penalize any company that underwrites Iranian affiliates, according to insiders on Capitol Hill . . . The legislation, which is currently working its way through the House, would tighten existing Iran sanctions by punishing any insurance company that underwrites activities that bolster the Iranian oil industry. Insurance providers could be sanctioned for underwriting shipping companies, cargo carriers, or airlines that have been subject to sanctions . . .  The now-bankrupt law firm Dewey & LeBoeuf is said to have moved aggressively against the measure on behalf of its client Lloyd’s of London, an international insurance group, multiple sources told the Free Beacon. Lloyd’s did not respond to a request for comment, and attempts to reach former LeBoeuf lobbyists who worked on the issue were unsuccessful . . . 'If these insurers would stop providing that coverage that companies have to support these risks [of dealing with Iran] on their own,' explained Nathan Carleton, spokesperson for United Against Nuclear Iran, a nonpartisan advocacy group. 'No one should be insuring business with Iran, and if these companies are lobbying to stop these sanctions we would oppose it because it’s not right.'" (Free Beacon, "INSURING AHMADINEJAD," 7/25/12)
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"Lloyd's of London will not insure or reinsure petroleum shipments going into Iran, the insurance market said on Friday, in another blow to the Islamic Republic from wide-ranging U.S. sanctions...'The U.S. is an important market for Lloyd's and, in recognition of this, the market will not insure or reinsure refined petroleum going into Iran,' Lloyd's General Counsel Sean McGovern told Reuters in a statement. 'Lloyd's will always comply with applicable sanctions,' McGovern added." (Reuters, “Lloyd's says won't cover Iran petroleum shipments,” July 9, 2010).
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Lloyd's of London [LOL.UL], the insurance market, is restricting cover for any ships carrying petroleum to Iran, the Financial Times reported on its website late Thursday.   Lloyd's was quoted as saying it would ensure its members complied with new U.S. rules once President Barack Obama signed new sanctions legislation." (Reuters, "Lloyd's Cover for Iran Petroleum Shipments," 7/2/2010)
 
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"Lloyd’s of London, the insurance market, will cut its coverage for refined oil shipments to Iran if the US passes wide-ranging sanctions legislation. Lloyd’s told the Financial Times it would comply with the legislation, versions of which have been approved by both houses of Congress... 'If the legislation is passed and sanctions are put in place by the US, we would comply and ensure underwriters in Lloyd’s were compliant, although we would not want the compliance burden to be disproportionate,' said Sean McGovern, general counsel for Lloyd’s.

Lloyd’s is telling underwriters they would be wise to review their contracts to look for ships heading to Iran. Mr McGovern said it was possible that underwriters would be compelled positively to ensure that a ship they had covered would not be going to Iran. This could take the form of inserting exclusionary clauses in future contracts, specifying that ships would not be covered if they carried goods to Iran." (Financial Times, "Lloyd's to Abide by Any Iran Sanctions," 2/16/10)

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 "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.' A statement from Lloyd's of London said it would take action to ensure any new sanctions were abided by. It said: 'Lloyd’s covers less than 10 per cent of the shipping that carries refined oil to Iran. 'If new sanctions were put in place, we would immediately take action to make sure underwriters were compliant.'" (Daily Mail, "Obama to target Lloyd's of London in plan for tougher sanctions on Iran," 10/2/09)

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"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... The London insurance market said: 'Lloyd’s covers less than 10 per cent of the shipping that carries refined oil to Iran. If new sanctions were put in place, we would immediately take action to make sure underwriters were compliant.'" (Financial Times, "Insurers targeted in Iran sanctions push," 9/28/09) 
Response

 

"Lloyd's of London will not insure or reinsure petroleum shipments going into Iran, the insurance market said on Friday, in another blow to the Islamic Republic from wide-ranging U.S. sanctions."  (“Lloyd's says won't cover Iran petroleum shipments,” Reuters, July 9, 2010).

 

Visa

Industry
Financial Services
Symbol
NYSE:V
States
CA
Country
USA
Contact Information
Sources

"Visa is not able to offer products or services to Iranian banks, merchants or consumers, a source in Visa Inc., US multinational financial services corporation, told Trend. This is due to the ongoing restrictions by the Office of Foreign Assets Control (OFAC) of the US..." (March 14, 2018)

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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. (From bull semen to bras, Iran still buys American, Associated Press, Sharon Theimer, July 9, 2008)

Response

No response at this time.

