Banco do Brasil S.A.

On June 7, 2010, BBNY manually added Isfahan Internacional Importadora Ltda (“Isfahan”), a customer of Banco do Brasil, S.A., Brazil (“BB-Brazil”), to its “Good Guy Exception List” after its Office of Foreign Assets Control (OFAC) interdiction software generated alerts on a recurring basis due to the word “Isfahan”—a location in Iran—in the company’s name. Although Isfahan’s line-of-business included the importation of carpets from various countries to Brazil, BBNY relied on verbal representations made to BB-Brazil by Isfahan that Isfahan did not export products to or import products from Iran when it decided to place Isfahan on its “Good Guy Exception List.”