Tokio Marine

Industry
Financial Services, Shipping
Symbol
TYO: 8766
States
CA
HI
NY
Country
Japan
Sources

"Officials from Japan Tokio Marine Insurance Company discussed issues of mutual interests with Deputy Head of Iran's Central Insurance Company for Reinsurance Mina Sediq Nouhi. In the meeting here on Saturday, Governor of Tokio Marine Insurance Company Eva Koma expressed pleasure for being in Tehran and explained history of company activities in Japan and the Middle East and said that the main activity of the company is in the field of marine insurance. He said that Tokio Marine accompany with two other insurance companies in Japan have 90 percent of Japan insurance market share." (IRNA, "First Japanese insurance interaction with Iran," 10/17/15)

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Listed by U.S. Government as doing business in Iran [formerly known as Millea Holdings Inc.]. (U.S. Securities and Exchange Commission, "List of Companies Doing Business With State Sponsors Of Terror," Removed from the Internet in July 2007)

Response

No response at this time.

MasterCard

Industry
Financial Services
Symbol
NYSE:MA
States
FL
MO
NY
Country
USA
Contact Information
Sources

According to the website Intravel Card, "You can’t use MasterCard in Iran. Due to sanctions, Iran is forbidden to make any USD/EURO transaction to International banking system So, MasterCard in Iran is not accepted nor Credit card and Visa Card or any other debit cards. You can use Iran debit card like IntravelCard instead of MasterCard in Iran."

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In their Annual Report filed with the SEC for fiscal year 2021, Mastercard stated that "Iran and Syria have been identified by the U.S. State Department as terrorist-sponsoring states, and we [Mastercard] have no offices, subsidiaries or affiliated entities located in these countries and do not license entities domiciled there."

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On March 16, 2016, OFAC issued a Finding of Violation to Mastercard that stated: "The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to MasterCard International Incorporated (“MasterCard”) for violations of the Reporting,
Procedures and Penalties Regulations (RPPR), 31 C.F.R. part 501. On October 25, 2007, OFAC designated Bank Melli pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” and Bank Saderat pursuant to Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism,” and added both parties to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”).

At the time OFAC designated Bank Melli and Bank Saderat, MasterCard held accounts in which Bank Melli or Bank Saderat had an interest. MasterCard had previously taken steps to restrict the above-referenced accounts following the issuance of Executive Order 12959 of May 6, 1995, “Prohibiting Certain Transactions With Respect to Iran” (“E.O. 12959”), which prohibited the exportation of goods, services (including financial services), or technology from the United States to Iran. In the time between the issuance of E.O. 12959 and the above-referenced designations, the Bank Melli and Bank Saderat accounts became dormant on MasterCard’s books, but the assets in the accounts nonetheless remained with MasterCard. MasterCard, however, failed to report the accounts to OFAC as blocked following OFAC’s designation of the banks. By failing to properly report the abovereferenced accounts in which Bank Melli and Bank Saderat had an interest, MasterCard violated § 501.603(b) of the RPPR."

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According to its Annual Reports filed with the SEC in 2016, 2017, 2018, and 2019

We identified through our compliance program that for the period covered by this Report, Mastercard processed transactions resulting from:


•certain European acquirers having acquired transactions for consular services with Iranian embassies located in Austria, France and Spain that accepted Mastercard cards
•certain European and Middle Eastern acquirers having acquired transactions for Iran Air, which accepted Mastercard cards, in Austria, France and Qatar

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In 2017 the U.S. state of Michigan listed Mastercard as an Iran restricted company rendering Mastercard ineligible for investment and/or state contracting./ "MasterCard does not have any direct links with Iran due to the primary sanctions still in place, said the Central Bank of Iran’s head of Communications and Information Technology Department.

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“Although the US-based company provides no services in Iran, negotiations are underway with non-US international companies to offer international credit cards to Iranians, which will come to fruition next year,” Nasser Hakimi was also quoted as saying by ISNA." (March 4, 2017)

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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. (Associated Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

Response

No response at this time.

ING Group

Industry
Financial Services
Value of USG Contracts
11
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2004&contractorid=257442&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
AMS: INGA
States
AZ
CA
CT
DE
GA
KS
MN
NJ
NY
NC
PA
TX
VA
WI
Country
Netherlands
Contact Information
Sources

According to its Annual Report filed with the SEC for 2019: "ING has a policy not to enter into newrelationships with clients from these countries and processes remain in place to discontinueexisting relationships involving these countries. At present these countries are Cuba, Iran, North Korea, Sudan and Syria."

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ING Bank maintains a policy not to enter into new relationships with clients from Iran and processes remain in place to discontinue existing relationships involving Iran. (2017)

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ING Chairman Jeroen van der Veer provided a keynote address at the 3rd Europe-Iran Forum on May 3, 2016.  (Europe-Iran Forum Website, “3rd Europe-Iran Forum: Program”). 

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Despite hopes of a new dawn for Iran's economy after nuclear-related sanctions were lifted, major Western banks are reluctant to do business with the Islamic republic for fear of US retribution. President Hassan Rouhani has said that to reach the target of eight-percent growth needed to modernise the industrial sector and relaunch the hobbled economy, Iran needs up to $50 billion in foreign investment every year. But without the big foreign banks, that looks impossible. "For the moment, the little European banks have agreed to work with us," said Parviz Aghili, head of the private Middle East Bank in Tehran. They include banks from Italy, Austria, Switzerland, Germany and Belgium, he said without naming them. "But not a single medium-sized or big bank has so far agreed to do it," he added... The limited number of institutions that do deal with the Islamic republic include Raiffeisen Bank and Erste Bank from Austria, Mediobanca and Banco Popolare of Italy, Germany's EIH, KfW and AKA banks, Belgium's KBC, ING of the Netherlands and Turkey's Halk, according to a banking expert in Tehran. "These banks have established working relations with the Iranian banks to open letters of credit for fairly small sums of 10, 20 or 50 million dollars." But they lack the resources to finance big projects like the deal struck between Iran and European aircraft manufacturer Airbus for 118 airplanes, or oil and gas development projects, the expert said. (AFP, "Iran banking hobbled by Western reluctance to engage," 9/13/2016).

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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 AmroBarclaysCredit SuisseLloyds 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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"ING Bank [a subsidiary of ING Group,] has agreed to pay a record penalty of $619 million for illegally moving billions of dollars through the U.S. banking system on behalf of Cuban and Iranian clients and threatening to fire employees if they failed to conceal the origin of the money . . . the bank, a unit of ING Groep NV, one of the Netherlands largest banks, used a system to 'strip,' or delete, references to Cuba and Iran and, through more than 20,000 separate transactions, successfully moved more than $2 billion through the U.S. financial system . . . [ING] engaged in transactions with Iran's central bank and state-owned National Iranian Oil Co."  (Wall Street Journal, "ING Fined a Record Amount," 6/12/12)

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Noted for conducting business with Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)

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"Dutch bancassurer ING Group NV repeated that it could face 'significant' fines due to a U.S. investigation of operations in countries which are under sanctions by U.S. authorities, such as Iran and Cuba. The United States imposes economic sanctions and export controls on Cuba, Iran, Sudan and Syria, viewing them as state sponsors of terrorism and limiting the scope for companies to do business there... A U.S. judge last August approved a $298 million settlement by British bank Barclays Plc over charges that it had violated U.S. trade sanctions by doing deals in Cuba, Iran, Libya, Sudan and Myanmar."(Reuters, "ING says could face fines following U.S. investigation," 7/27/10) 

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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)

Response

No response at this time.

Daewoo International

Industry
Financial Services
Value of USG Contracts
12
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2000&contractorid=298366&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
KS: 047050
States
CA
Country
South Korea
Contact Information
Sources

Daewoo International is a subsidiary of South Korean Steel Company POSCO

Company website lists branch in Tehran, Iran as part of its "Global Network." (Company website)

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"Daewoo International maintains an office in Iran, according to its website. It is an international trading company involved in everything from chemicals to construction. Daewoo Corporation won construction contracts from the  U.S. Army Corps of Engineers while Daewoo International fell under its corporate umbrella. Daewoo International was subsequently spun off and today is a separate company."  The company received $10.4 million from the US government for their investments in Iran during 2000-2009.  Their business in Iran is currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

Response

No response at this time.

Bank of Tokyo-Mitsubishi UFJ

Industry
Banking
Value of USG Contracts
1
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2006&recipientid=257386&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
JP: 8315
States
CA
GA
IL
KY
MN
NY
TX
WA
Country
Japan
Contact Information
Sources

"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)

Response

“We are determined to continue our efforts to ensure full compliance with the evolving laws and regulations relating to Iran sanctions.”